The tyre is finished.
The evidence trail
still needs building.

Our most developed specialist workflow

Rubber & Tyres is MarketPass’s most developed specialist EUDR operating workflow. It sits within our broader managed EUDR operations service for EU importers. Other relevant commodity flows are assessed before engagement.

Confirm scope before requesting a farm file

The current Annex I includes ex 4011, new pneumatic tyres of rubber. “Ex” limits coverage to the described subset. Assess the actual goods, material composition, current exclusions and classification; do not infer that all tyres or all rubber articles are covered.

The rubber commodity is now limited to Hevea brasiliensis. A purely synthetic product is not brought into scope by that commodity. For natural/synthetic blends, confirm which relevant natural rubber is present instead of treating synthetic content as a blanket exemption. Read the September 2026 Annex I amendment.

This table is an operational check, not a customs ruling. Our detailed scope guide separates the legal change, composition evidence and deadline decision.

The finished shipment is the starting point

First identify the importing legal entity, product line, quantity and representative invoice/packing-list references. Those establish the commercial flow. They do not explain the rubber’s production origin. Manufacturing and exporting countries can differ from the country where the natural rubber was produced.

Shipment → SKU/batch → manufacturer

Ask how the shipment lines resolve to production batches or a documented production period. A tyre model repeated across several runs is not a unique material-origin identifier. If batch identifiers are absent from the commercial record, establish the manufacturer’s cross-reference rather than inventing one.

Manufacturer → natural-rubber input

Obtain the explanation of intake, consumption and allocation controls for relevant rubber inputs. A bill of materials can identify a natural-rubber blend while leaving its supplier lots unknown. Production logs, input allocations and carry-over records answer a different question: which inputs may have contributed to the selected output?

Input → processor/supplier → production plots

Connect each contributing lot or defensible sourcing set to processor and origin records. Collection and processing may combine material. The origin universe needs to cover the relevant inputs and period, with uncertainty disclosed. One processor address or one convenient farm cannot stand in for an unresolved upstream set.

Production plots → supporting evidence

Geometry is only one gate. The operator workflow also needs the required information and evidence supporting deforestation-free and lawful production, then the applicable risk review and mitigation. Articles 9–11 govern those elements; a well-formed GeoJSON file does not resolve the rest.

Six failure points that matter in an operating process

A worked failure: plots supplied, flow unresolved

Deadlines and roles require an entity-specific check

Most substantive EUDR obligations apply from 30 December 2026. The regulation already entered into force in 2023. Under amended Article 38(3), the 30 June 2027 route depends on the operator qualifying as a micro/small undertaking or natural person established as such by 31 December 2024, with the stated product conditions and EUTR exception. Medium-sized operators do not qualify just because “SME” is used informally. A small supplier does not defer its importer’s obligations.

The 30 December 2027 date for newly added Annex I products must not be applied to the pre-existing ex 4011 entry. The Commission timetable distinguishes these categories.

A direct importer, a downstream operator and a trader do not automatically have identical duties. Operators generally carry out due diligence and submit a DDS, subject to the specific primary-operator provisions. Amended Article 5 assigns different information/record duties to downstream operators and traders. Assess your role before designing a DDS hand-off. MarketPass by Encode supports the operation; the operator retains responsibility.

The first engagement tests feasibility

The €1,000 diagnostic reviews one legal entity, up to five SKU families, one representative import/purchasing flow and up to two chains. It produces an evidence inventory, traceability/geolocation assessment, blockers, owner/action plan, written report and management readout. It can recommend resolving dependencies before a recurring service is proposed.

See the fixed diagnostic scope or use the manufacturer request guide.