Following the assessment of the European Commission’s set of documents on the EU Deforestation Regulation (EUDR), the tyre industry welcomes elements that appear to provide greater clarity and targeted simplification for companies implementing the Regulation.
In particular, the proposed exclusion of retreaded tyres and test tyres from the scope of the EUDR would help avoid unnecessary administrative burden for products that do not raise the same traceability considerations as tyres placed on the market in the usual commercial sense.
Tyres Europe also notes the recognition of the dual role that tyre manufacturers may play under the EUDR: as operators when importing natural rubber, and as first downstream operators when producing and selling tyres containing that natural rubber. This distinction is important to avoid unnecessary transmission of due diligence statement numbers further down the supply chain, where natural rubber has already been subject to due diligence at import stage.
Tyres Europe believes that the same operational logic should also apply to certain trader situations involving imported tyres. Imported tyres have already been subject to due diligence at the moment of import and therefore already carry a clear and objectively identifiable indication that upstream due diligence obligations were fulfilled. The objective is to avoid unnecessary duplication of DDS transmission obligations where prior due diligence has already demonstrably taken place.
At the same time, important operational challenges remain regarding the practical functioning of the EUDR Information System and the ability to aggregate Due Diligence Statement (DDS) references in a workable manner for complex industrial supply chains.
For the tyre sector, imported tyres and EU-manufactured tyres are operationally mixed in warehouses and distribution systems, often over long periods of time. Customer shipments may therefore require the repeated reuse and aggregation of large volumes of upstream DDS references. While the Commission has recognised the importance of grouping functionalities, the current technical architecture of the Information System risks limiting the practical operability of these simplifications. It is therefore essential that technically sustainable solutions are identified, allowing meaningful aggregation functionalities to remain operational in practice without compromising system resilience.
Adam McCarthy, Tyres Europe Secretary General: “The tyre industry supports the objectives of the EUDR and is ready to implement it. After years of preparation, companies now need implementation certainty. The priority now should be to ensure that the remaining operational issues are addressed through targeted refinements and further implementation guidance, rather than through any reopening of the Regulation itself”
Tyres Europe therefore calls for the EUDR implementation timeline to be maintained, while addressing remaining operational issues through targeted, practical solutions.
