The European Commission has removed soybean seeds EUDR coverage after recognising that seeds for sowing move through a separate, highly controlled value chain with negligible trade volumes and distinct certification, testing and traceability systems.
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The European Commission has removed soybean seeds for sowing from the EU Deforestation Regulation scope after recognising their separate value chain, negligible trade volumes and seed-specific controls.
Europe’s fight against deforestation has a clear objective: products placed on the EU market should not come from recently deforested land or contribute to forest degradation. Few in the seed sector would argue against that ambition.
But Euroseeds warned that one part of the EU Deforestation Regulation, known as EUDR, risked catching the wrong target. The association argued that soybean seeds for sowing should be excluded from the scope of the regulation because they are not part of the commodity flows that drive deforestation.
The European Commission has now taken that argument on board. In its Delegated Regulation amending the list of relevant commodities and relevant products under the EUDR, the Commission removed soya beans used for sowing from the regulation’s scope, recognising that they represent negligible trade volumes and are part of a separate value chain with distinct certification, testing and traceability systems.
Why it Matters
This is not just a win on a narrow customs code. It is a reminder that product scope matters in EU regulation. If seed lots are treated like commodity flows, rules designed to address deforestation risk can unintentionally create barriers for breeding, SMEs and seed movement.
The distinction may sound technical, but for breeders and seed companies it is highly practical. Soybeans used for feed, food or crushing move through large commodity chains. Soybean seeds for sowing, by contrast, are small, highly controlled lots used for breeding, seed multiplication and crop production. Euroseeds argued that treating both in the same way created a regulatory mismatch.
The issue arose because the EUDR scope covered “soya beans, whether or not broken” under CN code 1201. The Commission has now replaced that broad reference with a more specific code that keeps commodity soybeans in scope while removing the sowing category.
Clément Cardon, manager public affairs at Euroseeds, says the EUDR has an important environmental purpose, but regulation also needs to be proportionate. “Soybean seeds for sowing are not commodity soybeans. They are highly controlled seed lots, from the breeding cradle, and used to produce crops and develop better varieties,” he says. The Commission’s adjustment recognises that applying the same deforestation due diligence logic to both, Cardon adds, “would create complexity without adding meaningful environmental benefit.”
What EUDR Is Trying to Do
The EU Deforestation Regulation has been designed to reduce the EU’s contribution to global deforestation and forest degradation. It covers commodities associated with agricultural expansion, including cattle, cocoa, coffee, oil palm, rubber, soya and wood, as well as certain products derived from them.
Operators placing such products on the EU market, or exporting them from the EU, must be able to show that the products are deforestation free, legally produced in the country of production, and covered by a due diligence statement. That includes collecting information such as geolocation data for the plots of land where the relevant commodity has been produced.
For large commodity flows, that logic is understandable. For small seed lots, Euroseeds said the practical result would have been very different. Soybean seeds for sowing are produced, handled and traded under seed specific production and marketing rules. Their function is not to supply crushing plants or feed markets, but to enable crop production and breeding.
A bag of commodity soybeans and a bag of certified soybean seed for sowing might seem similar in theory, but the value chains arise from different systems and rules, with different economic and environmental implications.
Why Seeds Are Different from Commodity Soy
Euroseeds pointed to trade data to support its case. According to publicly available EU COM data, zero per cent of soya beans imported into the EU from Brazil and Argentina in 2024 were for sowing purposes. From the United States and Canada, only 0.2 per cent and 0.3 per cent respectively were destined for sowing. The letter also notes that 26 per cent of soybean imports from Serbia were for sowing, reflecting the role of neighbouring European countries with low deforestation risk.
The Commission’s Delegated Regulation now reflects that reasoning, stating that soya beans used for sowing present negligible trade volumes and are part of a separate value chain with distinct controls.
For seed companies, the issue is also operational. Seed lots already need identity, quality and traceability, principles that are also central to seed certification and global seed trade. Imported seed is subject to controls, including phytosanitary checks and, where relevant, GMO detection testing.
Branislava Popov, technical manager variety registration and seed marketing at Euroseeds, says seeds for sowing are not anonymous bulk commodities. “They move through a regulated system where identity, quality and traceability are essential,” she says.
“For soybean seed, Popov adds, this means the lot is already handled with “a different control level compared to commodity soybeans used for feed or crushing.”
Soybean commodities remain covered by the EUDR. Certified soybean seeds for sowing, however, are now treated according to their actual role and risk profile.
