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Which rubber goods are in Annex I — and which aren’t

Rubber is the seventh EUDR commodity, but the regulation does not sweep in all of chapter 40. It lists specific headings, and the exact code of your product decides the answer. The in-scope entries most rubber importers deal with are: [Reg. 2023/1115, Annex I]

• 4001 — natural rubber and similar natural gums, in primary forms or plates, sheets or strip.
• ex 4005 / ex 4006 / ex 4007 / ex 4008 — compounded, unvulcanised and vulcanised rubber in plates, sheets, strip, rods, thread and profile shapes.
• ex 4010 — conveyor or transmission belts or belting, of vulcanised rubber.
• ex 4015 — articles of apparel and clothing accessories, including gloves, mittens and mitts, of vulcanised rubber.
• ex 4016 — other articles of vulcanised rubber (other than hard rubber) not elsewhere specified in chapter 40 — this catches many seals and moulded parts.
• ex 4017 — hard rubber (ebonite) and articles of hard rubber.

Natural versus synthetic: only Hevea rubber is caught

Almost every rubber line in Annex I carries the prefix ex, which means only part of that CN heading is in scope — specifically, the part derived from natural rubber. Natural rubber (HS 4001) tapped from Hevea and similar plants is the relevant commodity; synthetic rubber (HS 4002) made petrochemically is not, and neither are articles made wholly from it. [Reg. 2023/1115, Annex I]

The Commission’s draft delegated act of 4 May 2026 would make this limit explicit, adding an “ex” clarification that only natural-rubber-derived products are covered. As at 10 July 2026 that draft is not adopted and not in force, and the final text may change — but the natural-only reading already follows from the current “ex” entries. [Commission EUDR implementation page] For a mixed-content glove or seal, the practical task is to establish and document the natural-rubber portion.

Are you the operator, or downstream?

The Due Diligence Statement is filed by whoever first places the product on the EU market. [Reg. 2023/1115, Art. 2(15) & Art. 4(1)]

• You import in-scope rubber goods into the EU. You are the operator. You run due diligence and file the DDS before the goods clear customs. [Reg. 2023/1115, Art. 4(1)]
• You buy rubber goods already placed on the EU market by another business. You are downstream. A non-SME downstream operator or trader keeps the upstream DDS reference numbers and records; an SME has the lightest duty. Either way you may not place goods you know are non-compliant. [Reg. 2025/2650]

A non-EU supplier — a glovemaker in Malaysia, say — is not the operator. Its EU customer is. The supplier’s job is to pass the origin data up the chain so the EU importer can file. [Reg. 2023/1115, Art. 4]

What to ask your rubber supplier for

For each in-scope lot, request the information the due-diligence step needs: [Reg. 2023/1115, Art. 9 & Art. 2(28)]

• Plot geolocation — coordinates, and polygons for plots larger than 4 hectares.
• Harvest or production dates.
• Country of production (which sets the risk tier).
• Legality evidence for the country of origin.
• The DDS reference number, where the supplier already filed as the operator.

File the statement in the EU Information System and keep the reference number it returns; that number travels with the goods. [Reg. 2023/1115, Art. 4 & Annex II]

Origin risk tiers for rubber

How much diligence you do depends on where the rubber grew. Implementing Regulation (EU) 2025/1093 benchmarks countries into three tiers. [Impl. Reg. 2025/1093] The main rubber origins sit low or standard: Thailand is low risk (simplified due diligence), while Indonesia and Côte d’Ivoire are standard risk (full due diligence). No major natural-rubber origin is currently high risk. The list is reviewed and can change, so tier each lot by its actual country rather than by reputation.

Which deadline applies

Medium and large operators and traders apply the rules from 30 December 2026; micro and small ones from 30 June 2027, if they met the SME size test (broadly under 50 employees and turnover or balance sheet at or below €10m) by 31 December 2024. [Reg. 2025/2650] Rubber is not timber, so the earlier timber-operator date does not apply.

What this determines — and what it doesn’t

Screening your rubber range tells you scope, role, deadline and the documentary obligations you owe. It does not verify that any plantation is deforestation-free — that depends on the geolocation-plus-evidence your suppliers provide and any satellite check. You don’t need a traceability platform to begin; you need to know which of your SKUs are caught and exactly what to ask your suppliers for.

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. Confirm your classification with counsel before relying on it for a market-access decision.

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