The EUDR for rubber: what tyre makers, importers, compounders and the rubber goods trade must do by 30 December 2026

In brief

Rubber is the commodity where the recast of Annex I changed the most. Since 18 September 2026, conveyor and transmission belts of heading 4010 and the catch-all heading 4016 for other articles of vulcanised rubber have been deleted. Seals, mats, plugs and profiles are therefore out of scope. At the same time it is now settled that used and retreaded tyres are not covered; all that remains of heading 4012 is the new tread for retreading under 4012 90 30.

The core of the chain stays in scope: natural rubber (4001), compounded rubber and other forms of unvulcanised rubber (4005 and 4006), thread and cord (4007), plates, sheets and profiles (4008), new pneumatic tyres (4011), tyre treads (4012 90 30), inner tubes (4013), apparel and clothing accessories including gloves (4015), and hard rubber (4017). Note 3 to Annex I always applies: only rubber from the rubber tree Hevea brasiliensis counts. Synthetic rubber, reclaimed rubber and waste are not covered, and tubes and hoses of heading 4009 never were.

Due diligence sits with the importer. Thailand, the largest supplier to the EU, is classified as low risk, so simplified due diligence applies. Indonesia, Malaysia and Côte d'Ivoire are standard risk, Myanmar is high risk. Vietnam, India and Sri Lanka are low risk.

For blended products the commodity decides. A tyre usually contains both natural and synthetic rubber. The Commission settled this in FAQ 2.2: due diligence covers only the natural rubber share. There is no de minimis threshold, so even two per cent triggers the obligation.

What to do now: check your article master against the new Annex I and remove the deleted headings, sort origins by country risk, ask suppliers for plot data covering the natural rubber share, record stock in customs warehouses and apply for access to the information system.

Which products are covered

Since 18 September 2026, Annex I applies as amended by Delegated Regulation (EU) 2026/2102. For rubber the list has become shorter, and the changes hit exactly the areas where European manufacturers are strong.

These headings are covered:

Deleted on 18 September 2026:

Heading 4010 for conveyor and transmission belts is gone. Anyone who makes, imports or trades conveyor belting has no obligations for that product under the EUDR any more. The catch-all heading 4016 for other articles of vulcanised rubber has gone too. It covered seals and sealing rings, floor mats, buffers, plugs, sponges, erasers, rubber bands and a large part of technical rubber goods. For many mid-sized makers of technical rubber articles this was the most important change of the year.

Of heading 4012, only the tread under 4012 90 30 remains. Retreaded and used tyres are not covered. The Commission had announced this in FAQ 2.8.1 for the draft delegated act; since 18 September 2026 it is what the annex says.

Never covered:

Synthetic rubber and factice of heading 4002, reclaimed rubber of 4003, waste and scrap of 4004, tubes, pipes and hoses of 4009, hygienic and pharmaceutical articles of 4014 such as condoms and teats, footwear with rubber soles of headings 6401 to 6405, and all vehicles, machines and appliances with rubber parts. The Commission's FAQ names the car with natural rubber tyres as an example of a product outside the scope: the vehicle's CN code is not in Annex I, so the Regulation does not apply even though covered components are built in.

Note 3. All rubber headings carry an "ex" and the reservation in note 3: only rubber from the rubber tree Hevea brasiliensis is covered. Balata, gutta-percha, guayule, chicle and similar natural gums sit in the same CN headings but fall outside the Regulation. That is more than a detail: anyone processing guayule rubber or importing chicle for chewing gum is not affected, but has to be able to evidence the distinction.

How the new Annex I is structured and how to check your own articles against it is in E4 Annex I and CN codes. For a single product with role and deadline there is the T1 EUDR check.

The blend rule: only the natural rubber counts

A passenger car tyre contains natural rubber, several synthetic rubbers, carbon black, silica, steel cord, textile cord, oils and chemicals. Exactly one of these is covered.

The Commission explains this in FAQ 2.2 using the tyre: where a relevant product such as a new pneumatic tyre is made from a mix of synthetic and natural rubber, the operator has to exercise due diligence only for the natural rubber ingredient. No geodata and no production period are needed for steel cord, carbon black or synthetic rubber.

Two consequences matter.

There is no de minimis threshold. Under FAQ 2.3 there is no volume or value threshold below which the Regulation would not apply, including within processed products. A tyre with two per cent natural rubber is caught in the same way as one with thirty per cent. Sorting products by value share sorts them wrongly.

No natural rubber, no obligation. If a product in one of the covered headings contains only synthetic rubber, note 3 does not bite and the Regulation does not apply. That covers many technical articles and some speciality tyres. Do not rely on what sales says about the recipe: obtain a supplier declaration stating the natural rubber content per article and file it with your scope assessment. At an inspection, "contains no natural rubber" is worth exactly as much as the evidence behind it.

