Yes, soya is one of seven commodities mentioned in the European deforestation regulation (EUDR). But whether your business actually has to deal with it depends on the specific product you import, process or trade, and on the role you play in that supply chain.
The regulation does not govern soya as a crop in general, but a fixed list of products made from soya or containing soya. This includes unprocessed soya beans, but also derived products such as soya oil, soya meal and the expeller cake remaining after oil is pressed from the bean. That last product in particular deserves attention, as it is widely used as a raw material for animal feed. If you trade in soya beans, soya oil or soya meal, there is a good chance your product is on the regulation's list of products.
Where it often goes wrong: soya as part of something else
A frequently asked question is whether the EUDR applies to products that contain soya as an ingredient but are not themselves sold as "soya". Think of compound animal feed for pigs or poultry, soya milk, tofu or soya sauce, or animal feed in which soya is one of several raw materials. Whether such a product falls under the regulation depends on its exact composition and the tariff code under which it is imported. A product containing soya does not automatically fall under the commodity "soya", and conversely, a product that at first glance has nothing to do with soya may still fall under the product list because soya is a principal component.
This is also the reason why traders tend to read the regulation either more broadly or more narrowly than it is. Both approaches carry risk: anyone who wrongly believes they fall outside the scope misses an obligation; anyone who wrongly believes everything falls under the regulation builds files for products where that is unnecessary. The precise scope is set out in the regulation's official text and its annexes, and if you are in doubt about a specific product, enquiry with customs or a lawyer is the appropriate route.
Another misunderstanding: soya in animal feed and meat or dairy
Some importers of meat, dairy or eggs wonder whether they also have to meet soya obligations through their supplier's animal feed. That is a logical thought, as much livestock is fed with soya meal. However, the regulation treats cattle and products derived from cattle as a separate commodity category, with its own product list. Whether and how the origin of animal feed plays a role in this is something the regulation's text and the European Commission's guidance clarify, not a general assumption. Drawing your own conclusions on this matter for your specific supply chain is precisely the kind of question for which custom legal advice is intended.
The role and entry date remain separate from the question of whether soya is in scope
If your product is on the list, that does not mean the obligations apply to you tomorrow. The EUDR has different entry dates, depending on the combination of your role in the supply chain and the size of your business. An importer of soya oil has a different position than a trader who resells soya meal only within the EU, and a small business gets a different date than a large one. The date that applies to your situation you determine in a few questions| without first having to go through the entire regulation.
For those working with soya, it is advisable to first establish clearly which product category the imported goods fall under before investing time in building a file. That first step, determining the scope, is different from assessing the risk of the country of origin or gathering geolocation data; those come later. An overview of how those follow-up steps fit together can be found in the knowledge base with explanations by topic|.
If you are uncertain whether your specific soya product falls under the Regulation, that is a question worth raising with customs or an adviser with knowledge of CN codes in your sector. What we can do for you is make clear which role and which obligation applies to your situation once it is clear that your product is in scope, and how other SMEs in comparable supply chains handle this is described on the page where we explain how the information is compiled|.
Do you want to know quickly where you stand with your soya product? Take the free role check or browse through the topics in the knowledge base; both take you a few minutes and provide immediate initial direction.