Deforestation Regulation (EUDR)

What is the Deforestation Regulation (EUDR)?

Officially adopted on 31 May 2023, the E.U. Deforestation Regulation (EUDR) 2023/1115 is a significant initiative aimed at curbing global deforestation and forest degradation by ensuring that products sold within the E.U. do not contribute to these environmental issues. This regulation aligns with the European Green Deal’s broader objectives and the E.U.'s commitment to sustainability, climate neutrality and biodiversity protection. Under the EUDR, businesses are required to ensure that the commodities or products they sell in the E.U. market are deforestation-free (commodities must not have been produced on land deforested after 31 December 2020) and legally sourced (compliance with laws of the producing country must be demonstrated clearly).

How is this relevant for the adhesive tape industry?

Adhesive tapes themselves are not explicitly listed within the regulation, but they may be indirectly affected via the supply chain if they include materials or components derived from regulated commodities—especially paper, cardboard, or wood-based release liners. Paper- or cellulose-based tapes or release liners, often derived from wood pulp or other forestry products, must comply with EUDR requirements. Adhesive tapes using natural-rubber-based adhesives might fall under scrutiny since rubber is explicitly regulated. Suppliers of rubber-based adhesives must ensure traceability and sustainability compliance too, ensuring materials do not originate from deforested land after the cut-off date (31 December 2020).

Status of legislative process

The EUDR is currently in force, with the extended timelines allowing businesses additional time to comply with the new requirements. Looking upstream, companies are expected to utilise this period to adapt their supply chains and ensure adherence to the regulation's standards. Tape manufacturers sourcing paper-based backing or liners, natural rubber or any other regulated commodities must perform detailed due diligence, tracing and verifying that sourcing practices comply (providing geo-location data and other evidence) with the deforestation-free criteria. Product documentation and supplier agreements must show compliance with EUDR standards. A system of reporting on due diligence (a registry for Due Diligence Statements (DDS)) has been created by the European Commission. The EUDR is already causing price increases of natural rubber, since it is produced outside of Europe. The limited capacity of European production is also expected to affect prices.

Timeline of measures

  • 29 June 2023: EUDR entered into force.
  • 14 November: The European Parliament voted to approve a one-year postponement of the EUDR's application date. Alongside the delay, the European Parliament proposed amendments, notably the introduction of a 'no-risk' country category. Commodities from these 'no-risk' countries would be exempt from the stringent due diligence requirements mandated by the EUDR.
  • 2 December: The Information System of the EUDR for submitting compliance went live.
  • 19 December: The Council of the EU formally adopted the regulation to delay the EUDR's application by 12 months.
  • 30 December 2024: Initial implementation date.
  • 30 December 2025: In response to concerns from global producers and internal opposition from the E.U. about the complexities associated with compliance, EUDR’s implementation was postponed by one year. By this date, all large companies must comply with due diligence requirements of all relevant products and raw materials, independent of origin.
  • 30 June 2026: Mandatory due diligence checks and reporting requirements will become enforceable for SMEs.
  • 2028: Planned re-evaluation of additional changes to EUDR.

What is Afera doing about the EUDR?

  • Afera’s RA-WG EUDR taskforce is preparing a guidance with decision-trees on how to decide if a product is “relevant” and what role a company plays (“operator” or “trader”) under EUDR.
  • The taskforce is also monitoring and exploring:
    • If different customs tariffs for natural rubber tapes using a film-based material will help level the market playing field outside the E.U.
    • A potential system for compliance along the supply chain, LiveEO, and creating a guidance for this.
    • If further clarification on the role of converters can be obtained.
    • Developments within the system, timelines and application.
    • Raising industry awareness that paper tapes and plastic tapes with rubber are within scope.
  • Only “relevant products” explicitly listed in Annex I of EUDR require due diligence. The list refers to CN codes (customs codes or combined nomenclature). If your product appears in the TARIC (Integrated Tariff of the E.U.) code, you may exclude the product from the EUDR Annex list. For example, “Rubber” appears in the TARIC data regulation code Y129, page 3, meaning that rubber (and some processed products with natural rubber) do not fall under EUDR: https://www.clecat.org/media/deforestation-reg-2023-1115---taric-data.pdf.

References

Interested in learning more about us?

Subscribe to our newsletter.