EUDR for rubber and tyre distributors: what stays in scope after the 2026 Annex I changes

Yes, but a narrower yes than the 2023 text set out. Natural rubber (CN 4001) is one of the seven EUDR commodities, and new pneumatic tyres remain a listed Annex I product. Delegated Regulation (EU) 2026/2102, published in the Official Journal on 17 September 2026, removed conveyor and transmission belts, the general "articles of vulcanised rubber" catch-all, and most of the retreaded-tyre entry from scope. A rubber or tyre distributor now has a shorter, more specific list to check than the one everyone was working from a year ago.

Which rubber products are still in Annex I

CN 4001 — natural rubber, balata, gutta-percha, guayule, chicle and similar natural gums, including natural rubber latex under subheading 4001.10 — is the commodity entry itself, and it is a full heading, not a partial one. Every downstream "relevant product" built from it is listed separately, and, with one exception, each of those downstream entries is an "ex" code: it catches the item only where it is made from natural rubber, not synthetic rubber sharing the same tariff heading.

CN code	Product	Still in scope?
4001	Natural rubber, including latex	Yes — the commodity itself
ex 4005	Compounded rubber, unvulcanised	Yes
ex 4006	Other forms and articles of unvulcanised rubber	Yes
ex 4007	Vulcanised rubber thread and cord	Yes
ex 4008	Plates, sheets, strip, rods, profile shapes of vulcanised rubber	Yes
ex 4011	New pneumatic tyres	Yes
ex 4012	Tyre treads (narrowed — see below)	Partially
ex 4013	Inner tubes	Yes
ex 4015	Rubber apparel and clothing accessories, including gloves	Yes
ex 4017	Hard rubber (ebonite)	Yes
ex 4010	Conveyor and transmission belts	No — removed Sept 2026
ex 4016	Other articles of vulcanised rubber (general catch-all)	No — removed Sept 2026

This table reflects Annex I as amended. The full Annex I changes are covered in detail here, including the exact adoption and publication timeline and the point we have not been able to fully resolve — whether the removals took effect on 18 September or 7 October 2026. If a removed code is the only reason a specific product line is in scope, check the commencement date before you rely on it being clear.

What actually changed for retreaded tyres

The pre-2026 Annex I entry for CN 4012 covered retreaded or used pneumatic tyres, solid or cushion tyres, and tyre treads and flaps, as a single block. The amended entry is reported to narrow this down to tyre treads specifically — the new rubber material bonded onto a casing during retreading — rather than the retreaded tyre as a finished product. In practice, that means a retreading business is no longer filing due diligence on the used casing it retreads, which was never going to have deforestation-linked geolocation data attached to it in any case, but it may still owe due diligence on the new tread material it buys in and applies, if that tread compound contains natural rubber.

This distinction matters commercially as well as legally. A retreader buying synthetic-compound tread stock has a materially easier compliance position than one buying natural-rubber-blend tread, even though both are retreading the same kind of casing. ETRMA, the European tyre and rubber manufacturers' association, pushed for exactly this kind of narrowing through the Commission's Annex I consultation, arguing the original blanket entry captured far more of the retreading trade than its actual natural-rubber content justified.

New pneumatic tyres under CN 4011 are unaffected by any of this. If you distribute new tyres, the due diligence obligation on the natural rubber in them is unchanged by the September 2026 amendment.

Natural rubber versus synthetic rubber

The EUDR regulates natural rubber as an agricultural commodity grown on cleared or retained forest land — it does not regulate synthetic rubber, which is a petrochemical product with no deforestation footprint. This is the detail that trips up tyre and rubber-goods distributors more than any CN code technicality: the same finished product — a tyre, a conveyor belt, a rubber seal — can be in or out of scope depending on what it is actually made from, not just which tariff heading it sits under.

A tyre blended from both natural and synthetic rubber (the normal case — passenger car tyres typically run 15–30% natural rubber by weight, with synthetic compounds making up the rest) is in scope because it contains natural rubber, not because the tyre as a category is regulated. You cannot resolve your EUDR status from a CN code alone; you need to know the compound.

