Which Rubber Products and HS Codes Fall Under the EUDR

Updated 2026-11-02 · 4 min read · By the akar.earth specialist team

EUDR HS codes for rubber: natural rubber under HS 4001, tyres and other listed rubber articles, and how Indonesian exporters keep crumb rubber traceable.

Under the EUDR, natural rubber is covered through HS heading 4001, which includes technically specified rubber, smoked sheets and natural latex, and Annex I also lists a range of rubber articles, including tyres. Indonesian exports are mostly crumb rubber in bales, so the key task is keeping each bale traceable to the smallholder plots that produced it; check the current Annex I for the full list of downstream rubber products.

Natural rubber in primary forms

Heading 4001 covers natural rubber in its primary forms. The main Indonesian export forms are:

All are covered. Each needs plot-level traceability for EU-bound volume.

Downstream rubber products

Annex I extends beyond raw rubber to a range of rubber products in chapter 40, including tyres, which are the largest end use of natural rubber. We do not reproduce the full list here; check the current Annex I, which was updated by Delegated Regulation (EU) 2026/2102, for the specific headings covering compounded rubber, articles such as belts, tubes and gloves, and tyres.

Indonesia has tyre manufacturing and rubber goods industries. A manufacturer exporting covered products to the EU must trace the natural rubber inputs to plots, whether the rubber came from its own catchment or was bought from other factories.

Why blending is the core problem

Crumb rubber factories blend raw material to meet technical grades. Bokar from smallholders varies in dry rubber content, dirt and age. Factories mix lots during cleaning, crumbing and drying to produce consistent bales.

Mass balance is not accepted under the EUDR. To export compliant bales, a factory needs:

• Segregated intake. Verified bokar from registered farmers received, weighed and stored separately.
• Dedicated runs. Verified material processed together, with line clearance before and after.
• Batch records. Each bale lot linked to the intake lots, collectors and farmers behind it.
• Grade management. Enough verified volume of the right quality to meet grade specifications without mixing in unverified material.

See segregation and rubber due diligence.

Tyres and finished goods

For a tyre or rubber goods maker, natural rubber is one of many inputs, and compounds blend rubber from several sources. Practical approaches:

• Source all EU-bound natural rubber from EUDR-verified suppliers.
• Keep verified and unverified rubber in separate stock and compound batches.
• Link production batches to rubber purchase lots and the supplier’s plot data or upstream statement reference.

Finished goods makers typically depend on their rubber suppliers’ traceability. This makes the crumb rubber factory the most important point in the chain.

Classification first

The right code determines whether due diligence is needed and what goes into the statement. Wrong codes are a common reason statements are questioned. Keep a product register listing each export product, its code, whether it is in Annex I, and its rubber sources. Agree codes with your customs broker and EU buyer. See due diligence statement.

Steps for Indonesian rubber exporters

1. List all products exported to the EU and their codes.
2. Check each code against the current Annex I.
3. For covered products, map raw material sources down to collectors and farmer groups.
4. Build a registered, mapped farmer base. See rubber smallholders.
5. Set up segregated intake and processing.
6. Keep bale-level batch records for five years.

How Indonesian rubber reaches EU tyre makers

Most Indonesian natural rubber bound for Europe does not travel straight from a factory to an EU tyre plant. It often passes through international traders, and sometimes through tyre plants outside the EU whose tyres are then imported. Each route changes who the EU operator is:

• Bales imported into the EU. The EU importer of the bales is the first operator and needs plot data from the Indonesian factory.
• Tyres made outside the EU and imported. The importer of the tyres is the operator. It needs the tyre maker to trace natural rubber back to plots, which in turn depends on the Indonesian factory.
• Tyres made in Indonesia and exported to the EU. The Indonesian tyre maker supplies the data; the EU importer files.

In every case, the data starts at the same place: the registered farmers and segregated runs of the crumb rubber factory. See operators and traders.

Next steps

See rubber and the EUDR for the sector overview and the EUDR hub for the full topic map. For help linking bale lots to plot data, see our EUDR compliance services or message us on WhatsApp.