# Are Tyres and Rubber Parts in EUDR Scope, and What Do You Collect?

Source: https://activatedigital.ai/knowledge/regulation/eudr-tyres-rubber
Last verified: 12 September 2026
Summary: Yes for the tyre, no for the vehicle it is fitted to. The Annex I rubber lines, what ex covers, and the eight things Article 9 makes you collect.

## Direct answer

**Yes for tyres themselves, and for most vulcanised rubber articles, because Annex I lists them by CN code under the relevant commodity Rubber. No for the vehicle or machine the tyre is fitted to, because that is not in Annex I.**

The main obligations apply from 30 December 2026, and from 30 June 2027 for qualifying micro and small undertakings. Both dates and their status are on [the dates page](https://activatedigital.ai/knowledge/digital-product-passport/dates-by-category).

## Summary

Commodity Rubber In scope new pneumatic tyres, retreaded and used tyres, tyre treads and flaps, inner tubes, belts, plates and sheets, and other articles of vulcanised rubber Out of scope the vehicle or machine the part is fitted to Applies from 30 December 2026, or 30 June 2027 for qualifying micro and small undertakings You must collect the eight categories in Article 9(1), and plot geolocation is the one that drives the cost

## The Annex I lines this rests on

Under the relevant commodity **Rubber**:

4001 Natural rubber, balata, gutta-percha, guayule, chicle and similar natural gums, in primary forms or in plates, sheets or strip ex 4005 Compounded rubber, unvulcanised, in primary forms or in plates, sheets or strip ex 4006 Unvulcanised rubber in other forms and articles ex 4007 Vulcanised rubber thread and cord ex 4008 Plates, sheets, strips, rods and profile shapes, of vulcanised rubber other than hard rubber ex 4010 Conveyer or transmission belts or belting, of vulcanised rubber ex 4011 New pneumatic tyres, of rubber ex 4012 Retreaded or used pneumatic tyres of rubber; solid or cushion tyres, tyre treads and tyre flaps, of rubber ex 4013 Inner tubes, of rubber ex 4015 Articles of apparel and clothing accessories, for all purposes, of vulcanised rubber other than hard rubber ex 4016 Other articles of vulcanised rubber other than hard rubber, not elsewhere specified in chapter 40 ex 4017 Hard rubber in all forms including waste and scrap; articles of hard rubber

Quoted from the annex as published. Only `4001` is listed bare; every other line carries `ex`, which means it reaches only the part of that heading the description names. Check the consolidated Regulation before relying on a line, and read [the scope test](https://activatedigital.ai/knowledge/regulation/eudr-scope) for what `ex` does to a classification.

## What that covers, and what it does not

`ex 4011` and `ex 4012` between them reach the whole tyre lifecycle the Regulation cares about: new, retreaded, used, solid, cushion, treads and flaps. A retreading business is not outside this because the casing is second-hand; the waste carve-out in Annex I needs goods produced **entirely** from end-of-life material, and a retreaded tyre is a casing plus new rubber.

`ex 4016` is the wide one. Other articles of vulcanised rubber not elsewhere specified in chapter 40 catches seals, gaskets, mats, mouldings and hoses, which is most of what a manufacturing business buys in without thinking of it as a commodity.

What it does not cover is the assembled thing. A car with tyres on it, a conveyor with a belt in it, a machine with seals in it: none of those is in Annex I. The tyre is a relevant product when it is placed on the market as a tyre.

## What you have to collect

Article 9(1) of Regulation (EU) 2023/1115 lists eight categories, and all eight apply here:

- **(a)** the product description, including trade name, type and species name;
- **(b)** the quantity;
- **(c)** the country of production, and parts of it;
- **(d)** the geolocation of all plots of land where the rubber was produced, and the date
or time range of production;

- **(e)** the name and contact details of suppliers;
- **(f)** the name and contact details of customers;
- **(g)** the information demonstrating the commodity is deforestation-free;
- **(h)** the information demonstrating production was in accordance with the law of the
country of production.

Point (d) is the expensive one for rubber, because natural rubber reaches a tyre plant through a long chain of smallholdings, dealers and processors, and the plot is at the far end of it. What the Regulation asks for in form is settled: [how precise a plot geolocation has to be](https://activatedigital.ai/knowledge/regulation/eudr-plot-geolocation).

The statement you then submit is a different and much shorter list: [what goes in a due diligence statement](https://activatedigital.ai/knowledge/regulation/eudr-due-diligence-statement).

## If you also sell footwear or furniture

A shoe company is usually in two commodities at once. The rubber sole is one, the leather upper is another, and they arrive on different supply chains with different evidence problems. See [leather and footwear under EUDR](https://activatedigital.ai/knowledge/regulation/eudr-leather-footwear).

A furniture or flooring business buying rubber underlay and wood panels has the same shape with wood as the second commodity. See [wood products under EUDR](https://activatedigital.ai/knowledge/regulation/eudr-wood-products).

## What this page does not do

It does not classify your product. That is a customs determination.

It does not restate the unpublished amendment. Commission Delegated Regulation C(2026) 4920 amends the list of relevant products and is not published, so it is not the operative Annex I: [does the July 2026 change to Annex I apply yet](https://activatedigital.ai/knowledge/regulation/eudr-annex-i-change).

It does not cover the tyre passport. The EU tyre Digital Product Passport work is a different regime on a different timetable, and it is owned by [the tyres category page](https://activatedigital.ai/knowledge/category/tyres).

## What would change this answer

Recheck if:

- Annex I is amended in a way that adds or removes a chapter 40 line;
- the application dates in Article 38 move again;
- Article 9(1) is amended.
**Last verified 12 September 2026.**

## Keep exploring

The questions this page usually raises next.

- [CompareNext questionIs My Product in EUDR Scope? Reading Annex I Against Your CN CodeScope is decided by your CN code, not by what the product contains.→](https://activatedigital.ai/knowledge/regulation/eudr-scope)
- [Another angleNext questionEU DPP Dates by Category: Every Date, and What Kind of Date It IsWhich product categories have a Digital Product Passport date, what kind of date each one is, and which have none.→](https://activatedigital.ai/knowledge/digital-product-passport/dates-by-category)
- [CompareNext questionWhat Goes in an EUDR Due Diligence Statement, and What Stays Behind It?The statement is what you submit before placing or exporting. The Article 9 information is what you collect and keep.→](https://activatedigital.ai/knowledge/regulation/eudr-due-diligence-statement)

## Sources and legal basis

- [Regulation (EU) 2023/1115, consolidated text](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1115-20251226)
- [Regulation (EU) 2023/1115 as published, OJ L 150, 9.6.2023](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1115)
