The German Rubber Industry Association (WDK) has once again urged the EU to introduce a "first-touch principle" for natural rubber (NR) under the European deforestation-free supply chains regulation (EUDR), warning that current rules will impose "excessive, repetitive paperwork" on companies.

"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".

Effective end of December, the EUDR will require all companies importing NR or products containing NR into the EU to prove traceability back to the plantation plot.

This obligation will also apply to all subsequent companies in the value chain that process the material further.

Engelhardt argued that the first company in the EU value chain will guarantee compliance with the EUDR.

"Why then all subsequent ones have to carry out the same bureaucratic effort again and again is completely incomprehensible", Engelhardt said.

According to Engelhardt, some German rubber companies use only small quantities of NR each year, but under the EUDR they will need to fulfil paperwork which can take "several person-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 effective reduction of bureaucracy – with one stroke of the pen", he added.

Another outstanding issue four months ahead of implementation is the absence of "binding provisions" from the EU Commission on how the regulation will be handled or transposed into national law.

Calling for 'urgent legal certainty', Engelhardt said affected companies needed reliability with regards to the EUDR implementation and exemption from repetitive bureaucratic obligations.