GPSNR supports the inclusion of smallholder farmers in EU natural rubber supply chains, and affirms their customary and native land use rights

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Smallholder farmers are key stakeholders in natural rubber supply chains accounting for 85% of global supply, and enabling the resilience and sustainability of the value chain. However, smallholder farmers are the most vulnerable to major changes in the economic and regulatory landscape. Their vulnerability is heightened by the fact that many smallholders lack formal land documentation. Fortunately, many rubber producing countries are progressively implementing land tenure formalization programmes for smallholders but they undoubtedly will take significant amounts of time to fully implement.

The Global Platform for Sustainable Natural Rubber (GPSNR) supports the intent and implementation of the EU Regulation on Deforestation-free products (EUDR), and considers it a bold and necessary step to addressing deforestation, human rights violations, and illegality in commodity production, including natural rubber. However, it is key that its implementation ensures the continued inclusion and support of smallholders in EU supply chains.

GPSNR includes more than 200 smallholder farmers from 12 countries in its membership and has heard their concerns regarding the potential unintended consequences of the law.

As reflected in its Policy Framework, GPSNR is committed to recognise and protect the customary, traditional and communal land tenure and use rights of Indigenous People and local communities (IPLC), including smallholder farmers who have such rights, even in cases where they are not formalised yet in the legal system of the country in which they reside.

In view of supporting the inclusion of smallholders in EU supply chains, while ensuring due diligence against illegality, the GPSNR requests the European Commission provide additional EUDR guidance to competent national authorities regarding how to effectively check that operators and traders have conducted sufficient due diligence to determine the legality of commodities falling within the scope of the Regulation considering the mosaic of native and customary land rights arrangements found on smallholder farms around the world. Examples of how this could be achieved might include: 

  •  The creation of a shared information system amongst competent national authorities to assess the practical state of producing countries’ efforts to document and formalize recognition of customary land tenure arrangements for smallholder farmers;

     

  • Work with producer country governments to identify prevalence of customary tenure.

     

  • Providing practical guidance to EU competent authorities and regulated companies on:

     

    o How to robustly assess and map the customary land title claims in each country to ensure smallholders are not cut out of supply chains before formal land registries are created and protect the right to self-determination of IPLCs who do not wish to engage in land title formalisation even if it becomes available. 

    o In countries where formalization of land tenure is still under development, prioritize assessment of legality to establish that commodities placed on the market do not originate from land that has been occupied or acquired in violation of national land laws or customary tenure arrangements (i.e., through a “land grab”); through dispossession or abuse of the rights of vulnerable members of a population by elites; or which is located within prohibited areas such as national parks, wildlife reserves, or other protected areas, or from other restricted use areas.

    o Specifics on the types of documentation to collect to substantiate the rights (formal or customary) of smallholder farmers to use land parcels for the production of the relevant commodity. This could include documentation recognized by local authorities, or other evidence of locally recognized land tenure, and evidence that key regulatory bodies in producing countries have indicated general acceptance that smallholder farmers cultivating land under customary and/or communal land tenure arrangements may legally produce and sell rubber (this may be explicit – e.g., through a license – or implicit, e.g. through the provision of official extension support, credit schemes, or marketing assistance to registered smallholders);

We call the Commission and other EU and national institutions for a joint effort to enable smallholder farmer organizations to meet EUDR compliance; and proactively work with the producing countries to address potentially conflicting national laws, issues of inadequate law enforcement and corruption, and provide support to producing countries to tackle these issues and empower smallholders to maintain access to EU markets. GPSNR commits to support just transitions to secure forms of land tenure. We will collaborate with members to enhance capacity in land tenure and support programs facilitating smallholders’ access to formal land documentation where applicable.

Finally, we wish to clarify that the above proposals are in no way intended to avoid compliance by GPSNR operators and traders purchasing and selling natural rubber products covered under the scope of the Regulation. Rather, they are designed to support and enhance the position of the six million smallholders in global rubber supply chains to help realize the potential of the law, whilst themselves benefiting from it. These proposals are supported by GPSNR’s smallholder and civil society representatives, alongside industry members.

