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Which parts are caught

The EUDR covers seven commodities and the products made from them; it does not have a "motor vehicle" line. [Reg. 2023/1115, Art. 1(1) & Annex I] Three of those commodities routinely show up on an automotive bill of materials:

• Rubber — tyres and rubber components. Natural rubber and articles made from it are in Annex I: tyres (HS 4011), and other rubber parts such as hoses, seals, belts and mouldings. Annex I marks these headings with an ex prefix, so only the natural-rubber version is caught — a purely synthetic part is out. [Reg. 2023/1115, Annex I]
• Cattle — leather seats and trim. Cattle hides and leather are in scope at the raw, tanned and prepared stages (HS 4101, 4104, 4107). Leather trim you import as leather is caught today. [Reg. 2023/1115, Annex I]
• Wood — wooden components. Wood is covered broadly under chapter 44, so any solid-wood trim or wooden part falls to be assessed as a wood product. [Reg. 2023/1115, Annex I]

Steel, glass, plastics, electronics and synthetic rubber are not relevant commodities, so most of the vehicle's mass is out. The EUDR question for automotive is narrow and specific: the rubber, the cattle leather and the wood.

Natural rubber vs synthetic — the "ex" distinction

Rubber is the commodity most automotive suppliers meet first, and it comes with an important distinction. Only natural rubber is a relevant commodity; synthetic rubber is not. Annex I therefore carries an ex prefix on the rubber headings, meaning only the portion of that heading made from natural rubber is in scope. [Reg. 2023/1115, Annex I] A tyre made with natural rubber is caught; a seal moulded from a wholly synthetic compound is not. The pending draft delegated act (below) would make the ex wording explicit, but the natural-versus-synthetic line already applies today.

In practice a tyre or component maker often wears two hats: it is the operator when it imports natural rubber to build parts, and it is a downstream operator when it sells those parts on to a vehicle assembler. Which hat you wear on any given part decides whether you file a DDS or reference someone else's. [Reg. 2025/2650]

Leather trim: in scope now, proposed for removal

Cattle leather is in Annex I today, so leather seats and trim you bring in as leather are in scope. [Reg. 2023/1115, Annex I] A draft delegated act published on 4 May 2026 proposes deleting all three leather entries (4101, 4104, 4107), which would take automotive leather out of the regulation. [Commission EUDR implementation page] But as at 10 July 2026 that act is not adopted and not in force — it is a draft, and leather is the most contested item in the review. Keep your leather origin data and DDS references flowing as if leather stays in; stand that work down only if and when the removal is actually adopted, not on the strength of a draft.

Which role are you, part by part?

Role turns on where each in-scope component enters your chain. [Reg. 2023/1115, Art. 2]

• You import the in-scope component (or its raw commodity) into the EU. Importing natural rubber, hides or wood makes you the first operator for that input: you run due diligence and file the DDS before it clears customs. [Reg. 2023/1115, Art. 4(2)]
• You buy the component already placed on the EU market. A Tier-1 supplier or assembler that buys EU-placed tyres, leather or wooden parts is generally downstream: it collects and keeps the DDS reference numbers, and a non-SME also keeps the upstream records and may not place goods it knows are non-compliant. [Reg. 2025/2650]

Deadlines follow the general timetable: 30 December 2026 for medium and large operators and traders, 30 June 2027 for micro and small ones that meet the size test — though a small supplier handling wood should check the timber exception, which keeps some small wood operators on the earlier date. [Reg. 2025/2650]

What to ask your part suppliers for

For each in-scope component, get the origin data for its commodity: [Reg. 2023/1115, Art. 9 & Art. 2(28)]

• Geolocation of the plots — the rubber estate, the pasture, the forest — coordinates, and polygons for plots over 4 hectares.
• Production or harvest dates.
• Country of production (which sets the risk tier).
• Legality evidence for the country of origin.
• The DDS reference number, where the supplier is the operator that filed it — and confirmation of whether a rubber part is natural or synthetic.

What this determines — and what it doesn't

Screening your parts tells you which components are in scope, your role on each, your deadline and the documentary obligations you owe — including a clear read on the pending leather change. It does not verify that any plantation, pasture or forest is deforestation-free; that depends on the geolocation-plus-evidence your suppliers provide and any satellite check. It gives you the map of your automotive obligations, commodity by commodity, not a clean bill on your supply chain.

General information about Regulation (EU) 2023/1115, not legal advice — and not a deforestation assessment. This kind of screening determines your scope, role, deadline and documentary obligations; it does not verify that any plot of land is deforestation-free, and it does not treat the draft May 2026 delegated act as if it were in force. Confirm your classification with counsel before relying on it for a market-access decision.

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