Only products with a verifiably deforestation-free origin may be placed on the market in the future. Jens Trabert explains what this means for FST in this interview.
The European Union aims to stop the conversion of rainforests into agricultural land in order to protect the climate, biodiversity and human rights. To achieve this, it signed off on the European Union Deforestation Regulation (EUDR). It obliges companies to prove that certain raw materials and goods do not stem from deforested areas. This means that goods and products may only originate from areas that have not been cleared since December 31, 2020. Suppliers must prove this with geodata. The regulation covers raw materials such as wood, coffee, palm oil and – of particular importance to Freudenberg Sealing Technologies (FST) – natural rubber. Companies unable to provide a due-diligence statement (DDS) for their goods will no longer be permitted to import them into the EU or sell them there. Non-compliance can lead to fines of up to four percent of annual revenue. For FST, this translates into new data, new processes and a great deal of work.
The regulation was set to come into force on January 1, 2026. The EU has now pushed the start date back by one year. Following the EU’s decision to postpone the deforestation regulation during the trilogue procedure at the beginning of December, the European Parliament formally approved the postponement during its session on December 17. This is intended to ensure a smooth transition.
The postponement gives companies more time – but, as Global Director of Sustainability Jens Trabert points out, it does not mean FST can ease off.
Mr. Trabert, when you heard that the European Union Deforestation Regulation was postponed, did you breathe a sigh of relief and relax?
Yes and no. It takes some of the pressure off, but we can’t just relax. The processes are complex and the requirements haven’t changed. We’re using the extra time to set up stable processes and train everyone involved. The delay is no reason to slow down – on the contrary: We want to be as well-prepared as possible before the regulation takes effect.
How much does it affect FST?
Actually, quite strongly – even if we process comparatively little natural rubber. The regulation applies to several thousand items, including kits and multi-component parts from the Industrial Services and Corteco divisions. The customs tariff codes are broadly defined and cover natural rubber, rubber blends, non-vulcanized rubber, as well as seals and rubber-metal parts made of soft rubber. But FST mainly processes synthetic elastomers, which also fall into the same tariff category but are irrelevant for the EUDR. So far, the negative import certification and communication with the customers have been very time-consuming.
In addition to natural rubber, the new EU rules also apply to other materials we use: wood, paper and palm oil. Wood and paper are used for packaging and pallets, for example, while palm-oil spray is applied in some of our production.
What exactly does FST have to do to comply with this law?
Our first task is to classify all imports and exports according to EUDR-relevant customs tariff codes. For any affected products, we must obtain due-diligence statements (DDS) from our suppliers. These confirm that the goods were produced without deforestation. The statements are uploaded into the EU’s information system and assigned a DDS number. Alternatively, we get the number directly from the supplier. The goal is to ensure seamless traceability throughout the supply chain. This makes the EUDR far more than a sustainability initiative – it is a compliance factor with direct impact on the supply chain.
In the second step, we must integrate these DDS numbers into our SAP master data and supply-chain processes. This ensures that shipments clear customs without delay and that we can respond quickly to customer inquiries.
That sounds like a big task. How are you handling it?
We’ve set up a team of experts and are working closely with colleagues from Purchasing, Material Development, Import/Export, Supply Chain Management, Sales, Compliance and the lead centers. FST doesn’t purchase all materials centrally; the lead centers also place their own orders, which makes this more complex. We’re providing training, sharing information, and have a detailed roadmap that lays out our next steps.
What are your current challenges?
There are a few technical hurdles and areas of uncertainty. For example, the EU’s system for registering DDS numbers is not yet fully operational – that was certainly one of the factors behind the postponement. Many things are currently in flux and we have to react flexibly to this. In addition, the European Commission has until May 2026 to propose simplifications. Only after that will the exact requirements be clear – and then the time until December 2026 will be short again.
Thank you very much for the interesting insights, Mr. Trabert.
