EUDR FAQs

The EUDR is a legislative measure enacted by the European Union to combat deforestation and forest degradation linked to the supply chains of specific commodities, including rubber. It aims to prevent products associated with deforestation from entering the EU market. Here is the link to the full EUDR regulations.

The EUDR was introduced to address environmental concerns related to global deforestation and forest degradation, which are critical for carbon storage, biodiversity, and climate regulation. It ensures that European trade does not contribute to global deforestation.

The EUDR targets high deforestation risk commodities such as palm oil, soy, beef, wood, cocoa, coffee, and rubber, including their derivative products like tyres, conveyer belts, chocolate, furniture, and others. Here is the link to the HS Codes of relevant materials that are covered under EUDR

Indian rubber exporters and rubber based product exporters must provide information and documentation that enables EU importers to comply with the EUDR. This includes details on the supply chain, land use rights, plot polygons of the farm from where the rubber was sourced, and legal compliance.

Exporters must implement a due diligence system to prove that their rubber products are not linked to deforestation and are produced in accordance with the law of country of production. The requirements include:

  • Legal production and compliance with country-of-origin laws.
  • Traceability of rubber to their origin i.e., to the exact farm polygons where the rubber is produced from.
  • Risk assessments and actions to mitigate deforestation risks in the supply chain.

Compliance requires:

  • Geolocation/plot polygons data of rubber farms.
  • Due Diligence Declarations submitted to EU importers as per EUDR.
  • Detailed supply chain information that supports traceability from origin to end product being exported.

Importers who fail to comply with EUDR requirements may face:

  • Fines:Up to 4% of their annual turnover in the EU.
  • Confiscation of Goods:Products linked to deforestation may be seized.
  • Exclusion from Public Procurement: They may be temporarily banned from participating in public tenders.
  • Reputational Damage:Non-compliance can harm their brand image and affect consumer trust.

The primary responsibility for ensuring compliance lies with the importer of Rubber or Rubber products in the European Union countries. The latest list of European Union Countries is provided here.

This means that companies or individuals importing commodities or products covered by the EUDR into the EU market are legally obligated to:

  • Conduct Due Diligence: Importers must implement a due diligence system to assess and mitigate the risk of deforestation and forest degradation associated with their products.
  • Collect and Verify Information: This includes gathering geolocation data, production dates, and other relevant details to trace the origin of the commodities and ensure they comply with EUDR requirements.
  • Submit Due Diligence Declarations: Importers must submit declarations to competent authorities, confirming that their products are deforestation-free and comply with the regulation.
Other Stakeholders' Responsibilities:

While the importer has the primary responsibility, other stakeholders also play crucial roles in ensuring EUDR compliance:

  • Operators (Exporters to European Union): Entities that harvest, produce, or trade commodities within the EU are also subject to the EUDR and must provide relevant information to importers to facilitate their due diligence processes.
  • Traders: Entities buying or selling commodities within the EU must keep records of their transactions to ensure traceability and facilitate checks by competent authorities.
  • Competent Authorities: National authorities in EU member states are responsible for enforcing the EUDR, conducting checks, and imposing penalties for non-compliance.

  • Supporting Role for Compliance: While the primary responsibility lies with the EU importer, you must provide essential support to ensure compliance with EUDR. This includes maintaining a thorough risk assessment of the supply chain participants.:
  • Documentation Provision: You must supply all relevant documentation to your buyer in the EU (the importer in the EU), including the following :
    • due diligence statements,
    • traceability certificates, and
    • detailed geolocation data of the origin sites (polygon sets).
  • Assist in Records of full Traceability and segregation: Maintain a transparent and traceable supply chain by ensuring that all provided data accurately reflects the rubber's journey from farm to export. Further, you must ensure that the EUDR compliant Rubber has not been mixed with non EUDR compliant Rubber during its entire journey from farm to exports.

