STATUS UPDATE

Does EUDR Apply to Viscose and Rubber? Yes — But Not Where You'd Think

Published 01.10.2026 · Fact-checked and updated 02.10.2026 · Reading time ~10 min · by Lior Gabriel Graetz · LG Fashion Labs

Leather is out of the EU Deforestation Regulation's scope as of September 2026, but two materials common in fashion and footwear never left: wood pulp — a main raw material behind viscose, rayon, modal and lyocell — and natural rubber from the Hevea brasiliensis tree. Both are still regulated, with due diligence obligations applying from 30 December 2026 for most operators. Operators that are natural persons or micro or small undertakings established as such by 31 December 2024 get until 30 June 2027 — but not for wood pulp, which is covered by the Annex to the EU Timber Regulation (Article 38(3)).

But "regulated" doesn't automatically mean "your brand has a direct legal duty." Exactly like the leather case this site already covered, EUDR's wood and rubber entries in Annex I list specific customs codes — pulp, timber and wooden articles such as furniture on the wood side; natural rubber in primary and semi-processed forms, tyres and a few rubber articles, including clothing accessories, on the rubber side — but not viscose fibre, yarn, fabric or textile garments, nor footwear. This guide works through what's actually covered, who carries the legal obligation, and what that means if your brand buys already-finished viscose fabric or rubber-soled shoes rather than raw pulp or latex.

CN Chapter 47

Wood pulp — a main feedstock for viscose, rayon, modal and lyocell — remains in Annex I as "ex 47 Pulp of wood" (dissolving pulp is CN 4702).

Hevea brasiliensis only

EUDR's natural rubber entry is now expressly limited to one rubber-tree species (table note 3); synthetic rubber and other natural gums are excluded.

30 Dec 2026 / 30 June 2027

Application dates: 30 December 2026 for operators and traders; 30 June 2027 only for operators that are natural persons or micro or small undertakings established as such by 31 December 2024 — and not for wood pulp.

1. What EUDR actually requires, and for which materials

The EU Deforestation Regulation — Regulation (EU) 2023/1115 — regulates seven "relevant commodities": cattle, cocoa, coffee, oil palm, rubber, soya and wood (Article 2(1)). For each, Annex I lists specific "relevant products" by Combined Nomenclature (CN) customs code — and only goods matching one of those listed entries fall within scope (Article 2(2)). Whoever first places a listed product on the EU market, or exports it, is an "operator" (unless it is a "downstream operator" — see Section 4) and must exercise due diligence in order to prove that the product is deforestation-free, legally produced and covered by a due diligence statement, with the geolocation of all plots of land it came from (Articles 2(15), 3, 4 and 9). Micro and small primary operators in low-risk countries file a one-time simplified declaration instead of a due diligence statement (Article 4a), but they still exercise due diligence.

Leather's three HS codes (raw hides, tanned hides, finished leather) were deleted from the "Cattle" entry by Commission Delegated Regulation (EU) 2026/2102, in force since 18 September 2026 — covered in this site's dedicated leather guide. That same delegated regulation kept "Wood" and "Rubber" in scope but amended their entries: it limited rubber to Hevea brasiliensis and carved bamboo, rattan and other woody materials out of wood (table notes (3) and (4)); it deleted the rubber codes 4010 (conveyor and transmission belts) and 4016 (other vulcanised-rubber articles); it cut 4012 down to tyre treads (ex 4012 90 30); it excluded used and second-hand products from several entries; and it rewrote the pulp-and-paper line (now "ex 47 Pulp of wood" and "ex 48 Paper and Paperboard: Articles of paper pulp, of paper or of paperboard"). That detail matters more than most summaries suggest.

