No. EUDR does not cover coconut. Regulation (EU) 2023/1115 names seven relevant commodities, and coconut is not among them. No coconut customs code appears in Annex I.
That answer holds for desiccated coconut, coconut milk and cream, coconut water, coconut flour, coconut sugar, and crude and refined coconut oil. None of them needs a due diligence statement.
The question still reaches the desk most weeks, and the confusion is well founded. Customs heading 1513 carries coconut oil and palm kernel oil under the same four digits. EUDR was drafted one level down, at six. Read the rule at four-digit resolution and you get the wrong answer in two directions: paying for due diligence nobody owes, or missing the one product family where coconut and the Regulation genuinely collide.
Which commodities does EUDR actually cover?
Seven. Article 2(1) defines relevant commodities as “cattle, cocoa, coffee, oil palm, rubber, soya and wood”. The list is closed, and widening it needs a legislative amendment rather than a delegated act.
Coconut has never been proposed as an eighth. The Regulation’s review clause points at maize, wooded land, other natural ecosystems and biofuels as candidates for extension. Coconut appears nowhere in that work.
Oil palm means the oil palm, not palms in general. That single distinction carries the whole answer.
Why CN 1513 causes the confusion
Heading 1513 is titled “Coconut (copra), palm kernel or babassu oil, and fractions thereof”. Three crops, one heading. Annex I picks up half of it.
| CN subheading | Product | Listed in EUDR Annex I |
|---|---|---|
| 1513 11 | Coconut (copra) oil, crude | No |
| 1513 19 | Coconut (copra) oil, other than crude | No |
| 1513 21 | Palm kernel and babassu oil, crude | Yes, under oil palm |
| 1513 29 | Palm kernel and babassu oil, other than crude | Yes, under oil palm |
Both listed entries are printed in Annex I with descriptions naming palm kernel and babassu. Neither mentions coconut. Copra oil has never sat in Annex I in any version of the text.
The mirror case is worth carrying in your head. Babassu is not oil palm either, yet babassu oil is caught today, because the drafters wrote subheadings rather than species. Scope follows classification, not botany.
Confirm your own ten-digit code in TARIC before relying on any of this. The tariff line decides which row you are in, not the product name on the invoice.
Does a listed code alone trigger a due diligence statement?
No. Two conditions have to hold together. The code must appear in Annex I, and the goods must actually contain or be made using the commodity named in the left-hand column of that same row.
Article 2(2) defines relevant products as products listed in Annex I “that contain, have been fed with or have been made using relevant commodities”. The Commission’s FAQ, version 5 of April 2026, states it directly: “the HS codes listed in Annex I are only pertinent to identify which products are captured by the EUDR”. The same document confirms that goods under an Annex I code which are not made of the corresponding commodity fall outside the Regulation.
That FAQ says on its face that it is not legally binding. Useful for planning, thin as a defence.
Where coconut can still collide: industrial fatty acids
One family of products carries real exposure. Annex I lists four oleochemical subheadings under oil palm: 3823 11 industrial stearic acid, 3823 12 industrial oleic acid, 3823 19 other industrial monocarboxylic fatty acids and acid oils, and 3823 70 industrial fatty alcohols.
None of those four carries an “ex” prefix in the text in force today. Coconut-derived fatty acids and fatty alcohols classify under the same subheadings as their palm kernel equivalents.
That gap shows up at the border. DG TAXUD created document code Y129 so a declarant can state that goods under an affected code fall outside EUDR, and the published condition text says the condition “is only used for ‘ex’ products”. On the face of that design, a coconut-derived fatty acid entered under 3823 19 meets an EUDR import control with no clean route to declare itself out of scope, while the FAQ says it was never in scope.
The Commission has adopted a fix. A delegated regulation of 13 July 2026 rewrites all four entries to carry “ex” and the qualifier “that has been synthesized using oil palm”. It also adds a note stating the Regulation does not apply to babassu oil “and other vegetable oils from other palm tree species”.
That act was not in force at the end of August 2026. It sits in a scrutiny period of two months from transmission, extendable by two more, in which Parliament and Council may veto but not amend.