Who owes the due diligence statement

Most finished tyres sold in the EU are manufactured outside it — commonly in Thailand, Indonesia, China or Vietnam — using natural rubber sourced locally, and arrive in the EU as the finished product. In that common case, the raw rubber itself never crosses into the EU market; only the tyre does, under CN 4011, and due diligence has to trace back through the manufacturer to the plantations and smallholdings that supplied the rubber in it, in the same way a coffee importer traces back through a roaster to the farm.

Three roles turn up in a rubber or tyre supply chain:

• The EU-based importer placing tyres, rubber goods or raw natural rubber on the EU market for the first time is the operator. The due diligence statement, geolocation and risk assessment (unless the origin qualifies for simplified due diligence) are theirs to produce and file in TRACES.
• A distributor buying already-imported tyres or rubber goods within the EU and reselling them is downstream. Since Regulation (EU) 2025/2650, a downstream trader does not file its own statement — it holds the reference number the importer was given and keeps records of who it bought from and sold to. Most independent tyre distributors and wholesalers sit here.
• A non-EU tyre manufacturer or rubber processor is not itself bound by the regulation, but cannot sell into the EU in practice without supplying the plantation-level geolocation its EU customer needs to file. A manufacturer that will not share this is not a supplier an EU importer can keep buying from once its application date passes.

The handful of EU-based tyre manufacturers that import raw natural rubber directly and process it domestically are operators at that import, and should check with their own compliance advisers whether placing the manufactured tyre on the market afterwards creates a separate filing point, rather than assume the first import clears everything downstream.

Where the rubber actually comes from

Natural rubber production is concentrated in a small number of countries, and their EUDR country risk tier varies — it is not uniformly standard risk the way some other commodities are.

Country	Share of global natural rubber supply	EUDR risk tier
Thailand	Largest single producer	Low
Indonesia	Second largest	Standard
Vietnam	Major producer and processor	Low
India	Significant producer, mostly for domestic use	Low
Malaysia	Established producer, now smaller volumes	Standard
Côte d'Ivoire	Fast-growing African producer	Standard

Thailand, Vietnam and India sit in the Commission's low-risk tier under Implementing Regulation (EU) 2025/1093, which unlocks simplified due diligence under Article 13 — no risk assessment or mitigation step, provided every plot in a given consignment is genuinely low risk. Indonesia, Malaysia and Côte d'Ivoire sit in the default standard tier, carrying a 3% competent authority check rate and the full risk assessment. None of the major rubber-producing countries is on the four-country high-risk list (Belarus, Myanmar, North Korea and Russia).

Mixing tiers in one shipment removes the simplified route entirely: a consignment blending Thai and Indonesian rubber is treated as standard risk throughout, because one standard-risk plot in the mix pulls the whole consignment out of the simplified path.

Deadlines — and why the timber carve-out does not apply to you

The EUDR's two main application dates split on company size, with one exception: micro and small operators whose products were already covered by the old EU Timber Regulation lose the later date and are pulled forward to the main one. Furniture and timber importers run into exactly this. Rubber and tyres were never EU Timber Regulation products, so that exception does not apply here — a micro or small rubber or tyre business gets the full later date regardless of what it deals in.

Your business	Deadline
Large or medium operator or trader, any size of trading partner	30 December 2026
Micro or small operator or trader	30 June 2027

The full deadline breakdown covers how the size thresholds under Directive 2013/34/EU are calculated, including what happens when a small rubber distributor is part of a larger group.

What to ask your suppliers now

• Is the tread, compound or finished rubber good you are selling me made from natural rubber, synthetic rubber, or a blend — and in what proportion?
• If you are a retreader, what is the compound of the tread stock you apply, separately from the casing you are retreading?
• Which plantations, smallholdings or processing stations supplied the natural rubber behind this specific batch, and can you provide geolocation for them?
• Are you the business placing this product on the EU market for the first time, or has an earlier link in the chain already filed a due diligence statement whose reference number I should be holding instead?

A supplier that cannot answer the first question is not yet in a position to tell you whether what they are selling you is in scope at all, let alone whether it is compliant.

Check what the EUDR requires of your specific role in a rubber or tyre supply chain, including whether a recent Annex I removal has taken a product line of yours out of scope entirely.