Tyres Europe sees ‘positive elements’ in EUDR revisions, seeks further clarity

Brussels — Tyres Europe (formerly ETRMA) has cautiously welcomed the European Commission’s draft revisions to the EU Deforestation Regulation (EUDR), notably the proposed exclusion of retreaded tires from the scope, while warning that further clarification is still needed for the industry.

The European Commission published a package of simplification measures 4 May aimed at cutting compliance costs and easing implementation ahead of the law’s entry into force at the end of 2026.

The package includes “a report to the European Parliament and the Council, an updated guidance document and ‘frequently asked questions’ (FAQs), and a draft delegated act on the product scope of the EUDR,” the Commission said.

According to the Commission, the draft delegated act includes additions of “certain downstream products, such as soluble coffee and certain palm oil derivatives,” while proposing the exclusion of products such as “leather or retreaded tires.”

It also proposes exclusions for “product samples, certain packing materials, used and second-hand products, and waste”.

The draft act is open for public feedback until 1 June.

The overall measures, said the Commission, “will provide additional clarity to economic operators, member states, third countries, and other stakeholders, while guaranteeing legal stability and predictability.”

These are “expected to reduce annual compliance costs… by about 75%,” compared to the original EUDR, it added.

In a 5 May statement to ERJ, Tyres Europe said it was reviewing the documents in detail but noted that “at this stage, some elements appear positive.”

In particular, the Brussels-based association pointed to the proposed exclusion of retreaded tires and test tires from the EUDR scope.

The move, it said, would help avoid “unnecessary administrative burden for products that do not raise the same traceability considerations as tires placed on the market in the usual commercial sense.”

Another potentially positive element is the apparent recognition of the dual role that tire manufacturers may play under the EUDR.

Depending on the activity, tire manufacturers may act as operators when importing natural rubber (NR), and as first downstream operators when producing and selling tires containing that NR.

This distinction, said Tyres Europe, “matters in practice.”

Where NR has already been subject to due diligence at the import stage, the subsequent placing on the market of tires containing that rubber should not automatically trigger the need to transfer due diligence statement numbers further down the supply chain.

This, said the association, could help reduce administrative burden and limit the “pull effect”, whereby downstream actors continue to request due diligence information even when it may not be legally required.

Furthermore, Tyres Europe noted improvements in the clarifications provided by the Commission’s FAQs.

The FAQs, it said, appear to clarify that a downstream operator or trader is not obliged to proactively assess whether their supplier is an operator, nor to request or obtain a due diligence statement number from their supplier, unless they are aware that their supplier is an operator.

However, the association said further clarification is still needed.

In particular, Tyres Europe said more clarification was needed on the treatment of imported tires and on the practical possibility of grouping due diligence statements for transmission downstream.

Tyres Europe said it will assess the points above over the consultation period.

“The four-week consultation period will be important to assess whether the proposed changes provide the legal clarity and practical simplification needed for compliance,” it concluded.