Most palm scope checks stop at the oil. They look up crude palm oil, find it in Annex I, and move on. The oleochemical half of the chain is where the surprises are: fatty acids, fatty alcohols, glycerol, methyl esters and the soaps and surfactants made from them. These arrive at an EU factory as chemicals with chemical codes, bought from a chemical distributor, and nothing about the paperwork says palm. Under the amended Annex I a large part of that list is in scope, and the test is not the code alone but what the molecule was made from. This guide walks the derivative entries, the qualifier that decides them, and the date they start to bite. Start from the palm oil commodity guide if you have not confirmed the upstream side yet.
The qualifier that decides everything: "synthesized using oil palm"
Commission Delegated Regulation C(2026) 4920, adopted on 13 July 2026, rewrites the oil palm block of Annex I. The important move is not that codes were added. It is that most of the derivative entries now carry ex in front of them plus the words "that have been synthesized using oil palm". Scope follows the input, not the tariff heading. The same customs code can describe an in-scope product and an out-of-scope one, and the customs declaration will not tell them apart.
That has a practical consequence worth absorbing before you audit anything. You cannot answer the scope question from your import data alone. Stearic acid arrives as stearic acid whether it came from palm, from tallow, from coconut or from a synthetic route. The question "is this in scope" is a question for the supplier, and the answer has to be documented, because it is the thing that decides whether a due diligence statement is owed at all.
A second, narrower qualifier sits underneath several entries: products are excluded to the extent they are used in manufacturing medicinal products for human or veterinary use. A pharmaceutical-grade stream of the same acid can therefore fall outside while the industrial stream falls inside.
The derivative entries, by family
The amended list groups into four recognisable families. Every entry below is qualified by the palm-origin test above.
| Family | Headings | What it looks like on an invoice |
|---|---|---|
| Fatty alcohols | ex 2905 16, ex 2905 17 00, ex 2905 19 00 | Octanol, lauryl, cetyl and stearyl alcohol; surfactant feedstock |
| Glycerol | ex 1520 00, ex 2905 45 | Crude glycerol and refined glycerol at 95 % purity or above |
| Fatty acids, salts and esters | ex 2915 39, ex 2915 70, ex 2915 90, ex 2916 15, ex 2916 19 10 | Palmitic, stearic, oleic, linoleic acids and their methyl esters |
| Industrial acids, alcohols and soap | ex 3823 11 00, ex 3823 12 00, ex 3823 19, ex 3823 70 00, ex 3401 11 00, ex 3401 20 | Industrial stearic and oleic acid, fatty alcohols, soap bars and flakes |
The residue entry moved too: oilcake from palm nuts or kernels is now ex 2306 60 00 rather than the whole heading, which matters to animal feed buyers who had read the old entry as covering everything under it.
Methyl esters: the distinction people get wrong
Fatty acid methyl esters are the most searched corner of this list and the one most often described loosely. Two things are true at once. Methyl esters of palmitic and stearic acid sit inside ex 2915 70, which covers those acids together with their salts and esters, and methyl esters of oleic, linoleic and linolenic acid sit inside ex 2916 15. Where they were made from oil palm, they are in scope.
Biodiesel is the other half of the sentence, and it went the other way. Inclusion of biofuels under heading 3826 was assessed alongside this amendment and was not among the changes adopted. So a fatty acid methyl ester sold as an oleochemical intermediate and the chemically similar ester sold as a biodiesel blend component are not treated alike. If your product sits near that line, the classification you use at import decides the obligation, and it is worth checking rather than assuming.
What counts as oil palm, and what does not
A new table note narrows the commodity itself. Oil palm means Elaeis species, including Elaeis guineensis. It expressly does not cover babassu oil from Attalea species, or vegetable oils from other palm trees. A derivative synthesised from babassu is outside the regulation even though the trade would call the feedstock a palm oil. Coconut, another common oleochemical feedstock, was never a relevant commodity in the first place.
This is where a scoping exercise built on the word "palm" rather than on the species produces the wrong answer in both directions, and it is the kind of distinction that only shows up when someone reads the annex rather than a summary of it.
The date, and why it is not the same date as everything else
Every derivative entry added by this amendment carries the same parenthetical: the provision applies from 30 December 2027. That is a year after the main application date for large operators, so a company that is in scope only through derivatives has more runway than one importing crude oil. The entries that were merely re-qualified rather than newly inserted follow the ordinary timetable, which for most operators is 30 December 2026, or 30 June 2027 for micro and small enterprises.
The amendment was adopted on 13 July 2026 and enters into force the day after it is published in the Official Journal, so the deletions elsewhere in the same act take effect before these additions do. Treat the two directions as separate dates rather than one event.
What an oleochemical buyer actually has to do
- List the codes, then ask the origin question. Pull every import line under the headings above. For each supplier and each product, get a written answer on whether the material was synthesised using oil palm. Codes alone cannot close this.
- Establish which role you hold. If the derivative you buy is already covered by an upstream statement, you are likely a downstream operator and keep reference numbers rather than filing. The operator, trader and downstream comparison settles which one applies.
- Decide how mass balance is handled. Oleochemical plants blend feedstocks by design. A book-and-claim or mass-balance certificate is a sustainability instrument, not a geolocation record, and it will not by itself produce the plot data Article 9 asks for. Segregated supply is the only arrangement that keeps plots attached to product.
- Get the plot data to the mill, then past it. The break in a palm chain is almost always at the mill, where estate and smallholder fruit is combined. The palm oil guide covers mill supply-base mapping; a derivative buyer inherits that problem two or three steps removed from it.
- Re-run the scope check on the amended list, not the original one. The product scope guide carries the amended table.
The uncomfortable summary for anyone buying chemicals rather than commodities: you are being asked to know something about a molecule that your purchase order was never designed to record. Fixing that is a supplier-qualification job, and there is a year and a half to do it.