This checklist provides a 28-point framework for rubber operators and traders to assess readiness for the EU Deforestation Regulation. It is organised by supply chain tier — from smallholder sourcing through processing and export — reflecting the 3-5 levels of aggregation rubber passes through before reaching the European market.
Completing this checklist does not constitute compliance. The EUDR requires operators to exercise due diligence and file a Due Diligence Statement substantiated by evidence. This checklist helps identify where your evidence chain has gaps before a competent authority finds them.
What is the EUDR rubber compliance obligation?
Regulation 2023/1115 prohibits placing on or exporting from the EU market commodities that are not deforestation-free or were not legally produced. Rubber and its derived products are among the seven covered commodity groups.
For rubber, the supply chain spans 3-5 tiers: smallholder to latex collector, collector to processor, processor to exporter, exporter to EU importer. Each aggregation point introduces traceability risk. The operator filing the DDS — typically the EU importer — bears the full burden of proof under Article 4, regardless of how many intermediaries handled the material.
Thailand's low-risk classification reduces competent authority inspection frequency (1% versus 9% for high-risk origins). It does not reduce the due diligence obligation. Operators sourcing from Thailand must still collect geolocation data, assess deforestation risk, verify legality, and file a DDS for every consignment.
What this template covers
Sourcing and geolocation (Articles 9(1)(d), 9(1)(e))
- All source plots identified and geolocated in WGS84 (EPSG:4326) at 6-decimal precision
- Single GPS point captured for plots of 4 hectares or less; polygon boundaries captured for plots exceeding 4 hectares
- Geolocation data includes collection timestamp, device metadata, and collector identity — not just raw coordinates
- Each plot linked to an identified farmer or landholder with tenure documentation on file
- Planting year or crop establishment date recorded for each plot to verify production against the December 31, 2020 deforestation cutoff
- For plots near the cutoff date: satellite imagery analysis performed to confirm no forest loss after December 31, 2020
Risk assessment (Article 10)
- Country risk classification confirmed for each origin (standard, low, or high risk) using current EU benchmarking
- For Thailand-origin rubber: low-risk classification documented, with acknowledgement that due diligence obligations remain unchanged
- Deforestation screening performed using satellite imagery anchored to the December 31, 2020 baseline
- Independent deforestation alert systems cross-referenced for each source plot (e.g., Global Forest Watch, RADD)
- Risk assessment methodology documented: data sources, resolution, thresholds, and decision criteria recorded
- Where concerns identified: risk mitigation measures documented and implemented before DDS filing (Article 10(2))
- Supply chain complexity assessed — number of aggregation tiers between farm and export documented as a risk factor
Legality verification (Article 9(1)(e))
- Relevant legislation of the country of production identified (land use laws, forestry regulations, environmental protections, labour laws, tax obligations, and third-party rights including FPIC)
- Legal compliance evidence collected or supplier attestation obtained with supporting documentation for each origin
- Informal tenure documented — village head attestations, customary rights records, or neighbour boundary agreements where formal title is absent
- Applicable permits, concession licences, or export authorisations on file and verified as current
Processing and traceability (Articles 4, 9)
- Cup lump and field latex collection points mapped — first aggregation tier (smallholder to collector) documented
- DRC measured at each handover (28-35% for field latex; 45-55% for cup lump) to enable volume reconciliation
- Wet-to-dry-weight conversion factors documented at each processing stage with sampling protocol
- Multi-collector aggregation tracked — where 2-3 collectors feed a processor, each collector's source plots linked to the batch
- Processor intake reconciled against outbound volumes (DRC-adjusted input vs. output within documented tolerance)
- Batch or lot identifiers maintained from processor through exporter with traceability links at each transfer
- No mass balance applied — the EUDR prohibits mass balance; physical segregation or identity preservation required
Documentation and filing (Articles 4, 9, 12)
- DDS prepared with all required fields under Article 4(2) before the product is placed on the EU market
- All supporting evidence archived and retrievable for the mandatory 5-year retention period (Article 12)
- Evidence chain auditable end-to-end: competent authority can trace from filed DDS to individual plot through each aggregation stage
- DDS reference number obtained from the EU Information System and linked to shipment and customs documentation
How to use this template
Step 1 — Map your supply chain. Document every tier from source plot to EU market entry: smallholders, collectors, processors, exporters, and the EU importer. Record aggregation points and which entity controls each handover.
