EUDR – are you affected?

Investigating the implications of this new legislation.

The European Union Deforestation Regulation (EUDR) aims to prevent products linked to deforestation from being placed on the EU market or exported from the EU. It has been one of the most discussed pieces of sustainability legislation in recent years. Its implementation has already been postponed twice, with multiple secondary and supporting measures, draft amendments, guidance documents and other supplementary information having been published. Therefore, what is the current status of EUDR and how could it be relevant for the glove industry?

At the time of writing this article, EUDR is still expected to apply from 30th December 2026 for large and medium-sized organisations, and from 30th June 2027 for small and micro-enterprises. Organisations placing in-scope items onto the EU market or trading those items within the EU will be required to carry out due diligence to demonstrate that those items are deforestation-free.

How it may affect manufacturers and importers

The key to determining whether a product is in scope of EUDR is the list of commodity codes detailed in Annex I of the regulation. The most relevant commodities for SATRA customers are likely to be those derived from natural rubber or wood.

It is also important to note that not all products using a particular commodity code will be in scope. For example, the commodity code 4015 covers ‘articles of apparel and clothing accessories (including gloves, mittens and mitts), for all purposes, of vulcanised rubber other than hard rubber’. However, this is preceded by ‘ex’ (ex 4015), which means that exclusions apply. In this instance, the exclusions relate to items made from synthetic rubber, or items produced from certain types of natural rubber (balata, gutta-percha, guayule and chicle) that have now been excluded from EUDR’s scope.

For wood, Annex I covers a wide range of wood and wood-derived products, including timber, wood-based panels, paper and certain furniture products. However, a finished product does not automatically fall within the scope of EUDR simply because it contains wood or a wood-derived material; the commodity code of the product itself must be included in Annex 1.

The flow chart shown in figure 1 can be used to help determine whether your organisation and products are likely to be in scope of EUDR, and from what date.

^Definitions of organisations by size according to EU recommendation 2003/361
Company category	Staff headcount	Turnover	or	Balance sheet total
Medium-sized	<250	≤EUR 50 m		≤EUR 43 m
Small	<50	≤EUR 10 m		≤EUR 10 m
Micro	<10	≤EUR 2 m		≤EUR 2 m

The current position at the time this article was prepared is that the latest draft changes remain open for consultation, meaning that further amendments, clarifications or delays cannot be ruled out.

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