2. Viscose, rayon, modal, lyocell — and the wood pulp behind them

Viscose (also called viscose rayon), modal and lyocell are regenerated cellulose fibres (Regulation (EU) No 1007/2011, Annex I). According to the Commission's Joint Research Centre they are mainly made from dissolving pulp — a higher-quality cellulose pulp, mostly from hardwood and softwood — which is converted into fibre by chemical derivatisation or direct dissolution. That pulp is what Annex I's "Wood" entry lists: alongside logs, sawn timber, wood charcoal and wooden furniture, it includes "ex 47 Pulp of wood" and "ex 48 Paper and Paperboard: Articles of paper pulp, of paper or of paperboard" of the Combined Nomenclature, each with exclusions for used, second-hand and recovered products. Dissolving-grade chemical wood pulp is CN 4702 00 00, in Chapter 47, so it falls within "ex 47 Pulp of wood".

Important exclusion

Bamboo viscose is not covered

Annex I's old wood-pulp line already carried its own exception before 2026 — "with the exception of bamboo-based and recovered (waste and scrap) products". Commission Delegated Regulation (EU) 2026/2102 generalised the bamboo part of it into a table note covering the whole "Wood" commodity category, explicitly excluding "bamboo, rattan and other materials of a woody nature." Bamboo-derived viscose, rayon or lyocell is made from bamboo pulp, not wood pulp, so it sits outside EUDR's scope entirely, both before and after that change. Only the wood pulp itself ("ex 47 Pulp of wood") stays within Annex I; viscose, rayon, modal and lyocell fibres, yarn and fabrics made from it are not listed products, whatever tree they come from.

What Annex I's wood entry does not reach is the fibre, yarn, fabric or garment made from that pulp. Once dissolving pulp is converted into viscose or modal fibre, the resulting product is classified under entirely different CN chapters — 54 (man-made filaments) or 55 (man-made staple fibres) for fibre, yarn and woven fabric, 60 for knitted fabric, 61 or 62 for garments — none of which appear anywhere in Annex I. The regulation's product-scope mechanism is tied to the specific customs code listed in the Annex, not to whatever raw material a later, differently-classified product happens to be made from.

3. Natural rubber and footwear — narrower than it looks

Annex I's "Rubber" entry — limited by table note (3) to rubber of Hevea brasiliensis — lists, by Combined Nomenclature code: natural rubber in primary forms or in plates, sheets or strip (ex 4001); compounded and other unvulcanised rubber (ex 4005 and ex 4006); vulcanised rubber thread and cord (ex 4007); plates, sheets, strips, rods and profile shapes of vulcanised rubber other than hard rubber (ex 4008); new pneumatic tyres (ex 4011); tyre treads (ex 4012 90 30); inner tubes (ex 4013); articles of apparel and clothing accessories, including gloves, of vulcanised rubber other than hard rubber (ex 4015); and hard rubber and articles of hard rubber (ex 4017). Used and second-hand products are excluded from ex 4008, ex 4015 and ex 4017. Not listed: headings 4002–4004, 4009 and 4014 and, since Delegated Regulation (EU) 2026/2102, 4010 (conveyor and transmission belts), 4016 (other articles of vulcanised rubber) and the rest of 4012. Finished footwear itself — classified under CN Chapter 64 — has never had its own line in Annex I, exactly like leather footwear never did under "Cattle."

Important limit

Only one species of rubber tree counts

Commission Delegated Regulation (EU) 2026/2102 added a table note restricting EUDR's "Rubber" entry to rubber of Hevea brasiliensis specifically. It explicitly does not apply to balata, gutta-percha, guayule, chicle or similar natural gums from other species — and it does not apply to synthetic rubber products at all. A sole made of synthetic rubber is therefore outside EUDR's rubber scope regardless of the finished-goods question.

Where a sole, elastic or coated fabric genuinely is made with Hevea natural rubber, the regulated transaction remains the one further upstream: whoever first places the listed natural rubber product (CN 4001 and the related headings) on the EU market. A footwear brand importing a fully assembled shoe is not importing a product listed under any of those rubber codes — it is importing footwear, Chapter 64 — so the same scope logic that excluded finished leather goods applies here too. The position differs if the brand itself places on the EU market any product Annex I does list — for example natural rubber in primary forms or sheets (ex 4001), or gloves or other clothing accessories of vulcanised rubber (ex 4015) made using Hevea rubber.

