EUDR for natural latex mattress and pillow makers

Only partly, and it depends which part of the chain you sit in. Natural latex foam — the raw rubber sheet or block used to make mattress and pillow cores — is a regulated EUDR commodity under CN ex 4008, inside the regulation's natural rubber range. A finished mattress or pillow, classified under CN 9404, does not appear anywhere in Annex I of Regulation (EU) 2023/1115. Whether you owe a due diligence statement turns on which of those two things you are actually placing on the EU market.

Which CN code actually governs a latex mattress or pillow

Annex I regulates natural rubber by customs code, not by product category, and the two codes that matter here sit a long way apart in the Combined Nomenclature.

CN code	What it covers	In Annex I?
4001	Natural rubber and similar natural gums in primary form, including latex	Yes — the commodity itself
ex 4008	Plates, sheets, strip, rods and profile shapes of vulcanised rubber, including cellular (foam) rubber	Yes, where made from natural rubber
ex 4016	Other articles of vulcanised rubber (general catch-all)	No — removed by Delegated Regulation (EU) 2026/2102, in force since September 2026
9404	Mattress supports; bedding and similar furnishings — mattresses, cushions, pouffes and pillows, including of cellular rubber	Not listed anywhere in Annex I

That last row is the one worth sitting with. Annex I brings wood furniture into scope explicitly — CN 9403 and part of 9401 sit inside the wood commodity range, which is why furniture importers have to think about finished goods as well as raw timber. The rubber commodity range gets no equivalent entry for bedding. Chapter 40 stops at sheets, strips, profile shapes and a short list of named articles — tyres, gloves, thread, hard rubber. Heading 9404 is never reached. A foam mattress core, once it has taken on the shape and character of a finished mattress or pillow rather than foam sheet or block stock, is outside the product list altogether, whatever it is made from.

Why the foam is in scope and the finished product generally isn't

A business that imports natural latex foam in sheet or block form — the state it is usually shipped in from a processing estate before being cut, glued or moulded into mattress cores — is placing an Annex I good on the EU market under ex 4008. That triggers the full due diligence obligation: geolocation for the plantation or smallholding the latex came from, a risk assessment unless the country qualifies for the simplified route, and a statement filed in TRACES.

A business that instead buys finished mattresses or pillows, ready to sell, is buying a CN 9404 product that nothing in Annex I reaches. It does not matter whether the foam inside is 100% natural latex, a synthetic blend, or reclaimed material — the finished bedding article is not a regulated commodity, so there is no due diligence statement to file on it and no reference number to hold, because none was ever generated for it.

The practical dividing line is therefore where in the supply chain the import happens, not what the product is eventually used for:

• Import raw latex foam sheet or block stock, then cut and assemble it into mattresses or pillows yourself → you are the first operator placing an Annex I good on the market. The due diligence duty is yours.
• Buy finished mattresses or pillows from elsewhere, whether made with natural latex or not → you are handling a CN 9404 product. The EUDR does not reach it, whatever marketing claims say about the latex inside.
• Buy latex foam cores that an EU-based foam manufacturer has already imported and cleared → that manufacturer, not you, was the first operator on the raw material. You are buying a semi-finished rubber component from inside the EU market, not importing an Annex I good yourself.

There is one case worth flagging rather than assuming settled: foam that arrives already cut and shaped to mattress or pillow dimensions, rather than as flat sheet or block stock, sits closer to the 9404 boundary than plain sheet does. Customs classification of a shaped foam core can turn on whether it has already taken on the essential character of the finished bedding article. If you import pre-shaped cores rather than sheet or block foam, get your own binding tariff classification rather than assuming ex 4008 still applies — this is an unsettled edge case, not a clear rule.

Natural, synthetic and blended latex: when it isn't an EUDR commodity at all

The EUDR regulates natural rubber as an agricultural commodity grown on cleared or retained forest land. It does not regulate synthetic rubber, which has no deforestation footprint — the same distinction that applies to tyres and other rubber goods applies here. The complication for mattress foam is that very little of what the trade sells as "natural latex" is actually 100% natural.

Foam made by the Dunlop or Talalay process is commonly blended with styrene-butadiene rubber (SBR), a synthetic latex, for cost and performance reasons — a mattress marketed as "natural latex" is often 70–85% natural Hevea brasiliensis latex with the remainder synthetic, and some products sold as "natural" or "botanical" latex run considerably lower. A blend containing any natural rubber latex is in scope on the natural portion; a product that is entirely SBR or another synthetic latex, whatever it is marketed as, is not an EUDR commodity at all, because there is no natural rubber in it to regulate.

