German rubber industry calls for ‘first touch principle’ in EUDR
17 Jul 2025
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WDK says documentation obligations risk turning EUDR into “yet another bureaucracy monster”
Frankfurt, Germany – The German Rubber Industry Association (WDK) has again called for the introduction of a “first touch principle” in the EU Deforestation Regulation (EUDR) to avoid “over-bureaucratisation.”
With businesses “completely overwhelmed,” WDK managing director Boris Engelhardt said the regulation should focus on a ‘first touch principle’.
“The first party in the European value chain proves EUDR compliance. All subsequent companies in the value chain would be exempt from further proof obligations,” he said 16 July.
Engelhardt said the European rubber industry is particularly affected by the regulation because it relies on natural rubber (NR) sourced mainly from Asia and Africa.
As NR cannot be cultivated in Europe, the proposed addition of ‘zero-risk states’ will not be relevant for the rubber sector, he added.
Stating the industry’s commitment to EUDR goals, Engelhardt proposed that documentation and government checks should be carried out “at the point when NR or NR products enter Europe.”
“A thorough check of the first importer into the EU fully meets the EUDR’s objectives,” he said.
“But why all companies processing this rubber or using it as an end product must also meet the same documentation obligations again is completely incomprehensible,” the WDK leader added.
This, he stressed, turns the EUDR into “yet another bureaucracy monster.”
Engelhardt said qualified NR traders can prove compliance of their shipments to the EU, while the German industry can also document whether imported finished products contain NR.
This, Engelhardt said, allows us to draw all necessary conclusions about EUDR compliance.
“EU legislators still have the opportunity to steer the EUDR in the right direction by introducing a ‘first touch principle’ - and truly reduce bureaucracy,” he concluded.
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