Statement by the Global Platform for Sustainable Natural Rubber on Proposed new EU Deforestation Regulation

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The Global Platform for Sustainable Natural Rubber (GPSNR) affirms the commitment of its membership toward deforestation-free natural rubber supply chains and acknowledges the importance of engaging with regulators to support its ambitions. In considering how to address the risk of deforestation and forest degradation associated with products placed on the EU market, we urge EU regulators to continue to engage with the rubber and tyre sector to ensure that the due diligence requirements ultimately deliver social and environmental benefits, including eliminating deforestation from rubber supply chains and improving smallholder livelihoods. Adopting a risk-based approach at jurisdictional or landscape level with mitigation and impact driven capacity building actions would promote inclusive and scalable progress in the smallholder context, whilst effectively addressing the goal of preventing products derived from deforestation caused by natural rubber from being placed on EU markets.

In this respect, GPSNR believes that any regulation addressing deforestation in the natural rubber supply chain, including the present proposal, must align with the following factors to be transformative:

• Sustainable natural rubber must promote equity for smallholders. Smallholders represent 85% of natural rubber production globally. The design of any regulation relating to natural rubber must consider and mitigate any potential negative impacts on smallholder farmers while aiming to improve the livelihoods of farmers who adopt sustainable practices.

• Considering the complexity of the natural rubber supply chain, a risk-based approach that has jurisdictional traceability as its foundation offers a practical and effective approach to addressing deforestation. While advances in traceability are being made in the natural rubber sector, it is currently infeasible to conduct farm-to-factory tracing in all cases. A risk-based approach would include requiring some farm-to-factory tracing where risk is non-negligible, but not in every natural rubber supply chain.

• Capacity building to promote sustainable practices, for smallholders and plantations alike, is an essential tool to curb deforestation in the natural rubber supply chain, so any regulation should prioritize funding to enhance capacity building.

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GPSNR Working Groups Update: May 2023

Strategy and Objectives Working Group: The consortium of Agridence and Koltiva have initiated field trials for the Risk Subgroup Traceability Pilot. The Risk Subgroup is also planning the next steps for the deliverable from ASI regarding the Risk Assessment Framework, including internal piloting and cross-walking with GPSNR commissioned studies to identify any gaps. 

Additionally, the Risk Subgroup and Basel Institution are in preliminary discussions for a potential collaboration to investigate corruption risk in the supply chain. The Assurance Model Task force will convene to receive updates on KPI alignments, the due diligence system, and the progress model of its members.

Smallholders Representation and Capacity Building (SCB) Working Group: The SCB WG has formally endorsed the Terms of Reference (TORs) on April 27, and the Smallholders Policy-Equivalent (SPE) Taskforce is currently working towards securing the SCB WG’s endorsement for the final recommendations presented in their report.

The Thailand National Subgroup recently announced a tender for GAP Coaching on May 4, with a proposal submission deadline of June 30, 2023. Meanwhile, the Agroforestry-Income Diversification Taskforce is working on finalising the workshop schedule for the years 2023-2024. Lastly, the SCB WG will continue to oversee all projects taking place in Indonesia and Thailand.

 Policy Toolbox Working Group: The working group has chosen consultant Petra Westerlaan to propose a quantitative approach for the reporting matrix, including a crosswalk with other reporting frameworks (CDP Forest, GRI, and ZSL-SPOTT), aiming to facilitate data aggregation and simplify the evaluation of annual progress. They will evaluate and decide on the consultant’s proposed revisions to the reporting framework, and make recommendations to improve the reporting process and timelines.

The Policy Toolbox WG has to agree on the TRR, update Reporting Guidance to reflect the proposed changes, and finalize the Compliance Panel TOR and operational guidance based on the Assurance Model. The WG is currently conducting meetings that will continue during the in-person meetings. 

Shared Responsibility Working Group: The face-to-face meeting included a presentation on governance and guiding principles, and manufacturers to submit a revised document. The WG is currently awaiting the outcomes of discussions on shared investment principles at the manufacturers’ category level before proceeding with their work. Once the proposal from the manufacturers is available, the WG will revamp the discussions on data sharing and value transfer.

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Introducing More Ways to Communicate about GPSNR

The COVID-19 pandemic is impacting the entire natural rubber supply chain. It has triggered car and tire manufacturing companies to operate with a reduced workforce, or temporarily halt production plants altogether. Strict lockdown measures have caused a drastic fall in the sales of consumer tires across Europe. Global demand for natural rubber has dropped, the effects of which will be felt by the 6 million natural rubber smallholders in Asia, Africa and Latin America.

Many smallholders live in poverty, depending on daily wages to feed their families. Their situations will only be exacerbated by the COVID-19 crisis. Already, the Association of Producers and Processing Plants of the State of São Paulo (APABOR) has estimated that for Brazil alone, the subsistence of around 100,000 natural rubber farmers and their direct relatives is at risk.

While COVID-19 exposes the vulnerabilities of smallholders, it also reveals the potential they have to be agents of change and drivers of transformation. The pandemic has reminded us of the connections between human health, resilient landscapes, economic stability and livelihoods; the post COVID-19 world is more likely to devote greater attention to tackling environmental, social and economic impacts of its many supply chains. Smallholders, who produce 85% of the world’s natural rubber supply, are thus key to advancing GPSNR’s vision of a fair, equitable and environmentally sound rubber value chain.

One of GPSNR’s major outcomes for this year has been welcoming our new smallholder members. As of today, a total of 27 smallholder members (with additions from Myanmar) have joined GPSNR. The inclusion of smallholders into the fabric of the Platform provides them the opportunity to drive the agenda for sustainable natural rubber and, in the long-term, realize the social, economic and environmental benefits that sustainability brings. 

We encourage GPSNR members to communicate this outcome through the communication channels of their respective organizations. To this end, we launched a quarterly Members’ Communication Toolkit which outlines the suggested key message and provides ready-to-use content for communicating the message. GPSNR Members may access the Members’ Communication Toolkit for Q2 2020 in the GPSNR Forum.  

More is being done to fully include these smallholders in the Working Groups and Executive Committee. The Smallholders Representation Working Group continues with its efforts in designing a programme for onboarding smallholders prior to the General Assembly. In the meantime, some of our new smallholder members are already actively involved in Working Group discussions. Additionally, having recognized the urgency to address the impacts of COVID-19 on smallholders, the Equity sub-Working Group is developing a position paper on the issue.

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