Natural rubber
Natural rubber is essential for the European tyre and rubber industry, with unique properties critical for performance and safety.
Derived from the Hevea brasiliensis tree, natural rubber is primarily sourced from Southeast Asia, West Africa, and South America. Tyre manufacturing accounts for 73% of the world’s natural rubber consumption, with each tyre using between 20-40% of this rubber by weight.
Our commitment to sustainability in the natural rubber supply chain
The industry prioritises a sustainable supply chain to ensure resilience, reliability, and stability in a competitive market. The tyre industry’s commitment to the Global Platform for Sustainable Natural Rubber (GPSNR) reflects this priority.
The tyre industry also supports the objectives of the European Deforestation Regulation (EUDR). ETRMA is a member of the Multi-Stakeholder Platform on Protecting and Restoring the World’s Forests hosted by the European Commission, learn more.
HOW DOES THE NATURAL RUBBER SUPPLY CHAIN WORK?
The EU depends entirely on imports for natural rubber, primarily from Indonesia, Thailand, Côte d’Ivoire, and Malaysia, making up 85% of EU imports.
The supply chain is complex and fragmented, involving smallholder farmers, dealers, processors, and manufacturers. This dynamic process sees rubber latex harvested daily, processed, and transported through multiple layers before reaching tyre and rubber goods manufacturers.
Natural rubber’s storage and transportation involve extensive logistics, with a significant portion coming from within a 150-200 km radius of processors. This material, if correctly stored, can have a long shelf-life, and the “first-in first-out” principle is not always followed, allowing for long-distance travel of the rubber.
EU Regulation on Deforestation-free products (EUDR)
The EUDR aims to prevent access to the EU market of commodities and derived products that have caused deforestation (after December 2020) and whose production does not respect the national legislation of the country of origin.
What is the scope of EUDR?
It concerns the following commodities: cattle, wood, cocoa, soy, palm oil, coffee, rubber, and some derived products, such as leather, chocolate, tyres, or furniture.
The complete list of commodities and derived products can be seen in the Annex I of the Regulation.
Who does the EUDR impact?
Any operator or trader (who are not SMEs or micro-enterprises) who:
– places such commodities on the EU market (including imports);
– makes them available on the EU market
– exports them from the EU market
must be able to prove they comply with the regulation.
When is EUDR coming into force?
As of 30 December 2024, the key articles of the EUDR will apply.
Micro and small enterprises will enjoy a longer adaptation period, and other specific provisions.
For guidance on the transition period, please refer to the EU Commission’s FAQs at this link.
What are the main elements of the EUDR obligation?
Relevant goods must be covered by a due diligence statement underpinned by a due diligence system.
The Due Diligence system comprises several steps explained below.
1. Collecting Information
To verify that relevant commodities/products are deforestation-free, the operator should provide geolocation coordinates allowing for the traceability of the plot of land where the commodity was produced.
If the plot of land is bigger than 4 hectares, the geolocation coordinates should be provided for each point of a polygon.
It is possible to provide a declaration in excess, that is, coordinates for several plots of land higher than those where the commodities were produced.
The operator’s responsibility extends to all geolocalised and declared plots of land, regardless of whether the commodity was effectively produced there.
Due diligence needs to be applied to all geolocalised and declared plots of land.
If one plot of the “geolocalised mix” is found to be non-compliant, the entire set of geolocalised plots of land is non-compliant.
2. Risk Assessment
Operators should provide adequately conclusive and verifiable information that the commodities/products are deforestation-free and in accordance with local legislation.
The EUDR does not set an official checklist of documents to be produced in the due diligence process. However, the below documentation should be included:
- Geolocation. There are no clear guidelines on how frequently the plot of land should be mapped.
- Date and time range of the production.
- Evidence that there hasn’t been any deforestation after 31 December 2020: Any map or system can be used as long as it is demonstrated to be the best source available.
- Evidence of no breach of local law: official guidelines from the European Commission are expected by the end of the second quarter of 2024.