  • Primary Responsibility: You hold the same responsibilities as EU importers since you are placing products directly into the market.
  • Due Diligence: You must conduct thorough due diligence to ensure no deforestation or forest degradation is associated with your products along with the necessary risk assessment of the supply chain participants.
  • Documentation Provision: You must supply all relevant documentation to EU, including the following :
    • due diligence declaration,
    • traceability certificates, and
    • detailed geolocation data of the origin sites (polygon sets)
  • Records of full Traceability and segregation: Maintain a transparent and traceable supply chain by ensuring all provided data accurately reflects the rubber's journey from farm to export. Further, you must ensure that the EUDR compliant Rubber has not been mixed with non EUDR compliant Rubber during its entire journey from farm to exports.

  • Record Keeping: You must maintain accurate records of your transactions to ensure traceability of the rubber. This includes details of whom you bought from and to whom you sold.
  • Support Compliance: Although not directly responsible for EUDR compliance, you play a crucial role in supporting exporters by providing them with the necessary documentation that proves the legality and traceability of the rubber.

  • Compliance with Standards: Ensure that all processing adheres to environmental standards that comply with EUDR. This involves not processing rubber from deforested areas post-December 31, 2020.
  • Documentation: Provide detailed records and documentation about the rubber's origin and the processing methods used, which must be shared with exporters to aid their compliance efforts.
  • Maintain full Segregation of EUDR Compliant rubber : Ensure the production processes are captured in detail for every consignment of EUDR compliant rubber supplied from your processing unit. It shall not be mixed with Non EUDR Rubber at any stage - right from receipt of goods, during processing and the final product being supplied by you to your buyer. Your records and details of end to end segregation may be sought by your buyer at all times. You must maintain appropriate storage records and batch processing records to prove that you have complied with full segregation as required under EUDR.

  • Cooperation in Mapping and Risk Assessment: Cooperate with field executives in the polygon mapping process and the risk assessment procedures. This includes sharing relevant documentation such as land ownership papers, KYC documents, relevant farm practices and legal compliance details.
  • Support Traceability: Provide clear information about the dealers / sub dealers or Rubber procurement Societies or Rubber procurement companies that you sell your rubber to support traceability efforts.

The iSNR (powered by TRST01) is an initiative by the Rubber Board of India, designed to facilitate compliance with the European Union Deforestation Regulation (EUDR) for the Indian rubber ecosystem. It aids exporters, processors, and traders by providing essential compliance tools such as traceability certificates, due diligence declarations, and geolocation data sets (GeoJson) necessary for the EU Import System (EUIS). This platform streamlines the compliance process, making it more efficient for stakeholders involved in the rubber supply chain targeting EU markets.

We encourage all stakeholders—including exporters, traders, and processors—to register on the iSNR platform. This initiative by the Rubber Board is designed to facilitate seamless compliance with the European Union Deforestation Regulation (EUDR). By joining the iSNR platform, you will benefit from:

  • Providing traceability certificates that confirm the legality of your rubber products, trace each consignment back to its origin, and ensure the products are deforestation-free.
  • Offering due diligence declarations that you can use to demonstrate compliance with EUDR to EU authorities.
  • Supplying GeoJason data sets to facilitate precise tracking and verification of the rubber's origin, which is a critical requirement under EUDR.

Indian rubber exporters can register on the iSNR platform through the Rubber Board Website. Upon registration, the platform provides all necessary documents and data including traceability certificates, due diligence declarations, and geolocation data sets to ensure full compliance with the EUDR, once the polygon mapping is complete.

Yes, there is a registration fee for exporters: (No fee for Traders/processors/farmers)

  • One-time Registration Fee and Annual Membership: Exporters must pay a one-time registration fee and an annual membership fee to access the platform's services.
  • Certification Fees: There are additional fees for generating each traceability certificate and for creating polygon data sets required for each consignment exported to the EU. These fees vary depending on the size of the exporter (SMEs and MSMEs may have different fee structures).

No, there are no fees for traders, processors, or farmers on the iSNR platform. Fees apply only to exporters who need to certify compliance with the EUDR.

A traceability certificate, issued by the iSNR platform, verifies the origin of rubber products and confirms their compliance with the European Union Deforestation Regulation (EUDR). This certificate includes due diligence statements (DDS), polygon data sets, and traces the entire supply chain. The fee for each certificate varies depending on the specifics of the export consignment.

