EUDR soap 2027 – palm oil traceability, CN 3401 and supplier declaration | Word/PDF/Excel

EUDR soap 2027 – new requirements for palm oil-based soap under CN 3401. EU Delegated Regulation (EU) 2026/2102 amends Annex I of the EUDR by adding, among other things, certain soaps that contain or have been manufactured with palm oil. The two new product headings are ex 3401 11 00 (soap in solid forms for toilet use) and ex 3401 20 (soap in other forms). The rules for these new product headings will apply from 30 December 2027.

Quick answer: The package provides Swedish soap manufacturers, importers, and distributors with practical Word/PDF/Excel support for classification, palm raw material, supplier certificates, origin information, EUDR role, batch tracking, and documented internal delivery decisions. You get 7 Word documents, 7 searchable PDFs, and 1 Excel workbook with nine tabs, totaling 15 customer files in a ZIP. The five work templates and the Excel workbook are in Swedish; the guides are available in Swedish and English, respectively.

Who Is the Template For?

Soap manufacturers and private label suppliers, importers of toilet soap, brand owners, wholesalers, purchasing managers, and businesses that sell soap in large volumes. Particularly relevant when the manufacturer uses palm oil or palm derivatives and the product may fall under the new customs codes.

What Changes on 30 December 2027?

The Commission Delegated Regulation (EU) 2026/2102 expands the product list in Annex I to Regulation (EU) 2023/1115 (EUDR). The new soap lines include ex 3401 11 00, soap in bars, cakes, and other solid forms for toilet use that contains or has been manufactured with palm oil, and ex 3401 20, soap in other forms with a corresponding palm oil link. For 3401 11 00, the legal text includes a specific exclusion for certain pharmaceutical manufacturing. The new product headings will have their own application date: 30 December 2027.

Two conditions must be assessed: first, correct CN classification, and second, whether the specific product actually contains or has been manufactured with palm oil. The prefix “ex” means that not all goods under the entire customs code are covered. Not all liquid hygiene products, cleaning products, or cosmetic products are automatically covered. A product name such as “soap” is not sufficient to determine the customs code.

Operator, Retailer, and DDS – Key Differences

The EUDR includes requirements, among others, that certain relevant products must be deforestation-free and produced in accordance with the applicable law in the country of production. In applicable situations, they must be covered by a due diligence declaration or a simplified declaration. However, Amending Regulation (EU) 2025/2650 simplified the obligations for certain downstream operators and traders. A small shop that buys already imported soap does not necessarily have the same obligations as the one that first places the product on the EU market. There are also special rules for micro/small primary operators.

Document 03 helps to establish the actual role before the company decides on its own DDS requirements, registration, or request for a supplier reference. The package does not submit any declaration to the EU information system. Roles and obligations must be assessed against the current legal text and the actual product flow. The EU Commission role guidance explains the differences.

Document by Document

Excel – Nine Tabs

The register tabs are Home, Product & CN, Palm Raw Material, Suppliers, Origin, EUDR-DD, Delivery Hold, Non-conformances, and Sources. They consolidate the most important internal ID numbers for soap, raw materials, suppliers, origin, references, and actions. Everything is delivered without actual customer data or fictional cases.

The Excel workbook has 440 formula cells and validations for, among others, CN code, Yes/No/Unclear for palm oil link, EUDR role, and internal hold. The statuses can show “Record registered – MANUAL ASSESSMENT”, “ASSESS – UNCLEAR PALM OIL LINK”, “Missing record”, or “STOP – INTERNAL HOLD”. The formulas have been tested with fictional IDs and have since been removed. Administrative status is never a legal product classification or approval.

Three Examples for Businesses

1. Solid soap imported with palm derivatives: the company has a soap bar with classification ex 3401 11 00 and confirmed palm oil link. Register the manufacturing batch, request the correct documentation, and assess the operator's obligations before 30 December 2027.
2. Product is called “liquid soap” but has a different CN code: do not assume the product name. Check the actual tariff classification against Annex I. The product's EUDR status cannot be determined without this step.
3. Small retailer in Sweden: the shop sells already imported goods. Assess the company's downstream role and the 2025 simplified rules before requesting that it submit its own due diligence declaration.

Six Steps: How to Get Started

1. Collect item numbers, production batch, and current ingredient or raw material list.
2. Verify the actual CN classification for the soap, preferably with a customs expert when uncertain.
3. Determine whether the product contains or has been manufactured with palm oil – request dated, batch-specific supplier certificates.
4. Assess whether you are an operator, primary operator, trader, or downstream actor under current EUDR.
5. Establish a traceable chain from the palm raw material to the finished soap and document the correct references.
6. Record any contradictions and manually decide on supplementation or an internal delivery pause.

Frequently Asked Questions

When will the EUDR apply to the new soap codes?

The new headings ex 3401 11 00 and ex 3401 20 in Delegated Regulation (EU) 2026/2102 will apply from 30 December 2027. This should be distinguished from the EUDR's general date of 30 December 2026 for medium/large operators and 30 June 2027 for most micro/small businesses.

Are all soaps and liquid cleaning products covered?

No. “ex” indicates subsets of the product codes, and an actual palm oil link is required. The correct classification of an individual product must be determined.

Is palm oil in the ingredient list sufficient to determine EUDR requirements?

No. Also check the product's CN code, the raw material's actual link to palm oil, the current regulatory framework, time period, and your role in the supply chain.

Must all Swedish shops selling palm oil soap create a DDS?

No. Amending Regulation (EU) 2025/2650 simplified the obligations for several downstream actors. The specific role and company size need to be investigated.

Is a sustainability label or a general supplier certificate sufficient?

Not automatically. The relevance of the evidence for the identified raw material, production site, time period, and manufacturing batch must be checked.

Can the template send information to the EUDR digital system?

No. They are editable local documents and a standalone Excel register, not a government integration.

Are all work documents available in English?

No. The five work templates and Excel workbook are in Swedish. You get a Swedish guide and a separate English User Guide. All seven documents come in Word and PDF.

Can the Excel file determine if a soap batch is legal to sell?

No. It only checks registered administrative data. Actual assessment requires legal review, original documents, and correct EUDR/customs classification.

Related Product on Mallbutiken

For a broader, industry-wide program, there is EUDR Due Diligence 2026/2027 – Geolocation, Risk Assessment, and DDS. This new product is more specific: soap under CN ex 3401 11 00 and CN ex 3401 20 with palm oil from December 2027, as well as supplier inquiries and operator roles after the 2025 changes.

Official Sources and Limitations

EUDR (EU) 2023/1115, Delegated Regulation (EU) 2026/2102, Amending Regulation (EU) 2025/2650, the EU Commission's EUDR page, and official role and responsibility guidance.

Document version 1.0 · AI-assisted source check November 12, 2026. No independent legal, customs, or government review has been performed. This is not an official declaration or certificate and does not establish deforestation-free status. Check the current EUDR text, product classification, and your own operator role when applying. The product is sold only after separate publication and linking of digital files in Shopify.