EUDR for rubber: scope, obligations, and how rubber plots are screened
Natural rubber and twelve headings of articles made from it, tyres included. The plantation is agricultural land, and its leaf-fall is not deforestation.
Updated 15 September 2026, 6 min read
Rubber is one of the seven commodities of Regulation (EU) 2023/1115 (Art. 2(1)). Annex I covers natural rubber under heading 4001 and, marked ex, articles of rubber from compounded rubber to tyres, tubes and clothing under headings 4005 to 4017. Since 18 September 2026, under Delegated Regulation (EU) 2026/2102, conveyor belts (ex 4010) and other articles of vulcanised rubber (ex 4016) are out, and the tyre entry covers tyre treads only (ex 4012 90 30). The regulation also confines rubber to Hevea brasiliensis: balata, gutta-percha, guayule, chicle and synthetic rubber are not covered.
In scope: Annex I codes for rubber
| HS code | Product | Status |
|---|---|---|
| 4001 | Natural rubber, balata, gutta-percha, guayule, chicle and similar natural gums, in primary forms or in plates, sheets or strip | In force |
| ex 4005 | Compounded rubber, unvulcanised | In force |
| ex 4006 | Other forms (rods, tubes) and articles of unvulcanised rubber | In force |
| ex 4007 | Vulcanised rubber thread and cord | In force |
| ex 4008 | Plates, sheets, strip, rods of vulcanised rubber | In force |
| ex 4011 | New pneumatic tyres, of rubber | In force |
| ex 4012 90 30 | Tyre treads (the new rubber tread used for retreading) | In force |
| ex 4013 | Inner tubes of rubber | In force |
| ex 4015 | Articles of apparel and clothing accessories, of vulcanised rubber | In force |
| ex 4017 | Hard rubber and articles thereof | In force |
The same regulation took 3 entries for this commodity out of Annex I on 18 September 2026. Products under these codes are no longer relevant products.
| HS code | Product | Status |
|---|---|---|
| ex 4010 | Conveyor or transmission belts of vulcanised rubber | Removed 18 September 2026 |
| ex 4012 | Retreaded or used pneumatic tyres of rubber (in-force entry; the adopted July 2026 amendment narrows this to ex 4012 90 30 tyre treads once it enters into force) | Removed 18 September 2026 |
| ex 4016 | Other articles of vulcanised rubber | Removed 18 September 2026 |
What the regulation asks of a rubber importer
The obligations apply from 30 December 2026. An operator that is a micro or small undertaking, established as such by 31 December 2024, has until 30 June 2027, except for products that were already covered by the EU Timber Regulation. The amendment is Regulation (EU) 2025/2650.
For every consignment the operator must hold, and the statement must rest on:
- The geolocation of every plot of production, as a polygon where the plot is above four hectares, with the production period (Art. 9(1)(d)).
- Evidence that the products are deforestation-free against the 31 December 2020 cutoff (Art. 9(1)(g)) and were produced in accordance with the country's laws in the eight areas of Art. 2(40) (Art. 9(1)(h)).
- The product description with its HS code, the quantity, the country of production, and who supplied and who bought (Art. 9(1)(a) to (f)).
- A risk assessment on that information (Art. 10), and before placing, a due-diligence statement filed in the Information System, whose reference number goes into the customs declaration (Arts. 4, 26 and 33). Everything is kept for five years (Art. 12).
What is specific about rubber
A rubber plantation is an agricultural plantation, and the Commission's FAQ confirms that rubber falls under the exclusion in Art. 2(6), so an established plantation is not forest under the regulation. Rubber trees are deciduous: the plantation drops its leaves every year, and that yearly leaf-off is the signature that maps of rubber are built on. A test that expects an evergreen canopy would read an established rubber plantation as unstable every dry season. The supply is also long: a tyre placed on the EU market rests on latex bought from thousands of smallholders through dealers, so the plot list arrives late and in pieces.
How Konstata screens rubber plots
Every plot is screened in more than one pass. The first runs the plot through WHISP, the open analysis developed under FAO's Open Foris, against the EU's own 2020 forest map, the global loss datasets and the alert layers, joined by national records where a country publishes them. Where that finds loss after the cutoff, a second pass locates it on the ground against the forest map, so a reading on land that was not forest in 2020 is not mistaken for the conversion of forest. Where the plot is still unclear, a third pass reads ten years of monthly satellite greenness for the pattern of an established crop. Each plot ends with a verdict and a written reason, never milder than WHISP's own headline, and a plot the data cannot settle is held for a person, with what to check written next to it.
For rubber the greenness pass built for evergreen crops is not applied, because it would misread the annual leaf-off; a rubber plot that the first two passes cannot settle is held for a person rather than run through a test that does not fit the crop. The rule that matters is the same as for coffee and cocoa: was there forest on the plot on 31 December 2020, and was it converted.
Where to start
- Check your own product codes in the HS code lookup and the Annex I browser under /eudr/tools.
- Settle which date binds you with the company size test, and read the benchmark for each country of production in the country risk tool.
- Open a free Konstata workspace with room for three plots, import them, and read the screening on your own data. No card and no sales call.
Questions
- Are tyres in scope of the EUDR?
- New pneumatic tyres of rubber (ex 4011) and inner tubes (ex 4013) are in Annex I. Since 18 September 2026 the tyre entry covers only tyre treads (ex 4012 90 30): retreaded and used tyres themselves left Annex I under Delegated Regulation (EU) 2026/2102, as did conveyor belts (ex 4010) and other articles of vulcanised rubber (ex 4016).
- Is a rubber plantation a forest under the EUDR?
- No. Agricultural plantations of commodities other than wood are excluded from the definition of forest (Art. 2(6)), and the Commission's FAQ confirms rubber. The test is whether forest standing on 31 December 2020 was converted to a plantation afterwards.
- Why does rubber read as loss in satellite data every year?
- Rubber is deciduous. The yearly leaf-fall lowers the greenness reading, and a check that expects a stable evergreen canopy flags it. Konstata does not apply that test to rubber.
- Our latex comes through dealers. Whose plots do we need?
- The plots of production: the plantations the latex was tapped on, however many dealers sit between them and you (Art. 9(1)(d)). Konstata's supplier link lets each dealer or cooperative deliver the geolocations it has, and reads what arrives.
Sources
Every claim on this page is drawn from Regulation (EU) 2023/1115 as amended, the Commission’s guidance and FAQ, and the implementing and delegated acts. Read the consolidated text on EUR-Lex.
Konstata is compliance software, not legal advice. Verify obligations against the consolidated EUDR text on EUR-Lex.
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