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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Preparing Smallholders for their Role in GPSNR

Following the announcement that the GPSNR General Assembly (GA) will take place in September, the Smallholders Representation Group has quickly adapted its plans around onboarding smallholder members prior to the GA. With restrictions around COVID-19 necessitating a virtual format for the GA, likewise the sessions involving smallholders would follow suit.

The onboarding will be conducted via a series of national and international calls starting from late July until the end of September. There will be a total of 3 calls amongst smallholders at the national level, and another 3 calls at the international level. 

The first national calls have already been conducted for all seven countries: Brazil, Côte d’Ivoire, Ghana, Indonesia, Myanmar, Thailand and Vietnam. During this first call, the smallholders were introduced to the video conference platform with a quick tutorial on its functions. Next, they were given an update on developments and projects within GPSNR before learning more about the upcoming GA, including the onboarding schedule, the process for Executive Committee elections and an overview of the resolutions. 

The Country Champions are providing immense support through coordination of the calls, conducting the calls in the local language and in some cases reaching out to the smallholders individually to help them overcome the barriers of using new technology.

The Working Group will be engaging an experienced facilitator who will be able to foster relationships as well as trigger and encourage discussion amongst the smallholders  in an international and multilingual setting. A Request for Proposal was posted on the GPSNR website and social media channels, and the Secretariat is supporting the Working Group in finalizing the selection of proposals.  

The next national call will see smallholders sharing about themselves and their work in natural rubber production, an activity designed to assist them each in articulating their thoughts and vision as potential election candidates for the Executive Committee.

News

GPSNR Working Groups Update: September 2021

What an interesting month has passed us by! As we step closer to the General Assembly of 2021, here’s what the working groups have on their plate:

Strategy and Objectives Working Group

After conducting 2 sessions of the Theory of Change (ToC) Workshop this month, the Strategy and Objectives working group will soon finalise the ToC document and potentially identify new strategies for GPSNR.

Smallholder Representation Working Group

After two successful smallholder onboarding workshops for smallholders from Indonesia and Cambodia, the working group is formally incorporating new smallholders from the two countries as GPSNR members. The group is also conducting onboarding workshops for India at the end of September and Sri Lanka and Thailand in October. 

At the same time, they are developing workshops to onboard more smallholders from Vietnam, Thailand, Ivory Coast, and Ghana and organizing the third Smallholders International Call next month. 

Policy Toolbox Working Group

As the General Assembly of 2021 comes closer, the group is continuing to develop the Implementation Guidance, Reporting Requirements and Compliance Panel Guidance. 

Capacity Building Working Group

As they develop key deliverables and milestones for Thailand National Subgroup and the Agroforestry Task Force, the Capacity Building Working Group is also busy with the Good Agricultural Practices (GAP), a system to monitor impacts of capacity building activities and implementation plans for Ivory Coast and Indonesia.

Traceability and Transparency Working Group

This working group has developed a Traceability Benchmark to support member uptake of traceability and provided draft input and received feedback for Implementation Guidance on traceability. They are now working on finalising the draft and conducting member consultations on the Benchmark. 

Shared Responsibility Working Group

The group is currently exploring and discussing detailed  solutions to identified root causes for each focus area of shared responsibility. It is also drafting activities and a framework for Shared Responsibility for integration into other processes such as the Implementation Guidance.

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