Compliance will be monitored by EU member state authorities through regular audits and inspections. Exporters must maintain detailed documentation of their supply chain and product origin, segregation/storage policies, which will be facilitated by the iSNR platform. Non-compliance can lead to fines, import bans, and reputational damage.

The Rubber Board plays a crucial role in authenticating exporters and ensuring they meet the EUDR requirements. It provides oversight and support, offering guidance on the necessary documentation for EUDR compliance and verifying the accuracy of the documents and data provided through the iSNR platform.

SMEs (Small and Medium-sized Enterprises) are defined according to Directive 2013/34/EU, which categorizes businesses into three groups based on their size:

  • Micro-undertakings: Fewer than 10 employees and an annual turnover or balance sheet total not exceeding €2 million.
  • Small undertakings: Fewer than 50 employees and an annual turnover or balance sheet total not exceeding €10 million.
  • Medium-sized undertakings: Fewer than 250 employees and an annual turnover not exceeding €50 million, or a balance sheet total not exceeding €43 million.

A business must evaluate its number of employees and financial metrics—annual turnover or balance sheet total—according to the categories established by Directive 2013/34/EU.

SMEs enjoy certain benefits to help them manage the challenges of compliance:

  • Delayed compliance date: SMEs have until June 30, 2025, to comply, giving them additional time compared to larger companies which must comply by December 30, 2024.
  • Simplified due diligence requirements: SMEs may face less stringent due diligence processes, especially if they source from countries classified as low-risk by the EU.

Correctly classifying as an SME can significantly impact the compliance requirements and deadlines applicable under the EUDR. Misclassification could lead to regulatory issues, missed deadlines, or improper compliance procedures.

If there is any uncertainty regarding classification as an SME under the EUDR, it is recommended to:

  • Seek guidance from relevant authorities or industry associations.
  • Consult legal or regulatory experts to ensure proper classification and compliance.

Not entirely. The EUDR includes some provisions to simplify compliance for SMEs:

  • Country Benchmarking System: SMEs may benefit from simplified due diligence if sourcing from low-risk countries, as classified by the EU Commission.
  • Reliance on Existing Declarations: SMEs can refer to a due diligence declaration already submitted by another market participant, provided their products are covered by it. In such cases, they only need to provide the reference number of that declaration.

SMEs may encounter specific challenges, such as:

  • Resource Constraints: Limited resources to implement complex traceability and due diligence systems.
  • Administrative Burden: Even with simplifications, gathering and managing the necessary information can be time-consuming and resource-intensive.
  • Market Access: Non-compliance could lead to restricted access to the EU market, affecting business growth and opportunities.

There are several ways SMEs can receive support, including:

  • Guidance and Information: The EU and member states are expected to offer tailored guidance and resources to help SMEs understand the EUDR.
  • Capacity Building: Training and support programs may be available, particularly for SMEs in developing countries, to help enhance their capacity for compliance.
  • Technology Solutions: Digital tools, such as those provided by platforms like TRST01, can streamline data collection and compliance reporting, making it easier for SMEs to manage their obligations.

  • Stay Informed: Monitor the latest updates and guidelines regarding the EUDR, particularly those specific to SMEs.
  • Seek Guidance: Consult with relevant authorities, industry associations, or experts for help in understanding the compliance requirements.
  • Utilize Technology: Explore digital solutions that simplify traceability and due diligence processes.
  • Collaborate with Suppliers: Work closely with your suppliers and partners to ensure transparency and share information throughout the supply chain.
  • Start Early: Begin preparing now for EUDR compliance to avoid disruptions when the regulation comes into effect.

Failure to comply with the EUDR could result in penalties, including:

  • Fines and import bans.
  • Reputation damage and potential loss of market access to the EU.

SMEs can find more information on the EUDR by consulting:

  • Official EU legislative websites.
  • Industry associations and trade organizations that specialize in environmental regulations.
  • Technology platforms likeTRST01 provide compliance and traceability tools.