4. Who actually carries the legal "operator" duty

EUDR defines "operator" as "any natural or legal person who, in the course of a commercial activity, places relevant products on the market or exports them, excluding downstream operators" (Article 2(15)), and "placing on the market" as "the first making available of a relevant commodity or relevant product on the Union market" (Article 2(16)). A "trader" is any person in the supply chain other than an operator or downstream operator who, in the course of a commercial activity, makes relevant products available on the market (Article 2(17)). Traders, like downstream operators, carry lighter obligations under Article 5: they do not submit due diligence statements, but must collect and keep the details of their suppliers and of the downstream operators and traders they supplied (and, where their supplier is an operator, the due diligence statement reference numbers or declaration identifiers) for at least five years and provide them to the competent authorities on request (Article 5(3)–(4)); they must immediately inform the competent authorities of relevant new information, including substantiated concerns, that a product they made available is at risk of non-compliance (Article 5(5)); those that are not SMEs must also register in the EU information system (Article 5(2)) and, where concerns are substantiated, verify that due diligence was exercised and that no or only a negligible risk was found before placing or making the product available (Article 5(6)). The duty to pass the reference numbers down the supply chain falls on the operator (Article 4(7)). A third category, "downstream operator" (Article 2(15b)), covers a person who places on the market or exports relevant products made using relevant products, all of which are already covered by a due diligence statement or a simplified declaration — think wooden furniture made from wood that already cleared due diligence, since furniture itself has its own Annex I entry. That category doesn't reach viscose fabric or footwear either, for the same reason the operator/trader roles don't: neither is an Annex I-listed product to begin with.

Both roles attach only to products that are themselves listed in Annex I (Article 2(2)); a product merely made from a listed product is covered only if it is also listed (as furniture is) — which viscose fabric and footwear are not. A company that buys wood pulp and spins it into viscose fibre is not "trading" pulp onward; it is manufacturing a new, differently classified product. The importer of the pulp — which can be the viscose spinner itself if it imports dissolving pulp directly — is very likely the EUDR operator for that pulp. A spinner or fabric mill that buys pulp already placed on the EU market by someone else, and the brand that eventually buys finished fabric or a finished garment, typically fall outside the operator/trader chain for that specific regulated transaction — because the product they're buying and selling is no longer the Annex I-listed product itself.

The same structure applies to natural rubber: the operator is whoever first places the listed Hevea rubber product on the EU market, or exports it — for example a direct importer of latex or rubber sheet, or an EU processor that imports or produces the listed rubber itself (a compounder that only buys rubber already covered by a due diligence statement is a downstream operator, Article 2(15b)) — not the footwear brand buying a finished, assembled shoe.

DPP AUDIT

How ready is your collection for the DPP?

Benchmark one complete collection against the LGFL DPP Data Framework. 10 domains, four ESPR categories. Under NDA.

Start Your DPP Audit

5. What this means for your brand

Not having a direct EUDR "operator" obligation for finished viscose fabric or rubber-soled footwear doesn't make the regulation irrelevant to your business. Three things still matter in practice:

Your suppliers' compliance is still your exposure. If the operator that places the pulp or raw rubber on the EU market cannot make a due diligence statement (or, for a micro or small primary operator, a simplified declaration) available, it may not place those products on the market (Article 3, point (c); Article 4(2) and (4); and, for micro and small primary operators, Article 4a(2) and (4)). That can interrupt supply further down the chain — an operational risk even where you carry no direct legal duty yourself.

DPP work may later draw on the same data. What an ESPR Digital Product Passport must contain is set product group by product group in delegated acts (ESPR Article 9(2)). No adoption date has been fixed for the textile (apparel) delegated act. The Commission's Digital Product Passport pages list adoption for Q3–Q4 2027 (DPP timeline, together with aluminium and tyres) and for Q4 2027 (textile-apparel page), both marked indicative. The Commission also says the information may include origin information, depending on that act. Sourcing data that your fibre supplier already collects for its own EUDR compliance could therefore be useful later for a textile passport — but nothing in ESPR or EUDR requires it to go into a passport today.

