The European Commission’s amendment proposal of 21 October to “simplify” the EUDR risks setting back implementation efforts and distorting competition in the tyre sector, just weeks before the Regulation enters into force.

Over the past years, European tyre manufacturers have invested heavily to comply with the Regulation as adopted — developing tailored IT systems, restructuring supply chains, and preparing to file due diligence statements (DDS) for natural rubber and tyres, whether EU-made or imported.

The Commission’s proposed “simplification,” however, fundamentally alters the core implementation logic, undermining the whole preparatory work and creating further legal and compliance uncertainties.

What, in principle, is newly introduced as a simplification of the law is the new “first placer” approach: importers of natural rubber — not tyre manufacturers — would become responsible for submitting DDSs.

Each tyre contains natural rubber from multiple batches and sources, meaning that each single product could be associated with hundreds or even thousands of DDS reference numbers, which would then have to be stored, tracked and retransmitted to/by distributors, retailers, and fleets — mostly SMEs with no systems to handle such data volumes.

Adam McCarthy, Tyres Europe Secretary General

“What is presented as simplification is, in reality, a last-minute different solution that simply cannot work with the reality of the tyre market in the European Union (EU). This does not make the EUDR more enforceable; it makes it more fragile.”

By contrast, imported finished tyres would carry only a single DDS, since the natural rubber they contain never entered the EU as a standalone commodity. This creates a competitive imbalance between EU-made and imported tyres, while doing nothing 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. The proposal effectively sets the clock back by 18 months, nullifying much of the preparatory work already undertaken by the tyre industry and its partners, just a few weeks away from the potential application date.

Tyres Europe therefore calls on co-legislators to:

• Reject the proposal in its current form, which adds complexities and uncertainty at the final stage of implementation;
• Amend the proposal to introduce real simplification by deleting the obligation to pass DDS identifiers down the value chain;
• Adopt and publish the Delegated Act amending the Annex I of the EUDR immediately, without delay, to provide legal certainty for innovation (testing and R&D tyres) and circularity (retreaded tyres).