From 30 December 2026, any company placing natural rubber on the EU market has to back each consignment with a due diligence statement. The date has slipped twice; the European Commission confirmed in May that it will not slip again. What changed most recently is the scope. Delegated Regulation (EU) 2026/2102, published on 17 September and in force the following day, rewrote Annex I and defined the relevant rubber narrowly, as natural rubber from Hevea brasiliensis. Synthetic rubber is excluded. That one line divides a protective glove catalogue in two.
The Split Runs Through the Catalogue
Butyl, neoprene, nitrile and fluoroelastomer are synthetic, so a glove built only from them carries no rubber obligation. Natural rubber latex gloves do. New goods under customs heading ex 4015 stay in scope, and the September amendment only carved out used and second-hand items.
The consequence is easy to lose in a tender. One call-off can mix a butyl glove, which needs no statement, with a latex glove, which does - and the paperwork is per consignment, not per contract. Footwear behaves differently again. The amendment removed most vulcanised rubber articles under 4010 and 4016, so a boot's position now depends on its code rather than on whether it contains rubber. Buyers should check lines individually rather than treating a product family as a single answer.
The Evidence Starts at a Plot
A statement is not a certificate. It rests on the geolocation of every plot that produced the latex: a single point recorded to at least six decimal digits for holdings up to four hectares, a polygon for anything larger. The land must not have been forest after 31 December 2020, and production must satisfy the law of the country concerned.
Gathering that is awkward in rubber. Roughly 85 percent of world output is tapped by smallholders and blended at the first dealer, which is exactly where plot identity normally disappears. Country risk then sets the workload. Origins classed as standard risk, Malaysia among them, get no simplified route, so full assessment and mitigation apply.
What Arrives With the Delivery
For a buyer, the deliverable is a reference number. Under the 2025 simplification, downstream operators no longer file statements of their own, but they must hold supplier and customer records, keep the references they receive, and retain both for five years. A statement attaches to a production period rather than a part number, so it has to travel with the lot.
One timing point is worth planning around. Goods lawfully placed on the EU market before 30 December sit outside the obligation. Buying forward to finish a season is legitimate; treating that as a permanent stockholding policy is not.
Specification Language for the Deadline
Four clauses do most of the work. Name the polymer family per SKU rather than per product family. Require the statement reference on every delivery note, not once at award. Require remaining shelf life at delivery, because age is now a compliance variable as well as a barrier one. And require written notice before any change of compound or latex source, since a substitution invalidates the permeation data the glove was bought for.
Then a fifth, less comfortable question: what happens when a statement is missing at the gate. The answer should be a documented rejection route, agreed before the first shipment, rather than an assurance that it will not arise.