Importing a listed product yourself changes the analysis. A brand that imports pulp, latex or rubber sheet directly — or any other product listed in Annex I, such as new clothing accessories of vulcanised Hevea rubber (ex 4015) — rather than buying already-converted fibre, fabric or components, becomes the EUDR operator for that transaction, with the full due diligence statement and geolocation obligations attaching directly.

Frequently asked questions

Does EUDR apply to viscose, rayon, modal or lyocell?

Indirectly, yes. These are regenerated cellulose fibres made mainly from dissolving wood pulp, and EUDR's "Wood" commodity entry in Annex I lists "ex 47 Pulp of wood", which includes dissolving-grade chemical wood pulp (CN 4702 00 00). But the finished fibre, yarn, fabric or garment is classified under different chapters (54, 55, 60, 61 or 62) that are not themselves listed in Annex I, so the legal due-diligence duty usually attaches to whoever first places the wood pulp on the EU market — typically the importer of the pulp (an EU pulp mill that makes pulp only from wood already covered by due diligence statements is a downstream operator, Article 2(15b)) — not the fashion brand buying finished viscose fabric or garments.

Is bamboo viscose covered by EUDR?

No. EUDR's wood-pulp entry already excluded bamboo-based pulp before 2026, and Commission Delegated Regulation (EU) 2026/2102 extended that into a general table note excluding bamboo, rattan and other woody materials across the entire "Wood" commodity category. Since bamboo-derived viscose, rayon or lyocell is made from bamboo pulp rather than wood pulp, it falls outside EUDR's scope entirely — only wood pulp itself remains within Annex I.

Does EUDR apply to natural rubber in shoe soles?

Only in a narrower sense than most brands assume. Annex I's "Rubber" entry, as clarified by Delegated Regulation (EU) 2026/2102, applies specifically to rubber of Hevea brasiliensis — not synthetic rubber, and not other natural gums such as balata, gutta-percha, guayule or chicle. Finished footwear itself has never had its own entry in Annex I; the regulated transaction is the listed natural rubber product (such as natural rubber in primary form, CN 4001) being placed on the EU market, which is the obligation of whoever places it there — not of the footwear brand buying a finished shoe.

If my brand only buys finished viscose fabric or rubber-soled shoes, do I have EUDR obligations?

Usually not a direct one. EUDR's "operator" duty attaches to whoever first places a relevant product — as listed by its specific customs code in Annex I — on the EU market, or exports it (downstream operators, who make products from already-covered ones, are a separate category). A finished viscose garment or an assembled shoe is classified under different customs codes than wood pulp or raw natural rubber, so a brand buying already-finished material or product is typically neither an "operator" nor a "trader" under EUDR for that transaction. The exception is a brand that itself places a product listed in Annex I on the EU market — for example by importing pulp, latex or rubber sheet directly, or a listed finished article such as new clothing accessories of vulcanised Hevea rubber (ex 4015); company size is irrelevant to the role.

When do EUDR's due diligence obligations currently apply?

30 December 2026 for most operators and traders. Operators that are natural persons, micro or small undertakings get until 30 June 2027 instead — but only if they were already established as such by 31 December 2024 (a micro or small business set up after that date falls under 30 December 2026), and not for products covered by the Annex to Regulation (EU) No 995/2010 (the EU Timber Regulation, repealed with effect from 30 December 2026), which lists pulp and paper of Chapters 47 and 48 (excluding bamboo-based and recovered products). For natural rubber the 30 June 2027 date can therefore apply to a micro or small operator; for wood pulp it cannot (Article 38(2)–(3)). The extended date covers operators only, not traders. For wood pulp and natural rubber, the operator is usually a supplier further up the chain than the fashion brand itself.

