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Are Tyres and Rubber Parts in EUDR Scope After the 2026 Annex I Amendment?

Some natural-rubber products remain in EUDR Annex I, but the 2026 amendment narrowed and clarified the rubber scope.

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Some natural-rubber products remain in EUDR Annex I, but the 2026 amendment narrowed and clarified the rubber scope. Do not use the old shortcut that tyres and most rubber articles are broadly covered.

  • Regulation (EU) 2026/2102 deleted ex 4010 and ex 4016 and replaced the broad 4012 treatment with the narrower ex 4012 90 30 tyre-tread entry.
  • The rubber commodity is tied to Hevea brasiliensis. Other gums and synthetic rubber fall outside it.
  • Retained pathways include ex 4001, ex 4005, ex 4011, ex 4013 and ex 4017, subject to their exact wording and exclusions.
  • A tyre within 4011 is checked against the current ex 4011 wording and the natural-rubber boundary, not the six-digit heading name.
  • A rubber sole does not automatically make a finished shoe an EUDR relevant product.

Regulation (EU) 2026/2102 deleted the former ex 4010 and ex 4016 entries and replaced the earlier broad 4012 treatment with the narrower ex 4012 90 30 tyre-tread entry. The rubber commodity boundary is also tied to Hevea brasiliensis, with other gums and synthetic rubber outside that commodity definition.

Classify the product against the current Annex entry and read the ex limitation and commodity boundary together.

The current rubber pathways to check

The amended Annex retains rubber pathways including the following headings or subheadings, subject to their exact wording and exclusions:

CN pathwayPractical scope point
ex 4001Natural rubber pathway, subject to the commodity/species boundary
ex 4005Compounded rubber pathway where the Annex conditions are met
ex 4006Other forms and articles of unvulcanised rubber where listed
ex 4007Vulcanised rubber thread and cord where listed
ex 4008Plates, sheets, strip, rods and profile shapes where listed
ex 4011New pneumatic tyres where the Annex conditions are met
ex 4012 90 30Tyre treads, replacing the earlier broader 4012 treatment
ex 4013Inner tubes where listed
ex 4015Articles of apparel and clothing accessories of vulcanised rubber where listed
ex 4017Hard rubber and articles of hard rubber where listed

This table is a routing aid, not a substitute for the Annex wording or customs classification.

What was removed

Two old routes must not survive in current copy or rules:

  • ex 4010 - deleted
  • ex 4016 - deleted

The amendment also removes the basis for treating the old broad 4012 entry as current. If an existing rule says retreaded or used tyres are automatically caught because of the former 4012 line, re-run it from first principles.

The commodity boundary matters

The EUDR rubber commodity is not “anything made of rubber”. The amended Annex and definitions distinguish Hevea brasiliensis from other gums and from synthetic rubber.

So a business must answer two separate questions:

  1. What is the product's CN classification?
  2. Does the material/product satisfy the Annex's relevant rubber commodity limitation?

A synthetic-rubber article does not become an EUDR relevant product simply because it shares a tariff chapter with a listed natural-rubber pathway.

Worked boundaries

New pneumatic tyre

A tyre classified within 4011 needs to be checked against the current ex 4011 wording and the natural-rubber commodity boundary. Do not stop at the six-digit heading name.

Tyre tread

The amended Annex identifies ex 4012 90 30 rather than retaining the former broad 4012 approach. That is a much narrower rule. Classify the actual article.

Conveyor belt or other article previously routed through 4010 or 4016

The old EUDR line is gone. Do not retain a current-scope result simply because an earlier Annex version covered the code. Check whether another current Annex pathway independently applies.

Rubber sole in finished footwear

A rubber component does not automatically make the finished shoe an EUDR relevant product. The finished article and any separately traded component need their own classification. See leather and footwear.

What evidence follows if the product is in scope?

Once a current relevant-product pathway is established, use the core EUDR rules for role, due diligence, geolocation and due-diligence statements. Do not collect those data merely because a product looks “rubber-based”. You can check which product facts you already hold in your browser.

See EUDR dates, geolocation and what product teams need.

What this page does not do

This page does not provide a customs ruling or establish the composition of a particular rubber article. It owns the EUDR worked boundary for tyres and rubber after the 2026 Annex amendment.

Use EUDR scope for the general classification method and the Annex I change owner for version history. The separate DPP question is what a tyre passport may carry later. The Radar shows which EU product rules apply now and which start later.

What would change this answer

A further Annex amendment, a relevant CN change or authoritative clarification that changes a listed rubber pathway or the commodity boundary would require this page to be updated.

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