Do I need rubber Track & Trace for EUDR?

Short Answer: Only if the rubber is in-scope for your specific product and supply chain.

Rubber is covered by the EUDR – but only in specific forms !!

Under Annex I of the EUDR, natural rubber (CN code 4001) is explicitly listed. That means:

• If you are importing or placing products on the EU market that contain natural rubber (e.g. tires, rubber sheets, gloves made from natural rubber, etc.),

• And this natural rubber is not recycled,

• Then you need to comply with EUDR.

This includes:

• Geolocation data of the land where the rubber was harvested.

• A due diligence statement (DDS) submitted via the EU Information System.

• Evidence that the rubber is deforestation-free and legally harvested.

You do not need Track & Trace for rubber if:

• You are dealing with synthetic rubber (not in scope).

• The rubber is fully recycled (recycled materials are out of scope – Article 1(3) EUDR).

• The product contains negligible traces of rubber (thresholds not yet clearly defined, but low-content exemptions may be introduced in secondary legislation).

• The product entered the supply chain before the cut-off date (before 30 December 2024).

So do you need Track & Trace for rubber?

Ask yourself:

1. Is natural rubber part of the product?

2. Is it virgin (not recycled)?

3. Are you placing the product on the EU market after December 2024?

4. Is your company the operator or trader responsible under EUDR?

If yes to all: → You must implement EUDR-compliant Track & Trace and Due Diligence.