Sources

EUDR — core regulationRegulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010 (consolidated text, 18.09.2026). Cited: Article 1 (subject matter and scope); Article 2, points (1)–(2) (relevant commodities and products), (15)–(19) (operator, micro or small primary operator, downstream operator, placing on the market, trader, making available, commercial activity); Article 3 (prohibition); Article 4 (obligations of operators); Article 4a (simplified regime for micro or small primary operators); Article 5 (obligations of downstream operators and traders); Article 9 (information requirements); Article 38 (application dates); Annex I ("Wood" and "Rubber" commodity lists — including the pulp entry ex 47 and the paper entry ex 48 with their exclusions, and the rubber entries ex 4001, ex 4005–4008, ex 4011, ex 4012 90 30, ex 4013, ex 4015 and ex 4017 — and table notes (3) and (4)). CELEX 02023R1115-20260918 ↗
Delegated Regulation (EU) 2026/2102 — Annex I amendmentsCommission Delegated Regulation (EU) 2026/2102 of 13 July 2026 amending Regulation (EU) 2023/1115 of the European Parliament and of the Council as regards the list of relevant commodities and relevant products (OJ L, 2026/2102, 17.9.2026, in force since 18.9.2026). Cited: recitals 5 (leather codes), 7 (bamboo/rattan exclusion from "Wood"; species clarification for "Rubber"), 10 and 11 (rubber codes 4012, 4010 and 4016); Annex, table notes (3) (Hevea brasiliensis restriction) and (4) (bamboo/rattan/woody-material exclusion) and the amendments to the rubber and pulp-and-paper entries. CELEX 32026R2102 ↗
EUDR — application timelineRegulation (EU) 2025/2650 of the European Parliament and of the Council of 19 December 2025 amending Regulation (EU) 2023/1115 as regards certain obligations of operators and traders (OJ L, 2025/2650, 23.12.2025). Cited: Article 38(2)–(3) as now worded (application dates: 30 December 2026; 30 June 2027 only for operators that are natural persons, micro or small undertakings established as such by 31 December 2024, and not for products covered by the Annex to Regulation (EU) No 995/2010) and Article 4(7) (communication of reference numbers down the supply chain). CELEX 32025R2650 ↗
ESPR — Digital Product Passport contentRegulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products, amending Directive (EU) 2020/1828 and Regulation (EU) 2023/1542 and repealing Directive 2009/125/EC. Cited: Article 9(2) (content of the digital product passport specified per product group in delegated acts adopted under Article 4). CELEX 32024R1781 ↗
Commission — textile delegated act timelineEuropean Commission, "Textile Apparel and the Digital Product Passport (DPP)" page — indicative timeline entry "Q4 2027: Planned adoption of the ESPR Delegated Act for textiles" (the Commission's general DPP page groups textiles, aluminium and tyres under "Q3–Q4 2027" in its DPP timeline; both are marked indicative), and the statement that the exact information requirements will be defined through the relevant delegated acts. single-market-economy.ec.europa.eu ↗
Combined Nomenclature 2026 — chapters and headingsCommission Implementing Regulation (EU) 2025/1926 of 22 September 2025 amending Annex I to Council Regulation (EEC) No 2658/87 on the tariff and statistical nomenclature and on the Common Customs Tariff (OJ L, 2025/1926, 31.10.2025; applicable from 1 January 2026). Cited: Chapter 40 (rubber), heading 4702 (chemical wood pulp, dissolving grades), Chapters 47, 48, 54, 55, 60, 61, 62 and 64. CELEX 32025R1926 ↗
Viscose, modal, lyocell — fibre definitions and pulp feedstockRegulation (EU) No 1007/2011 of the European Parliament and of the Council of 27 September 2011 on textile fibre names and related labelling and marking of the fibre composition of textile products and repealing Council Directive 73/44/EEC and Directives 96/73/EC and 2008/121/EC of the European Parliament and of the Council — Annex I (viscose, modal and lyocell defined as regenerated cellulose fibres); and European Commission, Joint Research Centre, "Bio-based textiles in a sustainable and circular bioeconomy" (JRC140676, 2025) — dissolving pulp, its sources and its conversion into fibre. CELEX 32011R1007 ↗ · JRC140676 ↗

All sources were accessed and verified directly on EUR-Lex, via the EU Publications Office, and on the websites of the European Commission and its Joint Research Centre on 02.10.2026; the Commission pages on the timing of the textile delegated act were last read on 13.10.2026. EUDR's product scope has changed materially in 2026 and could change again — verify the current Annex I list on EUR-Lex before relying on this guide's scope summary. This is general information, not legal, financial or investment advice.