Buyers importing coconut oleochemicals should check the live TARIC entry for their exact code before December 2026, and put the question to their broker in writing.
What if you buy coconut and palm blends?
Due diligence follows the ingredient. Where a product mixes a relevant commodity with something else, the Commission requires due diligence only on the relevant fraction, using a tyre of synthetic and natural rubber as the worked example. A coconut and palm oil blend needs a statement covering the palm content alone.
Two limits then bite on that palm fraction. Mass balance chains of custody are not accepted. And where a non-compliant part cannot be identified and separated from the rest, the whole product counts as non-compliant.
A blend does not dilute the obligation. It imports one.
What should EU coconut buyers verify in 2026?
Start with the dates, because they have moved twice and stale versions are still circulating. Regulation (EU) 2025/2650, published 23 December 2025, sets 30 December 2026 for large and medium operators and traders. Micro and small operators established as such by 31 December 2024 have until 30 June 2027, though that deferral excludes timber products already covered under the old timber regulation.
Country risk matters only for the palm, soya or rubber lines you buy alongside coconut. The classification list from May 2025 still governs.
| Origin | EUDR country risk | Effect on covered lines |
|---|---|---|
| Sri Lanka | Low | Simplified due diligence |
| Philippines | Low | Simplified due diligence |
| Vietnam | Low | Simplified due diligence |
| India | Low | Simplified due diligence |
| Singapore | Low | Simplified due diligence |
| Indonesia | Standard | Full risk assessment and mitigation |
Low risk is not an exemption. It removes the risk assessment and mitigation steps. The statement itself and plot-level geolocation still apply, and blending low-risk material with standard-risk origin removes the simplification.
Penalties justify the paperwork. Member States must provide for a maximum fine of at least 4% of annual Union-wide turnover, which is a floor on the ceiling rather than a cap.
Then look past EUDR entirely. The instrument that will reach a mid-sized coconut importer is Regulation (EU) 2024/3015, which bars products made with forced labour from the EU market from 14 December 2027. It carries no commodity list, no turnover threshold and no minimum volume.
Private schemes are also stricter than the law here. Rainforest Alliance certification covers coconut oil and refuses any crop grown on land cleared after 2014. Buyers asking coconut suppliers for that certificate are asking for a cut-off six years earlier than the 31 December 2020 date EUDR would never have applied to coconut.
What this means for buyers
- Procurement (persona A): strike EUDR clauses and EUDR surcharges from pure coconut contracts. There is no obligation to price. Redirect that budget to the documents that genuinely travel with the cargo.
- Procurement (persona A): if you buy coconut oil derivatives at CN 3823, treat classification as the live risk and settle it with your broker before December 2026.
- Importers and distributors (persona B): any palm, soya, cocoa or rubber line in the same container programme carries its own statement. Collect the reference numbers, since they must pass down the chain.
- Both: add one question to your supplier qualification pack, asking the supplier to state the exact CN code they declare on export.
FAQ
Is coconut oil covered by EUDR? No. Coconut oil classifies at CN 1513 11 and 1513 19, and neither subheading appears in Annex I. Only the palm kernel and babassu subheadings, 1513 21 and 1513 29, are listed.
Do I need a due diligence statement for desiccated coconut? No. Desiccated coconut is not a relevant product, and no due diligence statement, geolocation data or Information System entry is required for it.
Could coconut be added to EUDR later? Only by amending the Regulation itself, which a delegated act cannot do. No proposal to add coconut exists, and the review clause names maize and biofuels rather than coconut.
Why does my broker flag an EUDR control on my coconut fatty acid? Because CN 3823 subheadings are listed under oil palm without an “ex” prefix. The goods are out of scope in substance. The July 2026 delegated act is designed to close that gap once in force.
Does a low-risk origin such as Sri Lanka remove EUDR obligations? No. Low risk allows simplified due diligence on covered commodities. The statement and plot geolocation still apply, and coconut carries no obligation regardless of origin.
Buying coconut alongside palm or cocoa lines and want the scope question settled per code before December? Send the desk an RFQ.