A Small Trade Flow with Big Breeding Consequences
The EUDR question also links to a larger European policy objective: strengthening domestic plant protein production. The European Commission’s own Agri Food Data Portal notes that the EU produces around 5 million tonnes of protein crops per year and remains a traditional net importer of oilseeds. Soybean is therefore part of a wider conversation about protein autonomy, crop diversification and resilience.
Seed World Europe has covered this challenge in several recent articles, including the role of high-performance soybean cultivation in Europe, the Legume Generation project, and efforts aimed at boosting European legume breeding for protein and market growth. A common theme runs through all of them: Europe needs better adapted, higher performing legume varieties if it wants farmers to grow more protein crops.
Access to germplasm is central to that effort. Breeding depends on genetic diversity. For soybean, Euroseeds warned that European breeding programmes already face a narrow genetic base and limited access to diverse material, especially from North America. Additional compliance obligations for importing breeding material could have made that challenge worse.
According to Popov, breeders need access to diverse genetic material to develop soybean varieties that perform under European conditions. “If additional administrative barriers make it harder to bring in breeding material, the effect may not be visible immediately,” she says, “but over time it can slow gene driven innovation.”
Plant breeding is slow, complex and cumulative work. New soybean varieties need to combine yield, maturity, protein content, disease resistance, stability and adaptation to local environments. Europe’s climate conditions are changing, and farmers need varieties that can cope with heat, drought, shifting disease pressure and different production systems.
The Commission’s decision avoids placing an additional administrative layer on a seed category that is already highly controlled and strategically important. It also aligns with the Commission’s Vision for Agriculture and Food, which emphasises a competitive, future proof and resilient agri food sector, and with the EU’s wider ambition to strengthen its plant protein base.
SMEs and the Cost of Complexity
The position paper also highlighted the structure of the seed sector. Many European seed and plant breeding companies are SMEs. According to Euroseeds, 58 private and public organisations have listed the 814 soybean varieties registered in the EU Common Catalogue. Of the 45 private operators, 21 are small and medium enterprises, or around 47 per cent.
For those companies, EUDR due diligence would not have been a light administrative exercise. It can involve geolocation data collection, risk assessment, documentation and recurring compliance steps. For a small seed company importing limited amounts of breeding material or certified seed, the burden would have been disproportionate.
Cardon says the seed sector has a strong SME footprint. “For many companies, the question was not whether they support deforestation free supply chains,” he says. “The question was whether highly technical obligations designed for commodity trade should be imposed on seed lots that do not drive deforestation risk.”
Euroseeds had warned that additional compliance costs could delay seed market entry, disrupt planting schedules and reduce access to high quality seeds for farmers. Even small delays can matter in agriculture, where seasonal timing is everything. The Commission’s decision avoids that risk for soybean seeds for sowing, while keeping commodity soybeans within the EUDR scope.
The European Commission has removed soya beans used for sowing from the scope of the EU Deforestation Regulation.
In the Delegated Regulation adopted on 13 July 2026, the Commission states that soya beans used for sowing represent negligible trade volumes and are part of a separate value chain with distinct certification, testing and traceability systems.
The legal change is made through Annex I of the EUDR. The broad entry “1201 Soya beans, whether or not broken” is deleted and replaced with “1201 90 00 Soya beans, whether or not broken: other.”
In practice, this means commodity soybeans remain within the EUDR scope, while the sowing category is removed.
A Question of Proportion
At its heart, the Euroseeds position was about proportionality. The association supports the environmental objective of the EUDR but argued that regulation should distinguish between products that carry deforestation risk and seed lots that are small, traceable and used for sowing.
The Commission’s decision now reflects that distinction. It is not a loophole, but a way of aligning the regulation with its intended purpose.
According to Cardon, the change should not be seen as weakening the EUDR. “It is about making sure the regulation remains focused on where the deforestation risk actually lies,” he says. The Commission’s targeted clarification for certified soybean seeds for sowing protects the environmental objective, he adds, while avoiding unnecessary burdens for breeders and seed companies.
For the broader seed sector, the outcome is a reminder that product scope matters. The way a CN code is written can determine whether a regulation captures the right value chain or accidentally sweeps in a different one.
“If Europe wants more protein crops, it needs a strong breeding base and reliable access to seed,” says Popov. “Soybean seeds for sowing are part of the solution, not part of the deforestation problem.”
The policy lesson is therefore straightforward: targeted technical corrections matter. In this case, the Commission has kept the EUDR focused on deforestation risk, while giving the seed sector greater clarity to support genetic diversity, innovation and Europe’s protein ambitions.
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