PUBLIC CONSULTATION: GPSNR OPERATIONAL GUIDANCE FOR EUDR IN THE NATURAL RUBBER SUPPLY CHAIN
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Public feedback is currently closed and under review
The Global Platform for Sustainable Natural Rubber has prepared three guidance documents to support GPSNR members in their efforts to comply with the upcoming European Union Deforestation Regulation.
The Platform is now conducting a 30-day public consultation on these documents. After the consultation, a multi-stakeholder task force within the Platform will review the comments, make the necessary changes, and send these documents for endorsement by the Executive Committee.
Any feedback on the documents should be added by 15th May 2024.
The final version will be publicly available once all the feedback has been incorporated.
Earlier this year, I joined the Global Platform for Sustainable Natural Rubber (GPSNR) to work with smallholder farmers, civil societies, manufacturers, processors and end users on capacity building for those at the bottom of the natural rubber (NR) supply chain. The primary goal was to equip them with the necessary skills for sustainability reform, with the ultimate goal of cultivating better quality raw materials and fostering greater economic mobility. This journey provided me with valuable insights, enabling me to learn from industry professionals and gain an understanding of sustainability issues from diverse perspectives. In this short article, I would like to share some of my key takeaways from being exposed to GPSNR’s initiatives for a sustainable NR industry and interacting with those from other commodities on similar journeys.
To begin, the adoption of the European Union Deforestation Regulation (EUDR) is widely celebrated as a significant step in combating climate change and demonstrates the EU’s commitment to ensuring a sustainable supply chain. However, my interactions with smallholder members of GPSNR shed light on the concerns raised about the shifting of compliance costs to producers. One smallholder member I work with has often highlighted the challenge of balancing the cost of implementing sustainable practices against revenues. They expressed their desire for tangible benefits, such as receiving premium prices for their products, if they were expected to adopt sustainable farming methods. To truly ensure a sustainable supply chain, it is important for governments and industry players to support and assist the vulnerable groups along the supply chain in overcoming the financial barriers they face. This will help ensure that the burden of compliance costs is not disproportionately placed on their shoulders.
Attending the Partnerships for Forests (P4F) Forum 2023 in London. P4F’s invaluable support has played a pivotal role in empowering GPSNR’s smallholders and fostering sustainable engagement.
Additionally, while initiatives to combat deforestation remain crucial, we must not overlook the importance of addressing social issues and the potential economic consequences of such regulations. At the Amsterdam Declaration Partnerships in May 2023, I had the opportunity to hear a minister from a producing country emphasize the importance of consuming nations recognizing the economic and social consequences. Failing to consider economic and social consequences can have far-reaching effects such as increased poverty levels and inequality. Therefore, a holistic approach that balances all three pillars of sustainability is necessary to safeguard the well-being and livelihoods of those affected while protecting the environment.
Lastly, drawing from my experience during the National Initiatives Strategy meeting, an initiative to enhance social, environmental, and economic welfare on a global scale, it became clear that national initiatives have certain limitations when it comes to supporting multiple commodities simultaneously. Therefore, these initiatives need to prioritize specific commodities in order to ensure practicality and effectiveness. During the meeting, it was collectively acknowledged that national initiatives do not need to take the lead in every solution, but rather offer support to industry and government-led initiatives while fostering effective collaboration to avoid duplication in allocation of resources. This also highlights the significance of industry-led solutions, which can complement the work of national initiatives. Industry players’ proactive measures can help anticipate and mitigate potential risks in the supply chain more effectively, promote sustainable practices, and contribute to the overall goal of combating climate change and complying with EUDR.
As I reflect on my experience with GPSNR, it is evident that sustainability in the NR supply chain has been a longstanding commitment even prior to the introduction of the EUDR. Various initiatives have been taken to promote sustainable practices within the NR industry, including the approval of reporting requirements and the adoption of the GPSNR policy framework. These initiatives aim to encourage GPSNR members to align their practices with GPSNR Policy Framework and thus, establish strong sustainability commitments across the NR supply chain.
This year marks a significant transition for GPSNR as we move from commitment to implementation, focusing on four key fronts. Firstly, our efforts are dedicated to finalizing the GPSNR assurance model, an encompassing framework that establishes sustainability guidelines and standards for the entire supply chain. Additionally, GPSNR is also actively working on implementing the shared responsibility mechanism, wherein the manufacturers collaborate to share the costs of capacity building, fostering an equitable and sustainable NR industry.
Furthermore, GPSNR is expanding its capacity building initiatives in essential areas such as Good Agricultural Practices (GAP), agroforestry, and disease management. These efforts aim to empower local communities in key NR producing regions, particularly in Thailand and Indonesia. GPSNR also implemented a smallholders-inclusive strategy, whereby smallholders members can participate in the decision-making processes, become part of the Executive Committee of GPSNR, and have the voting rights at the General Assembly. This ensures that the voices and perspectives of smallholders are taken into account in the development and execution of sustainable natural rubber initiatives.
Lastly, GPSNR is actively striving to fine-tune decisions that support a smoother implementation of the EUDR, which include shared due diligence systems, joint deforestation analysis tools, and common traceability tools, all funded by manufacturers. These measures will enhance transparency and accountability within the NR supply chain.
Members of the Smallholder Representations and Capacity Building Working Group, which include smallholder members from Thailand and Indonesia, come together in Singapore, bringing their invaluable perspectives to GPSNR workshops in June 2023.
In conclusion, my journey with GPSNR as a passionate sustainability advocate has underscored the significance of collaboration in forging a sustainable NR industry. As we navigate the path forward, it is crucial to address the challenges ahead while maintaining a delicate equilibrium between environmental, social, and economic considerations. The initiatives undertaken by GPSNR, including capacity building, smallholder inclusion, and strategic decisions to support EUDR implementation, reflect a steadfast commitment to sustainability. Together, we can make a positive impact on the global NR supply chain and create a sustainable future.
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 Secretariat
April 27, 2022
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Step 1: Commitment and Reporting
Members commit to this policy framework and report on these questions
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