The tire manufacturing industry, a major consumer of natural rubber, says it’s ready for the European Union Deforestation Regulation, or EUDR, but remains concerned over the latest delay in the rule’s implementation.

The EUDR aims to prevent products linked to deforestation from being sold in the EU market. Rubber is one of the seven commodities targeted under the rule that’s set to take effect at the end of this year. Natural rubber is collected by scoring the bark of the rubber tree (Hevea brasiliensis) and collecting the milky white latex. At the base of the natural rubber supply chain are 6 million smallholders, mostly in Southeast Asia and, increasingly, West Africa, who produce about 85% of the world’s natural rubber. These farmers may have just a hectare or two of land under rubber, in multiple plots, and are independent, selling to multiple agents. The latex they harvest may then pass through numerous intermediary agents before in-country processing or export, making traceability within supply chains exceedingly complex.

Under the EUDR, companies placing goods containing natural rubber on the EU market will have to show that the rubber didn’t come from recently deforested land, and that it was produced in compliance with local laws. That will mean they must have traceability throughout their supply chains.

Originally slated to come into force in 2024, the EUDR’s implementation has been delayed twice. Large and medium-sized companies will now have until Dec. 30, 2026, to be EUDR-compliant, while small and micro-operators will be given a further six months.

Tire manufacturers consume 70% of natural rubber, and the EUDR has already catalyzed enormous change within the tire industry, said Stefano Savi, CEO of the Global Platform for Sustainable Natural Rubber (GPSNR). Founded in 2018, the GPSNR brings together tire manufacturers, smallholders, and civil society groups to address sustainability within the natural rubber industry. Its members now cover 60% of the natural rubber supply chain, and include most of the top 30 tire manufacturers, Savi said.

“Five years ago, everyone would have told you that traceability [in the rubber supply chain] is impossible,” he said. “And then when you have such a big actor like the EU creating what is effectively a level playing field, then things become possible, right? Because you force everybody to just step up.”

Many European tire manufacturers have invested heavily in preparation for the EUDR, says Marta Conti, director of public affairs at Tyres Europe, a trade association representing the continent’s tiremakers. These companies are frustrated by the delays; the more ready for the EUDR they were, the “angrier [they] are” at the delays, she said.

Industry giant Michelin has been EUDR-ready for more than two years, a spokesperson for the French company told Mongabay by email. Some of the challenges included mapping and recording the coordinates of around 2 million land plots, a task known as geolocalizing and aided by the use of RubberWay and other tools. As of December 2024, Michelin purchases rubber exclusively from deforestation-free supply chains, for products sold worldwide, and “therefore strongly regret[s]” the successive delays in EUDR implementation, it said in the email.

Germany’s Continental, another leading tiremaker, has also been ready for EUDR implementation since 2024, a company spokesperson told Mongabay by email. They said that the company welcomes the regulation as it will make sustainability efforts “equally binding for all market participants,” and that the EUDR will have industry-wide impacts. “Because many rubber buyers operate globally, suppliers often upgrade their practices to meet the most stringent regulatory standards, which in this case are those of the European Union,” the spokesperson said.

While European tire manufacturers are “upstream ready,” Conti from Tyres Europe said the downstream information system is still “a headache”. She said it still isn’t clear how downstream operators should handle due diligence statements (DDSs), the digital documents that companies need to fill out before placing their commodities on the EU market, despite recent amendments. For tire manufacturers and distributors, the system is unwieldy, unnecessarily complex and unclear, Conti said.

The spokesperson for Continental noted that tires contain a complex mix of natural rubber from different rubber shipments; and the already complex task of amalgamating and processing traceability information is made even more difficult by delays in implementation, uncertainties, and changing regulatory requirements.

“If you want traceability, [this is] not the way that you’re going to get it, it’s actually going to create a lot of uncertainty,” Conti said.