Any organisation operating within the EUDR should set up a compliance programme and review its risk assessment at least once a year.
Operators and traders throughout the supply chain are liable for the information they use/provide in their due diligence systems and statements.
The obligations stemming from the EUDR do not apply to local producers; hence, they should be instructed on how to provide relevant information correctly.
Being certified by a third party is not enough to be compliant, although it can help to carry out the information collection and risk assessment.
3. Risk Mitigation
Unless the risk assessment shows that there is no or only a negligible risk that your products/commodities are non-compliant, the risk mitigation measures should include:
- Additional information.
- Independent survey/audits.
- Capacity building and investments.
- Compulsory compliance programme.
All decisions regarding risk mitigation need to be reviewed once a year.
4. Reporting
The final report should include:
- A summary of the product’s description, quantity and country of production.
- The conclusion of the risk assessment and mitigation measures taken and a description of the information and evidence used.
- Any consultation process needed with third parties, indigenous communities, etc.
Additionally, operators and traders should collect, organise and keep for 5 years:
- All the information gathered.
- Documentation showing how the due diligence process was carried out.
- Documentation on mitigation measures.
- Due diligence statements.
5. Due Diligence Statements
Operators and traders should provide due diligence statements through the EU Information System for each batch of commodity/product imported, placed/made available on the EU market or exported.
What is the Tyre & Rubber Industry stand on EUDR?
We proposed pragmatic solutions to the EU Commission to help the implementation of the EUDR and fix issues inherent to our complex supply chain, to ensure:
• the availability on the EU market of imported tyres and natural rubber produced during the transition period after the EUDR implementation date;
• an effective EUDR implementation through an EU information system that is fit for purpose;
• a reduced number of due diligence statements in the supply chain by filing periodic statements and covering multiple intra-company/group transactions;
• pragmatic solutions regarding legality requirements to prevent the exclusion of smallholder farmers from EU supply chains;
• that production waste and tyre carcasses for retreading are excluded from the regulation, thus protecting the rubber circular economy;
• that derived products would only have to report on the commodity they are derived from (e.g. for tyres, natural rubber only);
• solutions for supply chains that include both SMEs and, further down the stream, big operators or traders.
Rubber Goods
Products made from rubber are a vital part of everyday life. This super-stretchy material finds its way into tens of thousands of different products—everything from rubber stamps and waterproof shoes to surfing wetsuits, swimming caps, and dishwasher hoses.
From aerospace to aeronautic, from the depth of the seas to the depth of the earth, from agriculture to household appliances, rubber products are everywhere and serve all kinds of industries, whose products could not function without the often-small technical rubber products. Applications are so broad that comparatively few people are aware how dependent we are on this remarkable product.
Supporting SMEs
The Rubber sector is characterised by:
Small and Medium Enterprises
In Europe, there are more than 6000 companies producing rubber goods. 98% of them are SMEs who operate in a highly integrated value chain to respond to the very specific and often niche needs of their customers.
High investments in advanced technologies
Investments are made to keep up with evermore demanding downstream sectors. These, combined with the characteristics of rubber, make such products strategic, unique and not replaceable.
Rubber and automotive
The automotive sector accounts for 65% of the production of general rubber goods. Beyond tyres, wiper blades, seals, air and radiator hoses and seatbelts list rubber as their main components. Rubber is resistant to several chemicals used in a car and can withstand the heat and cold. Rubber is also used to make gaskets used in cars, which help create a seal so there is no leak when fluids are flowing through junction areas in a pipe or a hose. Rubber is also used to cover electrical wires and to create shields for electrical parts and pieces in a car.
Rubber and every-day life
Household appliances, industrial applications and the energy/offshore industry account for another 30% of the market.
There are also hundreds of uses for rubber in the construction industry and in the leisure and sports equipment. Food contact articles are also a beneficiary of rubber: it is used in teats, toys and rubber seals which form essential parts of supply systems for drinking water.
Find here the position of ETRMA on Food Contact Materials
