Tyres Europe: EUDR proposals ‘set clock back by 18 months’

Brussels – Tyres Europe, formerly ETRMA, has slammed a proposal by the European Commission to “simplify” the European deforestation regulation (EUDR), saying it risks setting back implementation efforts and distorting competition in the tire sector.

In a 4 Nov statement, Tyres Europe noted that the industry has invested heavily over the recent years to comply with the regulation as adopted.

The investments, it said, included developing "tailored IT systems, restructuring supply chains, and preparing to file due diligence statements (DDS) for natural rubber (NR) and tires, whether EU-made or imported."

The proposed simplification (ERJ report), however, “fundamentally alters the core implementation logic, undermining the whole preparatory work and creating further legal and compliance uncertainties,” said Tyres Europe.

The ‘simplification’ involves the new “first placer” approach: NR importers — not tire manufacturers — would become responsible for submitting DDSs.

According to Tyres Europe, each tire contains NR from multiple batches and sources, meaning that each single product could be associated with “hundreds or even thousands of DDS reference numbers.”

These, it explained, will then have to be stored, tracked and retransmitted to/by distributors, retailers, and fleets — mostly SMEs with no systems to handle such data volumes.

“What is presented as simplification is, in reality, a last-minute different solution that simply cannot work with the reality of the tire market in the EU,” said Adam McCarthy, Tyres Europe secretary general.

This, McCarthy said, does not make the EUDR more enforceable, “it makes it more fragile.”

By contrast, imported finished tires would carry only a single DDS, since the NR they contain never entered the EU as a standalone commodity.

This, according to McCarthy, creates a competitive imbalance between EU-made and imported tires, while not helping to improve traceability or environmental outcomes.

“The Commission has introduced these changes without conducting an impact assessment, overlooking the readiness of industries and commodities covered by the regulation,” said the Tyres Europe leader.

“The proposal effectively sets the clock back by 18 months, nullifying much of the preparatory work already undertaken by the tire industry and its partners, just a few weeks away from the potential application date,” he added.

Tyres Europe therefore called on co-legislators to reject the proposal in its current form, saying it adds complexities and uncertainty at the final stage of implementation.

It also called for the proposal to be amended to introduce “real simplification” by deleting the obligation to pass DDS identifiers down the value chain.

The association also urged European legislators to “adopt and publish the delegated act amending the Annex I of the EUDR immediately,” to provide legal certainty for innovation (testing and R&D tires) and circularity (retreaded tires).