The share need not be known, the origin does. The Regulation does not ask for a percentage in the due diligence statement. It asks for geolocation and production period for the commodity contained in the product. In practice that means you need the plots your supplier's natural rubber came from, plus an assurance that nothing else was blended in.

Roles along the rubber chain

Two questions decide the role: who first brings the product onto the EU market, and does processing change the digits of the CN code that Annex I lists.

The importer is the operator. In the rubber chain that is almost always a tyre importer, a raw material trader or a manufacturer sourcing TSR blocks, RSS sheets or latex concentrate directly from Thailand, Indonesia or Côte d'Ivoire. The operator submits the due diligence statement before the goods are released for free circulation and enters the reference number with document code C716 in the customs declaration. That applies even when the goods are imported for its own production and never resold.

Processing in the EU: Annex I lists each stage separately. Unlike coffee, where roasting does not leave heading 0901, the rubber chain changes heading at every major step. Natural rubber (4001) becomes a compound (4005), the compound becomes a tyre (4011), an inner tube (4013) or a plate (4008). Each of these steps changes the digits listed in Annex I. Whoever performs such a step with goods already declared in the EU is a downstream operator under FAQ 3.1.1.

Whoever changes nothing is a trader. Tyre wholesalers, garage suppliers, DIY chains and online retailers buy finished tyres (4011) and sell them unchanged. They are traders, regardless of size.

Whoever turns covered goods into uncovered ones has no role. With 4010 and 4016 deleted, this happens more often in rubber than elsewhere. A manufacturer buying compound (4005) in the EU and making seals from it produces an article outside Annex I and has no obligations for it. The same applies to the retreader buying treads (4012 90 30) and producing retreaded tyres, and to the car maker fitting tyres and selling vehicles.

Nobody is a trader when exporting. Whoever ships tyres bought in the EU to the Great Britain, Switzerland or Türkiye is a downstream operator under FAQ 5.6.1, even if the same company would be a trader domestically. No reference number goes in the export declaration; the Commission has announced a dedicated TARIC certificate code that had not been published on 18 September 2026. Whoever re-exports goods it imported itself, unchanged, remains the operator and makes the reference number available to customs. Details are in E6 export and re-import.

Dual roles are the norm. A tyre maker with a plant in Germany imports natural rubber itself, buys compound from European compounders and sells tyres to the replacement market and to vehicle manufacturers. For the import it is an operator, for tyres made from purchased EU compound it is downstream. It does not have to pass the reference number of its own import statement to customers, but must keep it available for inspections (FAQ 3.8).

Six cases from practice

The tyre importer. A wholesaler with 120 employees imports passenger car tyres from Thailand. Role: operator. Deadline: 30 December 2026. Thailand is low risk, so simplified due diligence under Article 13 applies, without risk assessment and mitigation, as long as nothing points to circumvention or mixing. Geodata for the plots behind the natural rubber share, the production period and evidence of legality are still needed.

The small raw material trader. A family business with 20 employees imports TSR 20 blocks from Indonesia and supplies German compounders. It was established as a small enterprise on 31 December 2024. Role: operator. Deadline: 30 June 2027. Indonesia is standard risk, so full due diligence with risk assessment and mitigation.

The compounder. A compounder buys natural rubber (4001) from a German importer, mixes it with synthetic rubber and fillers and sells ready compounds (4005). Role: downstream operator, because the listed heading changes. Deadline: 30 December 2026. Obligations: no statement of its own, but suppliers, business customers and reference numbers kept for five years, plus registration in the information system as a non-SME.

The tyre plant. A manufacturer buys compound in the EU and builds tyres (4011) from it. Role: downstream operator. Deadline: 30 December 2026. If it also imports natural rubber itself, the operator role is added for that strand.

The retreader. A business buys new treads (4012 90 30) in the EU and retreads truck casings. The result is a retreaded tyre, which is not in Annex I. It has no role for that product. For the purchase of the treads: buying in the EU makes it a customer with nothing further to collect; importing the treads itself makes it the operator for them.

The maker of technical rubber goods. A mid-sized company produces seals, mouldings and floor mats. Since 18 September 2026 these products are no longer in Annex I, so it has no obligations for them. Purchased inputs stay in scope: importing plates (4008) or compound (4005) makes it an operator; buying them in the EU and processing them into uncovered articles leaves it with no role.

The deadlines

30 December 2026 applies to large and medium-sized companies importing rubber or tyres, and to all downstream operators and traders regardless of size.

30 June 2027 applies to operators established as a natural person, micro or small enterprise by 31 December 2024. The exception for timber from the annex of the old Timber Regulation plays no part in rubber, so the deferral applies without that carve-out.

