The European Commission has confirmed plans to adopt a delegated act in the near future to simplify Annex I of the EU Deforestation Regulation (EUDR). This follows official concerns raised by the International Retreading Association, BIPAVER, regarding the scope of commodities and products covered by the legislation.
BIPAVAR Pushing for Clarity
In a formal response to BIPAVER General Secretary Yorick Lowin, the Commission acknowledged industry concerns. It stated that a draft delegated act, which underwent public feedback earlier in 2025, is pending adoption. This act is expected to refine the list of products subject to the regulation.
The regulatory landscape for the tyre industry was further clarified by the publication of EU Regulation 2025/2650 on 19 December 2025. This amendment officially postpones the application dates for several core provisions of the EUDR. For large operators, the main obligations now apply from 30 December 2026. For micro or small undertakings established by 31 December 2020, the application is deferred until 30 June 2027. Additionally, the repeal of the previous Timber Regulation (EU) No 995/2010 is now set for 30 December 2026.
A significant addition to the regulation is the introduction of Article 4a, which establishes a simplified regime specifically for micro or small primary operators. Under this provision, eligible operators are exempt from certain standard due diligence requirements. Instead, they must submit a one-time simplified declaration to the information system before placing products on the market or exporting them. Upon submission, these operators will be assigned a permanent declaration identifier. Furthermore, for these small entities, the requirement for precise geolocation coordinates may be replaced by the postal address of the plots of land or the establishment where the commodities were produced.
To clarify which companies qualify for extended deadlines or the simplified regime, specific thresholds under EU Directive 2013/34/EU apply. Micro-enterprises are defined as those with a balance sheet total under €0.35 million, net turnover under €0.70 million, and fewer than 10 employees. Small enterprises must have a balance sheet total under €4 million, net turnover under €8 million, and fewer than 50 employees. Medium-sized enterprises are those with a balance sheet total under €20 million, net turnover under €40 million, and fewer than 250 employees.
The amendments also delay the development of the electronic interface between national customs systems and the EUDR information system, setting a new deadline of 1 December 2029. Additionally, the Commission is now required to carry out a simplification review of the regulation by 30 April 2026, which may lead to further legislative proposals. BIPAVER Technical Secretary Michael Schwämmlein continues to monitor these developments, particularly the pending progress on Annex I, which specifies which rubber-based products—including new and retreaded tyres—fall under the strictest due diligence requirements.
