EUDR by commodity

EUDR for Rubber

Rubber is one of the seven EUDR commodities, so natural rubber and many products made from it, including tyres, must be proven deforestation-free and legally produced before sale in or export from the EU. The hard part for rubber is tracing natural rubber through smallholders and processors, and separating it from synthetic rubber in finished goods. This page explains what is covered and what to do.

Orderly rows of rubber trees with latex tapping cups in a plantation

TL;DR

  • Rubber is in scope, covering natural rubber (heading 4001) and many rubber articles such as tyres in Annex I.
  • Products must be deforestation-free (no clearing after 31 December 2020) and legally produced, backed by a Due Diligence Statement.
  • Deadlines: 30 December 2026 for large and medium companies, 30 June 2027 for micro and small ones.
  • The hard part is tracing natural rubber from smallholders and isolating it from synthetic rubber in finished products.
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In scope

What the EUDR covers for rubber

  • Natural rubber in primary forms and as plates, sheets and strip (heading 4001).
  • New pneumatic tyres of rubber (heading 4011), where listed in Annex I.
  • Other rubber articles such as conveyor belts and gloves, where the relevant CN/HS code is listed in Annex I.

Only natural rubber is the regulated commodity. Synthetic rubber is not covered, but products mixing the two are in scope where their CN/HS code is listed, so confirm against Annex I.

These products are listed in Annex I of Regulation (EU) 2023/1115 by their CN/HS customs code, so you confirm scope by matching your product code, not the product name alone.

The hard part

The hard part for rubber

  • Smallholder geolocation: a large share of natural rubber comes from small farms, so collecting plot coordinates (and polygons for plots over 4 hectares) at scale is a major burden.
  • Separating natural from synthetic rubber: many finished goods blend both, so you must establish the natural-rubber content and its origin.
  • Long industrial chains for tyres and components pass through many processors before reaching the EU operator.
  • Aggregated and mixed latex lots make it hard to tie quantities back to specific plots.

The dual test applies throughout: an in-scope product must be both deforestation-free, meaning no clearing after 31 December 2020, and legally produced. Art. 3

Origins and risk

Where it comes from and the risk tiers

Common origins for rubber and their current EUDR risk tier. The tier decides how much due diligence applies, with low-risk origins allowing simplified due diligence. Country benchmarking (2025/1093)

  • ThailandStandard risk
  • IndonesiaStandard risk
  • VietnamLow risk
  • Côte d’IvoireStandard risk
  • MalaysiaStandard risk

The country tier sets how much due diligence applies. Low-risk origins allow simplified due diligence; standard-risk origins need the full process. Tiers can change, as the list is reviewed in 2026.

Look up any country in the country-risk tool.

What to do

What to do for rubber

  1. Confirm scope by matching your rubber products against the CN/HS codes in Annex I.
  2. Establish the natural-rubber content of each product and trace it back to plantations or smallholder plots.
  3. Collect geolocation for every plot, plus country of production, quantities and supplier details.
  4. Check each origin country’s risk tier and run risk assessment and mitigation for standard and high-risk origins.
  5. File a Due Diligence Statement in the EU Information System and pass the reference number down the chain.

For the full obligations and the due-diligence process, see the EUDR obligations guide, and for collecting data from suppliers see the supplier data guide.

Proposed Annex I change for rubber, not yet law

The draft Delegated Act of 4 May 2026 would remove retreaded tyres and some used and second-hand products from Annex I, among other changes. The consultation closed on 1 June 2026 and it is not yet adopted, so treat the current Annex I as the law until that changes. We will update this page if it does. 4 May 2026 simplification review

FAQ

Rubber and the EUDR: common questions

Are tyres covered by the EUDR?
Yes. New pneumatic tyres of rubber fall under Annex I heading 4011. A draft change of 4 May 2026 would remove retreaded tyres, but that is not yet law, so confirm your product by its CN/HS code.
Is synthetic rubber in scope?
No. Only natural rubber is the regulated commodity. Synthetic rubber is not covered, but a finished product that blends natural and synthetic rubber can still be in scope where its CN/HS code is listed in Annex I.
Are rubber gloves or conveyor belts covered?
They are in scope where the specific CN/HS code is listed in Annex I and the product contains natural rubber. Always confirm against the exact codes rather than the general product description.
When does the EUDR apply to rubber?
Large and medium operators and traders must comply from 30 December 2026, and micro and small enterprises from 30 June 2027, where they were established as micro or small by 31 December 2024.
How do I trace natural rubber to the plot?
You work back through processors and dealers to the plantations or smallholder plots, collecting latitude and longitude for each plot, with polygons for plots over 4 hectares. Where lots are mixed, you need a method to establish the origin of the natural-rubber content.

Get ready for the EUDR

Work through the EUDR Readiness Checklist, then explore the tools and guides built for your role.

Get the EUDR Checklist

This is guidance, not legal advice

This is guidance to help you understand how the EUDR applies to rubber, not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser.

Sources

  1. [1]Regulation (EU) 2023/1115, consolidated text including Annex I (EUR-Lex)retrieved 4 Jun 2026
  2. [2]European Commission: Regulation on deforestation-free productsretrieved 4 Jun 2026
  3. [3]European Commission Green Forum: EUDR implementationretrieved 4 Jun 2026
  4. [4]First country benchmarking list under the EUDR (2025/1093)retrieved 4 Jun 2026
  5. [5]Council of the EU: targeted revision (second delay and simplification)retrieved 4 Jun 2026
  6. [6]Commission simplification review of 4 May 2026 (draft Annex I changes)retrieved 4 Jun 2026

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