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EUDR readiness for palm oil mills and estates: the data to prepare

By the Sawitara team (PT Digital Decision Indonesia) · Published · Updated

Status as of 18 October 2026. The EUDR timeline has already been postponed twice. Check the latest dates in official EU sources before making decisions. This article explains the data buyers usually ask for; it is not legal advice, and Sawitara provides no certification or guarantee of compliance.

What the EUDR is

The EU Deforestation Regulation (Regulation (EU) 2023/1115) covers seven commodities, including oil palm and its derivatives. These products may only be placed on, or exported from, the EU market if they meet three conditions (Article 3):

  1. Deforestation-free: produced on land that has not been subject to deforestation after 31 December 2020.
  2. Legal: produced in accordance with the laws of the country of production. This covers land use rights, environmental protection, forestry, third-party rights, labour, human rights, the principle of free, prior and informed consent (FPIC), and tax, anti-corruption and customs regulations.
  3. Covered by a due diligence statement (DDS) submitted by the operator to the EU information system.

Application status as of 18 October 2026

PartyApplies fromBasis
Large and medium operators, downstream operators, traders30 December 2026Regulation (EU) 2025/2650
Micro and small operators, natural persons30 June 2027Regulation (EU) 2025/2650

The timeline so far: originally 30 December 2024, postponed to 30 December 2025 by Regulation (EU) 2024/3234, then to 30 December 2026 by Regulation (EU) 2025/2650, published in December 2025. The 2025 amendment also introduced the category of downstream operator. Only the operator who first places the product on the market submits a DDS. Micro and small operators in low-risk countries need only submit a simplified declaration. As of mid-October 2026, we found no official proposal to change these dates.

In the first country risk classification (Implementing Regulation (EU) 2025/1093, May 2025), Indonesia is rated standard risk. This means EU operators carry out full due diligence, not the simplified version. The classification is scheduled for review in 2026.

What European buyers will ask for

The EUDR binds operators in the EU. Its obligations therefore reach mills and estates in the form of data requests from buyers, exporters or refineries. Due diligence information under Article 9 includes:

  • Geolocation of every plot where the commodity was produced. Latitude and longitude coordinates use at least 6 decimal places. Plots above 4 hectares must be polygons; plots of up to 4 hectares may be a single point (Article 2(28)).
  • Date or time range of production.
  • Name and address of suppliers, and of buyers where relevant.
  • Adequately conclusive evidence of no deforestation, such as a land cover analysis against the 31 December 2020 cut-off.
  • Proof of legal production. In Indonesia this may be land titles (SHM), plantation concession rights (HGU), STDB for smallholders, and plantation business and environmental permits.

Context for international readers. SHM (sertifikat hak milik) is a freehold land title; HGU (hak guna usaha) is the long-term land use right under which plantation companies hold their land; and STDB (surat tanda daftar budidaya) is a smallholder cultivation registration certificate issued by the district estate crops office. These are the documents an EU buyer’s due diligence will most often ask Indonesian suppliers for.

Every plot of origin must be known. European Commission guidance states that products mixed with material of unknown origin cannot be declared compliant. The mass balance model common in certification schemes does not meet this requirement; oil for EUDR buyers needs to be kept separate (segregated).

The data mills and estates should prepare

1. A plot register with geolocation

Build one master list of plots for every FFB source: nucleus estate blocks, plasma plots and third-party supplier plots. Each plot needs a unique code, area, geometry (a point or polygon depending on area), planting date and legality status. Survey polygons in the field with GPS or draw them from imagery; do not use the village office coordinates as a substitute.

2. Traceability of external FFB

The hardest part is usually FFB from ramps, collectors and independent smallholders. One truck can carry fruit from many growers. Prepare:

  • a list of supplying growers for every ramp or collector, with their plots;
  • a record of plot of origin per weighbridge ticket, or per ramp receipt when fruit is combined at the ramp;
  • a firm rule for FFB without plot data: accepted as non-EUDR fruit and kept separate, not blended in.

3. Deforestation and legality screening results

Record for each plot whether land cover screening has been done, when, which tool or provider was used, and the result. Also keep the legality document numbers (SHM, HGU, STDB) with copies. Operators must keep due diligence records for 5 years, so buyers will ask for data that can be traced again later.

4. A document chain through to shipment

Link plots to weighbridge tickets, tickets to daily production, and production to dispatch delivery orders. Without this chain, even complete geolocation is hard to prove for a specific shipment.

Frequently asked questions

Do palm oil mills in Indonesia have to comply with the EUDR?

The legal obligations of the EUDR apply to operators and traders who place products on, or export them from, the EU market. Mills and estates in Indonesia are not directly obliged. However, buyers who sell into Europe will ask their suppliers for plot geolocation data, evidence of no deforestation and proof of legality.

When does the EUDR apply?

As of 18 October 2026, Regulation (EU) 2025/2650 sets the EUDR to apply from 30 December 2026 for large and medium operators, downstream operators and traders. For micro and small operators and natural persons, it applies from 30 June 2027. The date has already been postponed twice, so check official EU sources again.

Is an RSPO or ISPO certificate enough for the EUDR?

Not automatically. A certificate can be supporting evidence, but EUDR due diligence still requires the geolocation of every plot and adequately conclusive information that the product is deforestation-free and legal. Mass balance models that mix in material of unknown origin do not meet the EUDR.

Is one coordinate point enough for a smallholder plot?

For plots of up to 4 hectares, a single coordinate point (latitude and longitude, at least 6 decimal places) is enough. Plots above 4 hectares must be polygons.

How Sawitara helps with record-keeping

In Sawitara Trace (Certification module), the Traceability menu holds the supplier plot register: nucleus, plasma and third-party. Geolocation is stored as GeoJSON and validated against Article 2(28): at least 6 decimals, a polygon required for plots above 4 hectares, and polygons must be closed and must not self-intersect. Each plot also stores an STDB register (number, issue date, issuing agency, document), an SHM/SKT/HGU land title with validity, legality verification by a second officer, and the deforestation screening result. The EUDR & STDB Readiness tab summarises, per supplier or cooperative, what share of plots has an STDB, is verified and has a polygon, with a list of incomplete plots. Screening results are recorded from another tool or provider; Sawitara does not analyse satellite imagery. FFB weighbridge tickets and third-party purchases can be linked to plot codes, and the plot list can be exported as GeoJSON as input for the buyer’s DDS or read by designated buyers through the token-based traceability API. See the flow in the Sawitara Trace video tutorial. Nucleus estate block boundaries are managed in Sawitara Estate. An EUDR overview and how Trace helps are on the EUDR page.

Sawitara helps with record-keeping; it does not guarantee EUDR compliance, and it is neither a certification body nor a certified product. To weigh the value of a record-keeping system for your operation, try the ROI calculator.

Sources

Read nextFFB ramps and collectors: records, deductions, PPh 22 and reconciliationOpen page

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