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Which of your products are in Annex I

Rubber joined the EUDR as the seventh commodity, and Annex I lists it by Combined Nomenclature code. For a tyre maker, the two that matter most are natural rubber itself and the finished tyre: [Reg. 2023/1115, Annex I]

• 4001 — natural rubber, balata, gutta-percha, guayule, chicle and similar natural gums, in primary forms or in plates, sheets or strip. This is your raw material.
• ex 4011 — new pneumatic tyres, of rubber. In scope now.
• ex 4012 — retreaded or used pneumatic tyres of rubber; solid or cushion tyres, tyre treads and tyre flaps. Also in scope now (see the retreads section below).
• ex 4013 — inner tubes, of rubber. In scope.
• ex 4005 to ex 4008 — compounded, unvulcanised and vulcanised rubber in sheets, strip and profile shapes, which cover a lot of tyre-plant intermediates.

The word to notice on almost every line is ex. It means the CN heading is only partly caught — here, only the version derived from natural rubber. Synthetic (petrochemical) rubber sits under HS 4002 and is not a relevant commodity, so it carries no EUDR obligation. [Reg. 2023/1115, Annex I] A modern tyre blends both, so the practical task is to trace and account for the natural-rubber portion, not the whole tyre by weight.

Retreaded tyres: in scope today, but a draft act may change it

As the law stands on 10 July 2026, retreaded and used pneumatic tyres are in Annex I under ex 4012, so they carry the same due-diligence duties as new tyres. [Reg. 2023/1115, Annex I] That is the current, enforceable position.

There is a change on the table, though. On 4 May 2026 the Commission published a draft delegated act amending Annex I; its consultation closed on 1 June 2026. The draft proposes narrowing the retread entry from all of ex 4012 to just tyre treads (ex 4012 90 30), on the reasoning that most of a retread is an old carcass whose origin is untraceable and the new tread is the only part with fresh natural rubber. [Commission EUDR implementation page]

Are you the operator? (Where the tyre chain usually pins it)

The duty to file falls on the person who first places the product on the EU market, or who exports it. [Reg. 2023/1115, Art. 2(15) & Art. 4(1)] For tyres that usually resolves one of three ways:

• You import natural rubber into the EU and build tyres here. You are the operator on that rubber. You run due diligence and file the DDS before it clears customs. [Reg. 2023/1115, Art. 4(1)]
• You import finished tyres into the EU. You are the operator for those tyres and file the DDS for them. [Reg. 2023/1115, Art. 4(1)]
• You buy tyres or rubber already placed on the EU market by someone else. You are downstream. A non-SME downstream operator or trader keeps the upstream DDS reference numbers and records rather than filing its own; an SME has the lightest duty of all. [Reg. 2025/2650]

A tyre plant outside the EU that sells to an EU importer is not the operator — its EU customer is. The non-EU maker's job is to hand the origin data up the chain so the EU importer can file. [Reg. 2023/1115, Art. 4]

What to ask your natural-rubber supplier for

Due diligence starts with information about the natural-rubber portion. For each lot, request: [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 (this sets the risk tier — see below).
• Legality evidence for the country of origin.
• The DDS reference number, where the supplier already filed as the operator.

Then file the statement in the EU Information System and keep the reference number that comes back — it travels with the goods down the chain. [Reg. 2023/1115, Art. 4 & Annex II]

Origin risk tiers for natural rubber

Where the rubber grew decides how much diligence you do. Under Implementing Regulation (EU) 2025/1093, the world is benchmarked into three tiers. [Impl. Reg. 2025/1093] The big rubber origins sit in the lower bands: Thailand is low risk (simplified due diligence), while Indonesia and Côte d’Ivoire are standard risk (full due diligence). None of the major natural-rubber origins is currently high risk. Benchmarking is dynamic and gets reviewed, so a tier can move; check the country of each lot rather than assuming.

Which deadline you are on

Medium and large operators and traders apply the rules from 30 December 2026; micro and small ones from 30 June 2027, provided 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 timber-operator exception to the later date does not apply here.

What this determines — and what it doesn't

Screening your tyre range tells you scope, role, deadline and the documentary obligations you owe. It does not verify that any rubber 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 your position and exactly what to ask your natural-rubber 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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