Tyres Europe has submitted its response to the European Commission’s consultation on the draft Delegated Regulation amending Annex I of the EU Deforestation Regulation.

The Association welcomes the draft text as a constructive and proportionate step towards improving the operability and legal certainty of the EUDR. In particular, Tyres Europe supports the proposed approach to tyre retreading, which would limit the scope of the Regulation to tyre treads — the only new rubber component introduced during the retreading process — while excluding used tyre casings and retreaded tyres themselves.

This clarification is important for the tyre sector, as it aligns EUDR obligations with the actual introduction of new rubber material on the market, avoids unnecessary administrative burden for retreaders, many of which are SMEs, and supports the EU’s circular economy objectives.

Tyres Europe also welcomes the proposed clarification excluding products intended exclusively for testing, examination and analysis, as well as the broader clarifications on used and second-hand products and waste.

Given the ongoing implementation preparations across the supply chain, Tyres Europe calls for the swift adoption and publication of the Delegated Regulation before the summer break to support legal certainty and implementation readiness.

Read Tyres Europe’s full response below.