Ask for the actual blend ratio rather than relying on the word "natural" on a product spec sheet. A supplier that cannot state the proportion of natural to synthetic latex in a given batch cannot tell you whether, or how much of, that batch is subject to due diligence.

Who owes the due diligence statement

Three roles turn up in a latex foam supply chain, in the same pattern as other rubber goods covered in the EUDR gloves and medical rubber guide:

• The business that first imports natural latex foam sheet or block stock into the EU is the operator. It files the due diligence statement, with geolocation down to the plantation or smallholding.
• A mattress or pillow manufacturer buying that foam from an EU-based importer is downstream. Since Regulation (EU) 2025/2650, it does not file its own statement — it holds the reference number the importer was given and keeps records of who it bought from.
• A retailer, wholesaler or marketplace seller of finished mattresses and pillows generally has nothing to file, because the finished product sits outside Annex I. The exception is a retailer that also imports its own raw foam to manufacture under its own brand — at that point it is the first operator on the material, not merely a retailer of the finished good.

A foam manufacturer based outside the EU is not itself bound by the EUDR, but cannot sell sheet or block stock into the EU in practice without supplying the plantation-level geolocation its EU customer needs to file. A supplier that will not provide this is not one an EU importer can keep buying from once the application date passes.

Where natural latex actually comes from, and the country risk tiers

Natural rubber latex production for the foam trade is concentrated in a handful of countries, several of which carry different EUDR risk tiers under Commission Implementing Regulation (EU) 2025/1093.

Country	Role in the latex foam trade	EUDR risk tier
Sri Lanka	Major latex concentrate and foam exporter; natural rubber is its largest single EUDR-covered export category	Low
Thailand	Largest global natural rubber producer	Low
Vietnam	Major producer and processor	Low
India	Significant producer, mostly domestic use	Low
Malaysia	Established producer and foam manufacturer	Standard
Indonesia	Second-largest global producer	Standard

Thailand, Vietnam, India and Sri Lanka sitting in the low-risk tier unlocks simplified due diligence under Article 13 — no separate risk assessment or mitigation step — provided every plot supplying a given consignment is genuinely low risk. Mixing latex sourced from a low-risk and a standard-risk country in the same batch removes the simplified route for that whole consignment, not just the standard-risk portion.

Recycled and reclaimed latex content

Some mattress ranges use reclaimed or regenerated latex — offcuts and scrap from foam manufacturing reprocessed into lower-grade cores or underlays. Whether that content is exempt from due diligence as waste is a genuine question rather than an automatic yes: the standing waste exemption in Annex I requires the material to have actually completed its lifecycle under the Waste Framework Directive's definition, not merely to be marketed as "recycled" or "regenerated". The full test is set out in the recycled and reclaimed materials guide — do not assume reclaimed foam clears due diligence on the strength of the word "recycled" on a spec sheet without checking it against that test.

Deadlines

Rubber was never an EU Timber Regulation product, so the micro and small operator extension applies here without the carve-out that pulls some timber businesses forward to the earlier date.

Business	Deadline
Large or medium operator or trader, any size of supplier	30 December 2026
Micro or small operator or trader	30 June 2027

The full deadline breakdown covers how the size thresholds are worked out, including for a business that is part of a larger group.

What to ask your foam or mattress supplier

• Is what you are selling me latex sheet or block stock, a pre-shaped mattress or pillow core, or a finished, covered mattress or pillow?
• What proportion of the latex is natural rubber (Hevea brasiliensis) versus synthetic (SBR or similar), and does that ratio vary by batch?
• Which plantation, smallholding or processing station supplied the natural rubber in this specific batch, and can you provide geolocation for it?
• If you are an EU-based foam supplier, have you already filed a due diligence statement for this stock, and what is the reference number?
• If any content is reclaimed or regenerated latex, on what basis do you treat it as exempt from due diligence?

A supplier that cannot answer the first two questions is not yet in a position to tell you whether what they are selling you is an EUDR commodity, a finished product outside Annex I, or some mixture of both in the same shipment.

Check what the EUDR requires of your specific role in a latex foam or mattress supply chain, including whether the product you handle is actually listed in Annex I at all.