EUDR at 90 Days: What Indian Exporters Still Need to Finish Before 30 December 2026

SUSTAINABILITY & COMPLIANCE

The EU Deforestation Regulation now enters its final compliance window. Large and medium operators must meet full EUDR requirements by 30 December 2026. Small and micro enterprises have until 30 June 2027. After two delays — from the original December 2024 deadline to December 2025, and then to December 2026 — there is no meaningful scenario in which the deadline moves again. The European Commission**'**s mandatory review, completed in April 2026, reaffirmed the timeline while introducing simplification measures rather than further postponement.

For Indian palm oil refiners, soy crushers, leather manufacturers, and the broader agri-trade community supplying the EU, the 90-day question is no longer whether EUDR will be enforced. It is whether your due-diligence statement infrastructure will actually hold up under scrutiny when the first penalties land in 2027.

What EUDR actually requires

At its core, the EUDR covers seven commodities: cattle, cocoa, coffee, palm oil, rubber, soy, and wood — along with a wide range of derived products listed in Annex I. For any of these entering the EU market, operators must demonstrate three things:

• Deforestation-free: Products must not originate from land deforested after 31 December 2020.

• Legal compliance: Products must be produced in accordance with the legislation of the country of production.

• Due Diligence Statement (DDS): A formal statement filed in the EU's TRACES system, linking every commodity shipment to specific plots of land with high-precision geolocation coordinates.

The December 2025 simplification package clarified that only the first operator placing a regulated product on the EU market must submit a full DDS. Downstream operators who trade products already on the EU market are largely exempted from repeat submissions. Small and micro primary operators file a simplified one-time declaration. Printed products (books, newspapers) were explicitly excluded.

None of this changes the core obligation for Indian palm refiners and soy crushers exporting to Europe. If your product is placed on the EU market by your trading partner, the due-diligence chain begins with your geo-data. That data is what will be scrutinised.

CPKO carrying verified EUDR compliance is already commanding a premium of $350 to $400 per tonne over non-compliant volumes.

The Indian exposure

India's direct palm oil exports to the EU are modest — the country is a net importer. But Indian processors play a significant role in the derivative chain. Palm oil derivatives, oleochemicals, and refined products that eventually find their way into European supply chains are fully in-scope.

Soy is a different story. India exports soybean meal and soy oil into European feed and food value chains. Each shipment, under EUDR, must be traceable back to the specific soybean plots of Argentine, Brazilian, or US origin.

The leather industry — not always associated with edible oils but tightly linked to the cattle commodity under EUDR — faces its own compliance burden, affecting several clusters in Tamil Nadu, West Bengal, and Uttar Pradesh.

Where most Indian operators are (honestly) stuck

Based on conversations with trade counsellors, certification bodies, and sustainability leads at leading Indian edible oil companies through Q1 2026, the compliance picture is uneven.

Companies in a strong position are those that started supplier mapping in 2023 or earlier — typically the largest refiners with multinational procurement teams and existing RSPO certification infrastructure. Their geo-coordinate collection is 70 to 90 percent complete. Their DDS automation stack is being tested against TRACES.

The mid-tier — mid-sized refiners and exporters with significant EU exposure — is in the most precarious position. They have the obligation but not the systems. Many still rely on spreadsheet-based supplier tracking. Their palm oil suppliers in Indonesia and Malaysia may or may not have plot-level data. Their soy suppliers in Argentina and Brazil may have aggregated data but not plot-level geocoordinates ready for TRACES submission.

The smallest operators are, paradoxically, somewhat protected. The 30 June 2027 deadline for small and micro enterprises buys them an additional six months. The simplified DDS reduces the immediate data burden. But for these operators, the challenge will be educating the European buyers' downstream compliance teams that the simplification applies.

The pricing story

EUDR is already creating a two-tier palm oil market. CPKO (crude palm kernel oil) carrying verified EUDR compliance is commanding a $350 to $400 per tonne premium over non-compliant volumes in Q1 2026 European trade. Compliant palm olein is trading at narrower but still significant premiums.

For Indian refiners, the strategic question is whether to build EUDR compliance as a revenue opportunity — charging EU buyers the premium — or a cost centre to defend market share. The right answer depends on volume. Below 10,000 tonnes per year of direct EU exposure, the compliance cost is hard to recover. Above that threshold, the economics favour treating EUDR as a premium tier of business.

The practical 90-day checklist

If you are an Indian exporter with EU exposure, these are the questions that need clear answers in the next 90 days:

• Do you know who the 'first operator placing on the EU market' is for each of your regulated product flows? Is it your trading partner, your EU customer, or you? The answer determines who files the DDS.

• Do you have plot-level geo-coordinates for 100% of the volume flowing to EU-bound shipments? Not 80%. Not 95%. 100%.

• Is your data in a format that your EU counterparty's compliance system can ingest — typically GeoJSON for polygons above 4 hectares, point coordinates below?

• Have you reviewed your supplier contracts to include EUDR clauses, with explicit obligation for the supplier to provide geo-data and legality documentation?

• Have you identified an internal DDS submission lead or an external partner who will file on your behalf?

• Have you tested a full DDS submission in TRACES, even if only as a dry run?

What happens at GLOBOIL India 2026

GLOBOIL India 2026 runs from 29 September to 1 October — exactly 90 days before the EUDR enforcement window opens. The programme includes a dedicated EUDR compliance stream, alongside the RSPO plenary led by Dr. Inke van der Sluijs (Director, Market Transformation) and the CPOPC session led by Mdm. Izzana Salleh (Secretary General).

For companies that are not yet fully ready, it is the last major industry forum where the final 90 days can be planned — supplier conversations confirmed, DDS partners lined up, and price strategies finalised.

For companies that are ready, it is the forum where premium pricing conversations with EU buyers will be had.