Yes, rubber is one of the seven raw materials mentioned in the EU Deforestation Regulation (EUDR), and that is not limited to raw rubber. A range of products made from rubber, such as car tyres, rubber boots, conveyor belts and gloves, can also fall under the Regulation. What matters is whether the product is made from natural rubber (latex from the rubber tree), as this is the raw material whose cultivation can be linked to deforestation. Synthetic rubber, which is made on the basis of crude oil, does not fall under the Regulation.
The Regulation uses an Annex which lists product codes and descriptions indicating which goods fall under each raw material. For rubber, this means in practice: raw natural latex and rubber in primary form fall within it, as do a number of derived products, provided the product description in that Annex matches what you import or trade. Whether a specific item on your invoice falls under the scheme thus depends on the exact description and code, not on the word 'rubber' on the label.
Why the type of rubber makes the difference
The distinction between natural and synthetic rubber is not always visible in the end product. A car tyre, for example, often consists of a mixture of natural and synthetic rubber, supplemented with other materials. When assessing the matter, competent authorities look at the composition and the product code under which the item was imported, not at a general impression of the material. This makes it important for companies importing rubber products to know precisely which part of their assortment falls under the EUDR definition of rubber and which part falls outside it.
The same applies to mixed products, such as shoes with a rubber sole and an upper made of textile or leather. Whether such an item falls under the Regulation is determined on the basis of the product classification used at the time of import, and that classification also determines under which raw material the product is registered in the EU information system. Anyone in doubt about the classification of a specific item is well advised to verify this with a customs advisor or their own supplier before a declaration is drawn up.
What this could mean for your company
If your company imports, processes or places on the market rubber or rubber products, the first question is not only 'does my product fall under the EUDR', but also 'what role does my company have in that chain'. The obligations and the date of application differ according to role: an importer bringing in raw latex has different obligations from a trader reselling finished rubber products within the EU. That distinction, and which date applies to it, you can have that clarified in a few questions.
For companies that establish that their product falls within the scope of the Regulation, the next step is usually to build a file for each product stream: who the supplier is, which country the rubber comes from, and what documents go with it. The approach to this differs depending on the raw material and is detailed by subject in the knowledge base, including the points of attention that apply specifically to rubber.
It is also worth knowing that the risk classification of the country of origin plays a role in the depth of the risk assessment, regardless of whether it is rubber, timber or another raw material. That classification is determined by the European Commission and can change; it remains the responsibility of the economic operator to keep that information up to date when drawing up a file.
Uncertain about your own situation
Whether a specific rubber product in your assortment falls under the Deforestation Regulation, and what obligation applies precisely, cannot be answered in general terms: it depends on the product code, the composition, and your role in the supply chain. For the legal interpretation of your own situation, a lawyer or the competent supervisory authority remains the appropriate point of contact. On our page with frequently asked questions you will find more about how we distinguish between what we structure and what the market participant must assess themselves.
Do you want to quickly find out whether rubber or one of the other commodities in your trade is relevant for the Deforestation Regulation, and which role fits your company? Take the free role check, or browse through the knowledge base for the topics that revolve around your situation.