What documents do you need for the EUDR declaration on rubber?
For a EUDR declaration on rubber, you essentially collect the same documents as for other feedstocks: trade documents that identify the consignment, geolocation data of the plots where the rubber was produced, and information demonstrating that production complies with the legislation of the country of origin. The difference lies not in the list itself, but in how difficult it is to obtain complete and reliable geolocation data for rubber, because natural rubber almost always reaches you through small producers and intermediaries.
This last point is the detail that this topic hinges on. With timber or soya, you often work with a limited number of larger suppliers per consignment. With rubber, a processor purchases latex or coagulated rubber often from hundreds of small farmers at once, via a local collector or cooperative that mixes the consignments before they reach the exporter. This does not change the nature of the documentation, but it does make it more voluminous and more vulnerable to missing links.
The basic documents that the Regulation requires
The core of the file consists of the trade invoice and delivery note identifying the rubber consignment, the country and where relevant the region of production, the geolocation data of the plots on which the rubber was grown, and the period in which that production took place. To this is added information demonstrating that production complies with applicable legislation in the country of origin, such as land use, labour conditions and permits. Finally, documentation must be provided showing that the plot has not been deforested or degraded after 31 December 2020, the date that the Regulation itself uses as the threshold. What constitutes sufficient evidence in this regard is for the competent authority and the market participant to assess; we structure and validate the data provided, but do not ourselves make any determination as to the status of a consignment.
Why rubber requires an extra layer
With natural rubber, the supply chain often runs from tree to farmer, from farmer to local collector, from collector to cooperative or trader, and only then to the exporter with whom you yourself do business. Each link in that chain can combine consignments from different plots. For you as an importer, this means that the geolocation data you receive is actually a compilation of data that has already been collected and passed on earlier in the chain. If a link is missing anywhere, the origin of part of the consignment is missing, and that is difficult to remedy afterwards. It is therefore advisable to ask at the start of a supply relationship how far back the exporter can itself trace in the chain, rather than discovering only when preparing the declaration that this information is not available.
What you can practically do
It helps to document for each product stream which supplier provides which documents, which country of origin is involved and which risk classification is attached to it. This creates a file in which you can trace per consignment what you have and what is still missing. For rubber, it is useful to explicitly ask about the layer between farmer and exporter, because that layer in other chains often has fewer layers and is therefore more easily overlooked. the overview by feedstock showing the topics that apply shows which documents appear in each feedstock and where the points of attention lie for each chain.
The role of earlier links in the supply chain
Because rubber often passes through multiple intermediaries, it is customary for part of the due diligence to have already been carried out by an earlier market participant in the chain, for example by the exporter in the country of origin. You may use that information, but the responsibility to assess whether your own position in the chain complies remains with you as a market participant or trader. If you are uncertain about which role applies to you and which documents belong with it, that is the first thing you want to clarify before you build a file.
A good conversation with your supplier about what they are already recording saves a lot of detective work afterwards. how we process origin data into a file shows how the documents you receive are converted into a complete overview per consignment, and how we handle your uploaded documents describes how that data is stored.
Would you first like to know which role and which obligation apply to your company before you start collecting documents? in a few questions see which role and obligation applies to you provides a free initial indication of that, after which you can proceed with a file per product stream if desired.