If you place natural rubber, or a listed rubber product such as tyres, on the EU market, the EUDR requires you to show three things before it clears customs: the rubber was produced on land not deforested after 31 December 2020, it was produced legally, and it is covered by a due diligence statement. For large and medium operators this applies from 30 December 2026. Your supplier provides the data, but you carry the legal responsibility.
This guide walks through due diligence for rubber step by step. For our own progress, see our EUDR status.
Which rubber products are in scope
Annex I of Regulation (EU) 2023/1115 lists the rubber products covered. They include:
| HS heading | Product |
|---|---|
| 4001 | Natural rubber, including TSR (4001 22), latex and sheets |
| 4005, 4006, 4008 | Compounded rubber, other unvulcanised forms, plates and sheets |
| 4007 | Vulcanised rubber thread and cord |
| 4010 | Conveyor and transmission belts |
| 4011, 4012, 4013 | New tyres, retreaded and used tyres, inner tubes |
| 4015, 4016, 4017 | Rubber apparel and gloves, other articles, hard rubber |
That means a tyre maker importing finished tyres into the EU is in scope, and so is an importer of TSR20. For HS classification, see HS codes for palm oil and natural rubber.
Who must do what
The operator is the company that first places the product on the EU market or exports it. For imported TSR20 that is usually the importer of record. The operator must carry out due diligence and file the statement in the EU information system before customs release.
Companies further down the chain, such as a compounder buying TSR20 from an EU importer, have lighter duties under the 2025 amendment.
The three steps of due diligence
1. Collect information
You need, for each consignment:
- A description of the product, its HS code and quantity
- The country of production, and for rubber, the geolocation of every plot where it was grown
- The date or time range of production
- The supplier's name and address, and the name and address of any buyer you sell to
- Information showing the rubber is deforestation-free
- Information showing it was produced in line with the laws of the country of production
Geolocation must use latitude and longitude with at least six decimal places. Plots larger than 4 hectares need a polygon. Our guide to geolocation and traceability data shows what this looks like in practice.
2. Assess the risk
Using that information, you assess the risk that the rubber is not compliant. The regulation lists the factors, including the country's risk level, forest cover in the area of production, signs of deforestation, the complexity of the supply chain, the risk of mixing with rubber of unknown origin, and any concerns about legality or corruption.
For rubber, supply chain complexity is the main issue. A single TSR20 lot can contain cup lump from hundreds of small farms, collected through several intermediaries.
3. Mitigate the risk
If the risk is more than negligible, you must reduce it before placing the product on the market. That can mean asking for more data, independent audits, satellite checks of the plots, or excluding certain plots. If the risk cannot be brought down to negligible, the product cannot be placed on the market.
What to ask your rubber supplier
- Can you provide geolocation for every plot behind this lot, including smallholder plots?
- How do you keep traced rubber separate from untraced rubber at collection points and in the factory?
- Have the plots been checked against forest cover data for 31 December 2020? With which dataset?
- What legality evidence do you hold for land use rights and labour conditions?
- In what format will the data arrive, and will it match the invoice and bill of lading?
A supplier that cannot answer clearly is a risk to your statement. See sustainability in Liberian rubber for how these questions apply to smallholder supply.
Country risk
The Commission classifies countries as low, standard or high risk. Low risk allows simplified due diligence, without the risk assessment and mitigation steps, unless you have information that points to a problem. Standard and high risk require the full process. Our note on EUDR country benchmarking and Liberia explains where Liberia sits.
Records and penalties
Operators must keep due diligence records for five years. Penalties are set by member states and must include fines of up to at least 4% of the operator's annual EU turnover, confiscation of products and revenue, and temporary exclusion from public procurement.
Dates to plan around
For large and medium operators the EUDR applies from 30 December 2026, and for micro and small operators from 30 June 2027. Dates have moved before. Our EUDR timeline is updated when they change.