The German Rubber Industry Association (WDK) is urging the European Union to adopt a “first-touch clearance” under the EUDR, warning that the current framework risks overwhelming natural rubber (NR) businesses with excessive and repetitive bureaucracy.
Effective December 30, 2025, the EUDR will require all companies importing NR or NR-containing products into the EU to prove traceability back to the plantation plot. This requirement will extend to every company in the value chain, regardless of how much NR they use or whether they are the original importer.
“Since 2024, the German rubber industry has been ready to face the goals of the EUDR,” said WDK chief executive Boris Engelhardt. “What we are observing with horror, however, is the bureaucratic effort constructed by the EU Commission that is rolling towards us,” Engelhardt said, arguing that the first company in the supply chain should be responsible for proving compliance, exempting downstream processors and manufacturers from duplicating documentation.
“The first party in the European value chain proves EUDR compliance. All subsequent companies in the value chain would be exempt from further proof obligations. Why all companies processing this rubber or using it as an end product must also meet the same documentation obligations again is completely incomprehensible.”
He added that some German rubber companies use only small quantities of NR annually, yet under the EUDR, they will be required to complete paperwork that could take several days. “Environmental protection and human rights protection are guaranteed when NR touches European soil for the first time: first-touch principle,” Engelhardt said. “All others in the subsequent value chain can be released from the EUDR bureaucracy. That would be an effective reduction of bureaucracy – with one stroke of the pen.”
The appeal comes amid major changes to the European Union’s signature deforestation policy. Last week, Wood Central reported that the European Commission introduced a “negligible risk” category for timber products, potentially reducing compliance checks for goods from low-risk countries – including Vietnam, which supplies huge volumes of rubber into the European Union.
Despite supporting the EUDR’s goals of protecting ecosystems and human rights, Engelhardt stressed that enforcement should focus on the initial point of entry. “A thorough check of the first importer into the EU fully meets the EUDR’s objectives. EU legislators still have the opportunity to steer the EUDR in the right direction by introducing a ‘first-touch principle’—and truly reduce bureaucracy.”
- To learn more about the EUDR’s country classification scheme, click here for Wood Central’s special feature. And to understand why transhipment can muddy the waters on compliance and enforcement, click here for more information.