The trap is the same as in other sectors. Article 38(3) grants the deferral to operators only. A tyre dealer with twelve employees buying from a German importer is a trader and therefore bound from 30 December 2026. Its obligations are slim: names and addresses of suppliers and business customers, plus the reference numbers, kept for five years and produced to the authority on request.

Existing stock. Rubber and tyres released for free circulation before the date that applies to the importer are not covered, even if they are sold in 2027. The customs declaration is the evidence. Goods produced before 29 June 2023 are never covered; at import they are declared with code Y132. For tyres, which sit in warehouses for years, a clean stock record with dates pays off, because the DOT code shows when the tyre was made, not when it was placed on the market.

Customs warehouses. Tyres from Asia often sit uncleared in consignment or customs warehouses. While they are there, they have not been placed on the market. Released after 30 December 2026, they need a statement. Whoever buys uncleared from the warehouse and declares the goods for release is the importer and therefore the operator, even if it thinks of itself as a trader.

Origin and country risk

Country risk decides the depth of due diligence and the inspection rate. Implementing Regulation (EU) 2025/1093 governs. It names only the low-risk and high-risk countries; everything not listed is standard risk.

For rubber sourcing that means:

Inspection rates follow the classification: one per cent of operators for low risk, three per cent for standard risk, nine per cent for high risk, plus nine per cent of the volume.

Simplified due diligence under Article 13 removes risk assessment and mitigation, not the statement and not the geodata. And it falls away as soon as there are indications of circumvention or of mixing with goods from other countries. That is the issue in rubber trading: material from several origins runs through the same processors and traders in Singapore or Bangkok. Anyone buying from Thailand who cannot rule out that raw material from a neighbouring country was blended in cannot rely on the simplification.

The list is dynamic. The first review was announced for 2026. Set a reminder so that a reclassification of your main origin does not surface at the next customs transaction.

Geodata from smallholder chains

Most natural rubber comes from smallholders, in Thailand and Indonesia often from farms of a few hectares. Between the tree and the factory gate sit collectors, local dealers and processors who turn cup lump or latex into TSR blocks or sheets. For the EUDR this chain has to be traceable back to the plot.

Point or polygon. For plots up to four hectares a point with six decimal places is enough, above that a polygon is required. Most rubber plots are below that threshold, which helps with collection but increases the number of records.

File size. A due diligence statement must not exceed 25 megabytes. With several thousand plots per batch that is a real limit. Anyone working with polygons should check early whether records need to be aggregated or statements split.

No personal data. Geolocation means coordinates, not the names or ID numbers of farmers. That removes a recurring data protection question in smallholder programmes.

Responsibility stays with the importer. Whether the data come from a cooperative, an exporter or a service provider makes no difference to the operator's responsibility for their accuracy. Contracts should therefore cover not only delivery of the data, but also audit rights and the consequences of false information.

No mass balance. Goods of known origin may not be mixed with goods of unknown origin at any stage. If part of a batch is non-compliant and can no longer be separated, the whole batch cannot be placed on the market. In a chain designed around mixing at the collection point, segregation has to be agreed contractually, mapped technically and checked by sampling.

Timing. Besides the place, the period of production has to be stated. For rubber that is the tapping period, not the shipping date.

Plantation, forest and the cut-off date

One definition matters for rubber that rarely comes up in other chains. Under FAQ 4.14, rubber cultivation counts as an agricultural plantation within the meaning of the Regulation. Agricultural plantations are excluded from the definition of "forest". Both consequences follow:

Where forest was converted into a rubber plantation after 31 December 2020, that is deforestation under the Regulation. Rubber from that land may not enter the EU market. The cut-off date is hard, and replanting elsewhere does not cure it.

Existing plantations, on the other hand, are not forest. Replanting or clearing and replanting on land that was already a plantation before 2021 does not trigger deforestation under the Regulation. The evidence therefore turns on the status of the land at the cut-off date, not on current management.

Rubberwood. Old rubber trees yield a sought-after furniture timber. As soon as it becomes sawn wood, panels or furniture, the wood rules apply with the headings of Chapter 44 and the furniture headings, including the requirements on forest degradation. For rubberwood from an agricultural plantation, the evidence turns on the land not having been forest converted after the cut-off date. The wood side is described in E13 timber industry; the headings differ and the statement is a separate one.

Legality. Alongside deforestation-free status comes legality under the law of the country of production: land use rights, environmental law, labour law, taxes, trade and customs rules. In smallholder chains, land title is the hardest point, because plots are often farmed without formal registration. Clarify early which documents are available in the country of origin at all, and record the assessment.

