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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Secretariat Update – July 2019

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As a partner organization for the program, GPSNR was given the responsibility of assigning a research project to the selected group of highly motivated students, who will work on the given topic for a duration of two and a half months. After discussions with the strategy and objective Working Group, ‘Equity in the Natural Rubber supply chain’ in Asia, with main focus on China, Thailand and Indonesia, was concluded to be the chosen main topic of research for the participants. The research will focus on better understanding the cost benefit analysis at different levels of the supply chain, including social and environmental externalities. Students will work on this research project, the findings of which will be submitted to the platform by 12 September 2019.  

Increasing engagement with research organizations and academic institutions such as ESSEC Business School in Singapore, to ensure a science based approach to sustainability in the rubber industry, will remain a key objective for the Platform.

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Smallholders Representation Working Group Update – February 2020

These documents have now been translated into several languages to cater to the geographical diversity of the group. Ensuring that the smallholders have a good foundational understanding of GPSNR’s aims, structure and bodies of the Platform and the roles of those bodies, is key to inclusion and participation. 

A sub-Working Group has been specially established to focus on preparations for the General Assembly and related sessions. The sub-Working Group will have its first session in early March, and will discuss matters such as agenda, potential facilitators, translation services, as well as plans to hold two half-day orientation sessions with the smallholders prior to the General Assembly. 

Due to the ongoing coronavirus situation, the Working Group will revise its timeline for continuing its plans to organize smallholder workshops in additional countries like India and Malaysia. Up for consideration is a partnership with the Capacity Building Working Group on possible short-term projects that can be implemented in the meantime.

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