The GPSNR Executive Committee has sent this letter to the European Commission for further deliberation. 

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GPSNR Working Groups Update: April 2022

Here are all their updates from the last month:

Strategy and Objectives Working Group

After conducting a gap analysis of GPSNR’s current activities based on the platform’s Theory of Change, the strategy and objectives working group is working on a strategy to address the gaps found, which they will soon present to the Executive Committee. The gaps found include government engagement and the enhancing the enablers mentioned in the Theory of Change. You can read the Theory of Change here. At the same time, the risk sub working group continues to develop GPSNR’s approach to evaluating and mitigating risk.

Smallholder Representation Working Group

Having onboarded 23 new smallholders into the platform this month, the working group continues to build on other aspects of its scope, including planning workshops for Liberia, Ghana and Malaysia, developing country-specific smallholder engagement activities with smallholders and Country Champions and appointing a consultant to develop the smallholder policy equivalent.

Policy Toolbox Working Group

This group is continuing discussions among its three subgroups: Transparent reporting roadmap, Implementation Guidance and RR Guidance & Tools. In the coming months, they will finalise guidance for the reporting requirements and share it with members.

Capacity Building Working Group

The group is currently busy in the development of GPSNR’s knowledge sharing platform, which includes smallholder interviews, compiling and assessing responses of member surveys and holding focus group discussions in May 2022. At the same time, they are working on advancing Capacity Building plans for Indonesia, Thailand and Côte d’Ivoire. For capacity building efforts in Indonesia, the group has formed two Task Forces under the Indonesia Subgroup to advance Budwood Garden and Disease Fighting strategies.

Shared Responsibility Working Group

The Shared Responsibility has completed a draft of Shared Responsibility Framework and presented it to the membership at two member consultation webinars. In case you missed these, you can watch the recordings here. It has also opened the draft framework to member feedback till 2nd May. Take a look at the framework here and fill in your inputs here.

GPSNR Assurance System – Assessment Service Provider Application

Singapore, 15 December 2025 — Members of the Global Platform for Sustainable Natural Rubber (GPSNR) gathered today for the organisation’s 7th General Assembly, marking a landmark year of progress in collective responsibility, accountability, and member-driven sustainability across the natural rubber value chain.

A major milestone in 2025 was the launch of GPSNR’s risk-based Assurance System, which sets clear sustainability expectations, introduces independent verification, and promotes continuous improvement beyond compliance. Developed collaboratively over several years, the system provides a credible, globally relevant framework for advancing sustainability in the sector. At this GA, End User companies reaffirmed their support and agreed on a structured pathway toward full implementation in their category.

“This year marks a turning point for GPSNR,” said Stefano Savi, CEO of GPSNR. “The Assurance System gives our members a shared and trusted foundation for demonstrating progress across the value chain.”

Members also marked the first year of the Shared Investment Mechanism, an innovative model enabling manufacturers to equitably share the costs of large-scale capacity-building projects, ensuring long-term benefits for upstream actors, particularly smallholders.

“Sustainability cannot be achieved by one part of the value chain alone,” Savi added. “By investing together, our members are enabling more inclusive and impactful outcomes worldwide.”

Looking ahead to 2026, GPSNR will support implementation of the Assurance System through data gathering, member learning, and cross-stakeholder dialogue to ensure the system reflects on-the-ground realities and diverse business models.

The Assembly concluded with renewed commitment from members to advance equitable, resilient, and sustainable natural rubber supply chains.

About GPSNR:

The Global Platform for Sustainable Natural Rubber (GPSNR) is a multi-stakeholder, member-driven initiative working to advance sustainability across the natural rubber value chain.

More at sustainablenaturalrubber.org

Media contact:

Bani Bains, Communications Director
bani.bains@gpsnr.org | +65 9726 8165

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