Customs and the information system

At import, the reference number of the due diligence statement is entered in the customs declaration with document code C716, together with the verification number. Goods produced before 29 June 2023 are declared with Y132. Products outside the Regulation because their CN code is not in Annex I need no coding; within a covered heading from which your article drops out, the relevant Y codes apply. The overview is in the glossary TARIC codes.

For export, the operator makes the reference number available before export. Downstream exporters state no reference number; the announced dedicated certificate code had not been published on 18 September 2026. Agree this with your customs agent in advance so that the first export does not get stuck.

Access to the information system runs through the EU Login followed by registration. Non-SME downstream operators and traders also have to register, even though they submit no statement. How a statement is built and which fields cause trouble is in E2 due diligence statement, and passing on the numbers is covered in E1 reference number.

Germany: competence and state of implementation

For import, export, processing and trade the Federal Office for Agriculture and Food (BLE) is the competent authority. The rubber industry therefore deals with one authority, unlike timber, where the federal states are responsible for primary production.

The national implementing act and the accompanying administrative regulation had not been promulgated on 18 September 2026. That changes nothing about the obligations under the Regulation, which applies directly. What remains open are penalty ranges and procedural questions. Anyone waiting for them before starting to collect data loses the time needed for the countries of origin.

Roadmap to the deadline

1. Check the article master. Match all CN codes against the new Annex I and remove the deleted headings 4010 and 4016 as well as retreaded and used tyres. Document the outcome, including the negative decisions.
2. Clarify the natural rubber content. Record per article whether natural rubber is present and have the supplier confirm it. Set aside articles without natural rubber, with evidence.
3. Determine the role per sourcing route. Look at import, EU purchasing, processing, trade and export separately. Dual roles are the norm.
4. Sort origins by country risk. Thailand, Vietnam, India and Sri Lanka low, Indonesia, Malaysia and Côte d'Ivoire standard. Set up the risk assessment for standard risk.
5. Request the data. Ask exporters and processors for plot data, production period and evidence of legality, with a deadline and a format. The template is in the compass.
6. Agree segregation. Contractually exclude mixing with goods of unknown origin and verify compliance.
7. Record stock. Capture goods in customs warehouses and on consignment with dates and decide what is released before the deadline.
8. System access and internal roles. Apply for registration in the information system, assign responsibility for the statement, customs and record keeping, and put the due diligence system in writing.

For a first view of your role and deadline there is the T1 EUDR check. How the obligations fit together is in the E12 EUDR guide.

Download the compass: EUDR Rubber Compass 2026 with codes and deadlines, the six cases, the template for requesting data from suppliers and the country overview.

Frequently asked questions

Are conveyor belts still covered?

No. Heading 4010 was deleted by Delegated Regulation (EU) 2026/2102 and has not been covered since 18 September 2026. Anyone importing or making conveyor belting has no obligations for it. Purchased inputs such as compound (4005) or plates (4008) remain covered.

Do seals and technical rubber articles fall under the EUDR?

As a rule, no longer. The catch-all heading 4016 for other articles of vulcanised rubber has been deleted. Check the actual CN code though: plates and profiles of vulcanised rubber (4008), thread and cord (4007), hard rubber articles (4017) and clothing accessories (4015) are still in Annex I.

Do I need a statement for retreaded tyres?

No. Retreaded and used tyres are not covered. Only the new tread under 4012 90 30 is. Importing treads makes you the operator for them; buying them in the EU and retreading casings leaves you with no role for the retreaded tyre.

My tyre contains only five per cent natural rubber. Does the EUDR still apply?

Yes. There is no volume or value threshold. Due diligence is limited to the natural rubber share, though: no data are needed for synthetic rubber, carbon black, oils or steel cord.

How do I treat goods from Thailand?

Thailand is classified as low risk under Implementing Regulation (EU) 2025/1093. Simplified due diligence under Article 13 applies: statement and geodata yes, risk assessment and mitigation no, as long as there are no indications of circumvention or mixing. As soon as raw material from another origin could have been blended in, the simplification does not apply.

What about rubberwood?

Rubberwood falls under the headings of Chapter 44 and the furniture headings as wood. It needs a separate due diligence statement and the information on forest degradation. The rubber plantation itself is not forest within the meaning of the Regulation, because agricultural plantations are excluded from the definition of forest.

We sell tyres to the Great Britain. What do we have to do?

Whoever exports tyres bought in the EU is a downstream operator and submits no statement of its own. No reference number goes in the export declaration; the announced TARIC certificate code had not been published on 18 September 2026. Whoever exports tyres it imported itself, unchanged, remains the operator and makes the reference number available to customs.

Does the Regulation apply to guayule or balata?

No. Note 3 to Annex I limits the scope to rubber from the rubber tree Hevea brasiliensis. Balata, gutta-percha, guayule and chicle are not covered, even though they are classified in the same CN headings. You should be able to evidence the distinction.