EUDR for artificial turf and synthetic sports pitch makers

Artificial turf, 3G pitch systems and their infill sit almost entirely outside the EU Deforestation Regulation, because none of their main components is one of the seven commodities EUDR covers. Turf carpet is a textile product, not wood or rubber; infill is overwhelmingly synthetic polymer. The exception is anything upstream that genuinely is natural rubber or wood, sold under a code Annex I still lists.

Why turf carpet itself is out of scope

EUDR applies only to products listed by customs code in Annex I of Regulation (EU) 2023/1115, under one of seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. Artificial turf carpet — the tufted pile, whether polyethylene, polypropylene or nylon fibre tufted into a woven or non-woven backing — is classified under CN heading 5703, "carpets and other textile floor coverings". That heading sits in Chapter 57 of the Combined Nomenclature, which covers textiles. It is not in Annex I under any commodity, and it was not added by the 2026 Annex I amendment either.

This means the finished product's own classification takes it out of scope, regardless of what any individual input is made from. A turf roll backed with a latex coating, sold as a single CN 5703 product, is not an EUDR relevant product — in the same way a sofa upholstered in a rubber-backed fabric is assessed by its own furniture code, not by the rubber content of one layer. The site's guide to recycled and reclaimed material covers the same classification-first logic for mixed-material products generally.

Why the infill doesn't change the answer

Most 3G and hybrid pitches use loose infill between the turf blades — rubber crumb, sand, or an "organic" alternative such as cork or coconut coir. None of these pulls the system into scope, for two separate reasons.

It's almost always synthetic. Rubber crumb infill is typically styrene-butadiene rubber (SBR) reclaimed from scrap tyres, or thermoplastic elastomer (TPE) granules manufactured new. EUDR's rubber commodity is defined narrowly: Annex I's rubber entries apply only to rubber of Hevea brasiliensis, the para rubber tree, and expressly exclude other natural gums and all synthetic rubber. SBR and TPE were never covered, whatever a product data sheet calls them.

Even natural rubber crumb is the wrong form. Loose rubber granules and powder — the form infill takes regardless of polymer — fall under CN heading 4004, "waste, parings and scrap of rubber, and powders and granules obtained therefrom". That heading has never appeared in Annex I's rubber list. So even a pitch infilled with genuine Hevea rubber crumb would be using a product form the regulation does not reach.

Cork and coconut coir infill clear scope for a more basic reason: cork comes from Quercus suber, cork oak bark, which is classified in Chapter 45 of the Combined Nomenclature, separate from EUDR's wood commodity entries in Chapter 44; and coconut is not one of the seven EUDR commodities at all. Sand infill obviously raises no EUDR question.

Pitch component	Typical material	EUDR commodity it might touch	In scope?
Turf carpet (pile and backing)	Polyethylene, polypropylene or nylon, CN 5703	None — textile heading, not in Annex I	No
Rubber crumb infill	SBR or TPE (synthetic)	Rubber, if natural	No — synthetic, and loose granules sit under CN 4004 even when natural
Cork infill	Cork oak bark	None — Chapter 45, not EUDR wood	No
Coconut coir infill	Coconut husk fibre	Not an EUDR commodity	No
Sand infill	Mineral	None	No
Shock pad / underlay	Usually bonded SBR or PU foam	Rubber, if natural	Almost never — same synthetic-rubber answer as flooring tiles
Wooden sub-base battens or sleepers, sold separately as a wood product	Natural timber	Wood	Possibly — assess independently

The genuine exception: natural rubber shock pads and backing

Shock pads — the resilient layer under the carpet that absorbs impact — are occasionally made from bonded natural rubber crumb rather than synthetic, particularly premium systems using reclaimed natural-rubber matting. If a shock pad or turf backing coating is sold as a separate product under a CN code that Annex I still lists for rubber — for example ex 4008, plates and sheets of vulcanised rubber other than hard rubber — then that component is in scope on its own terms, even though the turf carpet it ends up under is not. The guide to rubber flooring and sports surfacing sets out the CN 4008 versus CN 4016 distinction in detail; the same test applies here. CN 4016 was deleted from Annex I by the September 2026 amendment, so finished rubber matting sold as worked articles clears scope by classification as well as by material in most cases now.

The practical question to ask a supplier is not "is this rubber" but "what CN code does this ship under, and is it natural rubber under that code". Get that in writing rather than inferring it from a product name.

If you also supply wooden sub-base materials

Some sports-pitch contractors also supply or install timber sleepers, edging boards or sub-base structures as part of a wider construction package. Those are wood products in their own right, assessed under EUDR's wood commodity independently of the turf system sitting on top of them. If that's part of your business, treat it as a separate due diligence question — the fact that your turf is out of scope says nothing about a timber edging board invoiced on the same job.

What this means for your paperwork

If your business only manufactures, imports or installs turf carpet, infill and standard shock pads, you have no EUDR due diligence statement to file for that product line — there is no relevant product to attach one to. You do not need to monitor the December 2026 or June 2027 application dates for this part of your business, because those dates only start obligations for products EUDR actually covers. The full deadline breakdown explains who those dates do apply to, if you have other product lines that are in scope.

Keep the classification reasoning on file anyway. A competent authority or a customer's compliance team may ask why you concluded you're out, and "it's a textile floor covering under CN 5703, and Annex I doesn't list that heading" is a better answer than silence. If a supplier later changes a shock pad formulation to natural rubber sheet, or you start selling timber sub-base components directly, revisit the question — scope is assessed product by product, not business by business.

If you're not sure which category a specific product falls into, run it through the checker: it asks what you actually make and sell and gives a direct answer rather than a general rule of thumb.

FAQ

Is artificial turf covered by the EU Deforestation Regulation? No. Turf carpet is classified under CN 5703, a textile heading that does not appear in Annex I under any of EUDR's seven commodities.

Does rubber crumb infill bring artificial turf into scope? Almost never. Most infill is synthetic rubber (SBR or TPE), which EUDR's rubber commodity excludes entirely. Even genuine natural rubber crumb is sold as loose granules under CN 4004, a heading Annex I does not list.

What about cork or coconut-based "organic" infill? Neither is an EUDR commodity. Cork sits in a different customs chapter from EUDR's wood entries, and coconut isn't one of the seven commodities at all.

Could a shock pad or backing layer be in scope even if the turf isn't? Yes, if it's genuinely natural rubber and sold under a CN code Annex I still lists, such as ex 4008 for rubber sheet. Ask your supplier for the material and the customs code, not just whether it's "rubber".

Do the December 2026 and June 2027 deadlines apply to turf manufacturers? Only if you also handle a product that is genuinely in scope — a natural-rubber shock pad sold separately, or timber sub-base materials, for instance. Pure turf and infill businesses have nothing to file against either date.

Does it matter whether the turf is imported or made in the EU? No. EUDR applies to placing products on the EU market and to exports from it, not to where manufacturing happens. An out-of-scope product is out of scope regardless of origin.

Should we still keep evidence of our classification? Yes. Keep the CN code, the material specification from your supplier, and a short note on why the product doesn't appear in Annex I, in case a customer, auditor or competent authority asks.

Does the 2026 Annex I amendment affect synthetic turf? Not directly — turf carpet was never listed, so it couldn't be removed. The amendment is more relevant to rubber flooring tiles and matting, covered in the site's guide to that change, and to rubber shock pads that use the same CN codes.