Step 2 — Work through each section. Assess each item against your current evidence. Mark items complete only when documentary evidence exists — not when a process is planned or a supplier has verbally confirmed.
Step 3 — Close gaps before filing. Prioritise sourcing and risk assessment items, as these require field-level data that cannot be reconstructed after the fact. Missing geolocation data requires a return visit to source.
Step 4 — Review quarterly. New source plots, processor changes, and country risk reclassifications require periodic reassessment. Treat this checklist as a living document.
How to implement this in your organisation
Assign ownership. Your compliance officer or sustainability manager owns this checklist and is accountable for its completeness. Procurement staff and processing supervisors contribute evidence at each supply chain tier; the export manager reviews the assembled package before DDS filing.
Set the review cadence. Review DRC reconciliation evidence at each processing handover — collector-to-processor and processor-to-exporter — rather than on a fixed monthly schedule. Conduct a full checklist reassessment quarterly and immediately when triggered by a new supplier onboarding, a new source plot entering the supply base, or a country risk reclassification by the European Commission.
Define your escalation path. Any gap identified during review halts DDS preparation for the affected consignment until the gap is closed. The responsible team member escalates unresolved gaps to the export manager within 48 hours, with a documented explanation of the gap and a proposed remediation timeline.
Connect to existing workflows. Integrate geolocation verification into supplier onboarding so plot data is captured before the first delivery, not retroactively. Link DRC measurement and volume reconciliation checks to your existing QC handover points at each processing stage, and attach completed checklist evidence to export documentation packages alongside commercial invoices and packing lists.
Who needs this template
- Rubber exporters assembling DDS evidence packages for EU-bound consignments
- Processors documenting DRC conversion, batch traceability, and intake reconciliation
- Compliance officers auditing evidence chains across multi-tier rubber supply chains before DDS filing
- EU importers verifying upstream evidence meets the standard for a defensible Due Diligence Statement
FAQ
Does Thailand's low-risk classification reduce my due diligence obligation?
No. Low-risk classification reduces competent authority inspection frequency — 1% of operators for low-risk origins versus 9% for high-risk. The due diligence obligation itself is identical regardless of classification. Operators sourcing from Thailand must still collect plot-level geolocation, perform deforestation screening, verify legality, and file a DDS for every consignment.
Why is mass balance prohibited under the EUDR?
The EUDR requires every product on the EU market to be traceable to deforestation-free plots. Mass balance allows compliant and non-compliant material to be mixed with credits allocated proportionally, meaning a specific product cannot be traced to a specific plot. Article 9 requires plot-level traceability, making physical segregation or identity preservation the only acceptable approaches.
How do I handle DRC conversion across multiple processing stages?
DRC varies at each stage: field latex (28-35%), cup lump (45-55%), processed block rubber (near 100% TSC). Document the measurement methodology and sampling protocol at each handover. Reconcile input and output volumes using documented conversion factors with an acceptable tolerance range. Investigate and explain discrepancies beyond tolerance before filing the DDS.
Does completing this checklist mean I am EUDR compliant?
No. This checklist helps identify evidence gaps. Completing every item means you have documented your evidence chain — it does not certify compliance, guarantee a successful regulatory review, or substitute for independent legal counsel. Operators must exercise due diligence and substantiate their DDS with evidence a competent authority can verify.
Rubber supply chains involve more aggregation, informal tenure, and conversion variability than most EUDR-covered commodities. A checklist identifies gaps — a platform closes them. Book a demo to see how ResourceLedger provides evidence-grade traceability from smallholder plot to EU port of entry.