RSPO and Legislation

Effective: from 30 December 2025, from 30 June 2026 for SMEs.

Legal implication

Applies to companies placing commodities associated with deforestation on the EU market, regardless of origin. Regulations come into force at ports and entry points across the EU for commodities derived from seven commodities – wood, palm oil, rubber, soy, cattle, cocoa and coffee.

How does this impact the sustainable palm oil sector?

Companies will have to comply with the obligation to conduct due diligence on legality and provide traceability data.

Is RSPO relevant in this process?

With RSPO Certification, RSPO Members:

• are better prepared and equipped to deal with the EUDR as they already have relevant processes in place;
• could be subject to fewer checks by EU Member States’ National Competent Authorities as they have indicated that they might consider reputable certifications like RSPO as a risk mitigation tool in deciding where to allocate their scarce resources. Article 10.2.j of the EUDR explicitly recognises third-party verified schemes as tools which can be used by companies in their risk assessment, which will be an important element for our members to demonstrate compliance with that part of the regulation.
• are able to show that they go beyond the EUDR legal minimum requirements (no deforestation and legality), thus instilling trust among their stakeholders.

Effective as of Q1 2027, with a widened scope of companies until 2029

Applies to large companies operating in the EU (meeting certain size thresholds)

Legal implication

This will require companies and their upstream and downstream partners, including supply, production and distribution to prevent, end or mitigate their adverse impacts on human rights and the environment. Such impacts include for example: slavery, child labour, labour exploitation, biodiversity loss, pollution or destruction of natural heritage. Companies will need to step up all relevant due diligence processes in place.

Is RSPO relevant in this process?

Multiple documents stemming from audits could servethe companies’ due diligence processes. The RSPO currently aims to develop its processes and optimise the digitalisation of documents to best support its members in performing due diligence, notably through the development of a new tool, prisma.

Note: *In February 2025, proposals to change certain elements of CSRD and CSDDD were put forward and are currently being assessed by EU co-legislators.  

Effective since Jan 2023

Applies to large companies operating in the EU (meeting certain size thresholds)

Legal implication

Mandates large companies to track and report their sustainability performance, using European Sustainability Reporting Standards (ESRS).             

How does this impact the sustainable palm oil sector ?

EU companies with connections to the global supply chain would require their suppliers to provide ESG information to meet the disclosure requirements of CSRD.

Is RSPO relevant in this process?

Multiple documents stemming from audits could support companies’ reporting requirements and help them perform the double materiality assessment. 

Note: *In February 2025, proposals to change certain elements of CSRD and CSDDD were put forward and are currently being assessed by EU co-legislators. 

Effective: Controls will start as of 14 December 2027 (date of entry into application of the legislation)

Legal implication

The EU FLR prohibits products made with forced labour (including child labour) from being placed on the EU market or exported from the EU. The law will apply to all goods, both produced inside the EU and outside the EU. 

How does this impact the sustainable palm oil sector?

This legislation is expected to become a lex specialis for due diligence. With the expected additional guidance to be provided by the European Commission, the Regulation should complement the supply chain monitoring obligations set under the CS3D.

Is RSPO relevant in this process?

The RSPO has a robust system in place to detect occurrence of forced labour during the production of sustainable palm oil. It is complemented by an open grievance mechanism. As a multi-stakeholder platform, RSPO also helps its members have a comprehensive view over their supply chains and to engage in dialogues with affected communities. 

Applicable timeline for entry into application is unknown – file still under negotiations

Legal Implication

This proposal requires companies to substantiate claims they make about environmental aspects or performance of their products and organisations using robust, science-based and verifiable methods. 

How does this impact the sustainable palm oil sector?

The RSPO welcomes the proposal for the Green Claims Directive as an important step to tackle misleading claims and greenwashing. The legislation represents an opportunity to shine a light on legitimate, robust and scientifically-supported claims.