ETRMA joins a cross-commodity call for clarification on EUDR implementation

28 March 2024


The European Tyre and Rubber Manufacturers’ Association (ETRMA) has signed a cross-commodity letter to the EU Commission and Member States requesting urgent clarifications and workable solutions for the implementation of the EU Deforestation Regulation (EUDR).

Considering the significant adjustments that suppliers, operators, and traders need to make, the coalition expressed concerns regarding the pace of preparation of EUDR-related legislative acts, the mandatory systems (e.g., the Information System), and the guidance and clarifications required for implementation by operators and traders and enforcement by competent authorities.

Pending clarifications and missing tools should be provided by Q2 2024 to avoid potential disruptions in all commodity supply chains, with potential unintended adverse effects on the supply of essential goods for the European market, such as food, feed, chemicals, packaging, hygiene products, tyres and other automotive components, construction products, furniture, bioenergy, printed media and more.

Specifically concerning the tyre and rubber industry, ETRMA is proposing pragmatic solutions to the EU Commission to help the implementation of the EUDR and fix issues inherent to our complex supply chain, to ensure:

• the availability on the EU market of imported tyres and natural rubber produced during the transition period after the EUDR implementation date;
• an effective EUDR implementation through an EU information system that is fit for purpose;
• a reduced number of due diligence statements in the supply chain by filing periodic statements and covering multiple intra-company/group transactions;
• pragmatic solutions regarding legality requirements to prevent the exclusion of smallholder farmers from EU supply chains;
• that production waste and tyre carcasses for retreading are excluded from the regulation, thus protecting the rubber circular economy;
• that derived products would only have to report on the commodity they are derived from (e.g. for tyres, natural rubber only);
• solutions for supply chains that include both SMEs and, further down the stream, big operators or traders.

Read the cross-commodity letter and our pragmatic proposals below.