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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News

GPSNR Working Groups Update: December 2022

Strategy and Objectives Working Group

The risk subgroup, which sits under the umbrella of this working group, is working on a series of Traceability tools webinars for GPSNR members to present on some tools available that would help members map their supply chain. The subgroup is also working on a pilot traceability study to investigate what it takes (costs, time, labour) for a company to map its supply shed. The subgroup is also working with a consortium to develop a risk assessment matrix.

The assurance model subgroup continues to work on the KPIs set during the last in-person meeting as they are to be finalised at the end of the year and presented during the next in-person and hybrid meetings in January 2023.

Smallholder Representation Working Group

After completing two rounds of pilot agroforestry workshops for smallholder members in Indonesia, and Cambodia, the working group is working on concluding how GPSNR should approach agroforestry capacity building in the long term through an agroforestry strategy. This work stream aims to integrate priorities of smallholders with developing long-term income diversification strategies through the Capacity Building Working Group.

They are also busy holding focus group discussions towards the smallholder policy equivalent, kickstarting HCSA-HCVN programme field trials for natural rubber smallholders, and on enhancing integration with the capacity building working group.

Policy Toolbox Working Group

The group is working on finalizing the TORs for the Year 1 Reporting Review to be conducted in the first quarter of next year. They are also assessing if any changes to the reporting framework and its details (i.e. process, extensions, questions) are needed based on the Year 1 Reporting Review results. They have already kicked off the crosswalk of the reporting requirements against other reporting frameworks to better improve the questions. The group would also be sending out a survey for members to provide feedback on their reporting (reporting process, reporting requirements questions, guidances, etc.). They would also be working on the Transparency Reporting Roadmap for years 2 and 3 of reporting that would be voted at the GA 2023.

Shared Responsibility Working Group

The group is currently evaluating proposals to appoint a software developer for the second phase of the GPSNR Knowledge Sharing Platform based on a reworked tender. In 2022, they have also kicked off the Disease Fighting Project with SNV-IRRI in Indonesia, after having recently completed the first milestones of the Koltiva and SNV-Proforest GAP coaching projects in the country. They continue to seek members’ funding for capacity building projects in Indonesia (second stream of disease fighting) and Cote d’Ivoire (training centres). To know more, you can find the project details here

News

Smallholders Representation Working Group Update – January 2020

Of the 22 applicants, one is from Brazil, four from Côte d’Ivoire, two from Ghana, five are from Indonesia, four from Thailand and six are from Vietnam.

The 2nd General Assembly on 31 March 2020 will see the proposal of a new membership category, ‘Smallholder Producers’. Should the voting on this resolution pass, smallholders will officially find their voice in global efforts to ensure a socially, economically and environmentally sound natural rubber supply chain.

Thanks to sustained funding from Partnerships for Forests (P4F), we will be able to invite the geographically diverse group of smallholders to Singapore to attend their first General Assembly, with the view to onboard them and to have smallholder producers represented in the Executive Committee via the voting of nominated individuals.

As it is important for the smallholders to understand what is required of them at the General Assembly and as an Executive Committee member, the Working Group will be scheduling several sessions, both remote and on-site, to thoroughly brief the smallholders on GPSNR’s Statutes and Code of Conduct. The smallholders will also have the opportunity to get acquainted with one another in the two days prior to the General Assembly.

In preparation for this, the appointed Country Champions of the Working Group will be assisting the smallholders in travel logistics and other administrative matters. The Working Group is also looking into engaging professional translation services at the General Assembly to emphasize impartiality.

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