Savi said that despite challenges, GPSNR members have been proactive in improving sustainability within the natural rubber industry. GPSNR’s own Risk-Based Assurance Framework, implemented in 2024, is a structured process through which members identify, assess, and mitigate deforestation and human rights risks within their supply chains. As of 2027, members will have to undergo third-party verification of their risk assessment systems. In contrast to the EUDR, the GPSNR assurance system generally requires traceability to the district-level; if the district-level deforestation risk is assessed as greater than low risk, traceability to the farm plot is also required.

While the EUDR is already having a positive effect in driving change, Savi said he remains concerned that smallholders in very remote locations will not be able to benefit from the price premium expected to come with EUDR-compliant rubber.

“These are the farmers that are getting the least money because they’re [far] away from the supply chain, so there are more intermediaries taking a cut,” he said. “They’re the ones closest to the forest frontiers, because those are the places most difficult to reach. And my worry is really, when you see the companies simplifying supply chains, they will exclude somehow these farmers.”

Over the past 10 years, prices have dropped substantially, making natural rubber barely profitable for many smallholders, Savi said. He likens rubber trees to an ATM: tapped for cash, but with a declining balance. There’s a danger that impoverished farmers might clear new land for other more profitable crops. Supporting farmers and improving livelihoods is thus a key part of long-term sustainability, and of ensuring adequate supply to meet future demand without deforestation.

To do so, GPSNR members contribute, based on the rubber volume they buy, to a common fund called the Shared Investment Mechanism. The fund, along with in-kind contributions by members, is used for projects focused on sustainability and capacity building, such as agroforestry, improving agricultural practices, and supporting traceability.

“We’re already demonstrating that the projects we have on the ground do make a difference,” Savi said. “We just need to scale it up.”

Some supply chains still problematic

Nevertheless, traceability within some smallholder supply chains is currently “impossible,” said Phuc Xuan To, managing director of forest policy, trade and finance at Forest Trends, a nonprofit. In Vietnam, smallholders manage 54% of land under rubber, and in 2024 contributed 63% of production. Many do not have clear land titles, To said. The small private companies buying rubber from Vietnamese smallholders also import rubber from smallholders in Cambodia and Laos, freely mixing the supplies, with little or no recordkeeping, To said.

That makes complying with the EUDR’s land legality and traceability requirements nearly impossible. In contrast, larger rubber plantations, and a small number of smallholders who are already certified through the Forest Stewardship Council or other programs, are better prepared for EUDR, To said. One solution would be to take a landscape-level approach, to encompass entire regions and multiple commodities.

Still, the exclusion of smallholders from EUDR-compliant supply chains is unlikely to have much of an impact on livelihoods, To said; only about 7% of Vietnam’s natural rubber and rubber products are exported to the EU.

However, on a positive note, the EUDR is spurring the Vietnamese government to improve the reliability of forest cover maps, and, crucially, resolve unclear land titles. That’s likely to have a net positive effect, To said.

EUDR implementation delays risk progress

Experts Mongabay spoke to all agree that the EUDR needs to go ahead.

“The inclusion of natural rubber in the EUDR catalyzed momentum in the rubber sector for traceability to the farm/plantation,” Amy Smith, director of sustainable natural rubber and forests at WWF, told Mongabay by email. “Unfortunately, with the delays in EUDR’s application, changes in requirements, and the current lack of clarity about further revisions, this progress is at risk.”

Many companies have invested time, money and resources into traceability systems, and say they’re ready, Thea Parson, manager for forests and climate at Mighty Earth, a nonprofit, told Mongabay by email.

“So it’s only the laggard companies, really, that are holding this back and need the political will for the regulation to really go into effect,” Parson said.

Banner image: Tapping rubber in Kalimantan Tengah, Indonesia. Over 90% of global natural rubber production comes from Southeast Asia. The remainder comes from South and Central America, and increasingly, West and Central Africa. Image by Mokhamad Edliadi/CIFOR.

Citation:

Warren-Thomas, E. M., Edwards, D. P., Bebber, D. P., Chhang, P., Diment, A. N., Evans, T. D., … Dolman, P. M. (2018). Protecting tropical forests from the rapid expansion of rubber using carbon payments. Nature Communications, 9(1). doi:10.1038/s41467-018-03287-9

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Alexandra Popescu Senior Editor - Latin America

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