EUDR in automotive: where regulation truly meets the supply chain

Why the automotive sector should care about EUDR

EUDR is not a regulation targeting the automotive industry as such, but rather its supply chains. The Regulation focuses on products placed on the EU market or exported from the EU, with the decisive factors being the origin of the commodities, their movement through the supply chain and their customs classification, not the purpose or technical function of the final product.

For automotive businesses, this means that EUDR relevance is assessed based on the material composition of components, the country of production of regulated commodities and the role of the company within the supply chain. EUDR therefore does not target the vehicle as a finished product, but rather the individual inputs and components derived from regulated commodities.

Which automotive components fall under EUDR

From an automotive practice perspective, it is essential to assess EUDR impacts at the level of specific components. Components that contain regulated commodities may fall under the Regulation regardless of their functional significance, visibility or degree of integration.

Typical examples include interior elements based on wood or wood-based composites, tyres and other parts containing natural rubber, or leather interior components.

The scope of EUDR is defined by the combination of the regulated commodity and the HS code listed in Annex I. The mere use of a “natural” material is not decisive; the presence of a regulated commodity must always be assessed together with the customs classification of the specific product.

In practice, for key components containing regulated commodities (e.g. new tyres from natural rubber, leather seats, wooden trim), it is recommended to identify their HS/KN/TARIC codes and continuously monitor the annual updates of the Combined Nomenclature. The vehicle as a final product does not fall under EUDR unless its HS code is listed in Annex I – what matters are the affected components.

However, not every “rubber”, “leather” or “wood” automatically means EUDR applicability. For example, relevant leather must be cattle‑derived, and for wood, only wood material as defined in the Regulation, not synthetic or alternative materials.

Whether a particular automotive component falls under EUDR must therefore always be determined based on the material’s biological origin, its link to a regulated commodity and the corresponding HS code.

Suppliers, material origin and the global dimension of the automotive supply chains

EUDR uses the concept of country of production of the commodity, not the country where the vehicle or component is manufactured. This distinction is crucial because automotive production is typically geographically and contractually separated from the primary production of the underlying commodities. 

Automotive supply chains are long, multi‑tier and often global. Final manufacturers typically have no direct relationship with the location where the regulated commodity was produced. This is one reason why EUDR emphasises verifiable traceability and clearly defined data flows and responsibilities across the chain.

The obligation to gather information about the origin of the commodity lies primarily with the operator – the entity placing the relevant commodity or product on the EU market (i.e. manufacturing in the EU or importing into the EU) or exporting it from the EU. The operator must obtain key information from its suppliers, retain it and make it available as required. In the customs process, alignment with the Due Diligence Statement (DDS) must be ensured.

This information is made available to the first downstream operator who handles the product after it has been placed on the EU market. This entity must retain the information and provide it on request. Any further entities in the supply chain are assessed separately depending on their role and size. With the amended EUDR, the Regulation ensures informational continuity within the supply chain, without broadly transferring the full obligation scope to all entities in the chain, as had been the case under the original wording.

Why it is not enough to know who is OEM and who is Tier‑1

Common automotive classifications such as OEM, Tier 1, Tier 2 or Tier 3 describe a company’s position in the manufacturing and integration chain. However, these terms are not used by EUDR and do not directly determine obligations.

For EUDR purposes, the decisive factor is the regulatory role of the entity (operator, downstream operator, trader), the flows of products it handles and the company’s size. The same company may act in different roles depending on the situation, with obligations varying accordingly. 

Contractual roles alone are not sufficient. EUDR requires verifiable traceability of regulated commodities throughout the chain and prohibits mixing with unknown or non‑compliant material. In practice, this means establishing a clear system of due diligence, responsibilities and audit trails to ensure the required transparency.

Proper assessment of EUDR applicability in specific business situations therefore requires systematic internal mapping of product flows, the roles of individual entities and their size. These elements have a direct impact on contractual arrangements, information flows and expectations placed on suppliers.

Roles under EUDR and their significance in automotive

An operator is the entity placing a relevant product on the EU market - by manufacturing it in the EU or importing it - or exporting it outside the EU. Operators bear primary responsibility for complying with EUDR, including performing due diligence, collecting origin information and submitting the required declarations.

A downstream operator handles relevant products after they have been placed on the EU market. This role is very common in automotive, especially among system suppliers and assembly or integration plants. Their obligations are typically more limited and focus on maintaining continuity with the operator’s declaration and storing relevant information in line with their role and size.

A trader buys or sells relevant products without manufacturing or processing them. Their obligations are narrower and focus mainly on keeping and providing basic information about products, suppliers and entries in the chain.

Conclusion

EUDR does not set universal obligations for vehicles as final products. What matters is whether a specific component falls under Annex I and contains a regulated commodity. In practice, this requires correct classification (HS/CN/TARIC), implementing an effective due diligence system, verifiable traceability without mixing with unknown or non‑compliant sources, and submission of the due diligence statement (DDS) by the correct entity in the chain.