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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.
Strategy and Objectives Working Group
The risk subgroup, which sits under the umbrella of this working group, has studied the various definitions of polygons in the EU Deforestation Regulation through an extensive survey conducted for GPSNR PPT members.
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. 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 and evaluating proposals received for the GPSNR-HCSA Smallholder Toolkit Field Trials.
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.
Capacity Building Working Group
The group is currently evaluating proposals to appoint a software developer for the second phase of the GPSNR Knowledge Sharing Platform. They have kicked off the Disease Fighting Project with SNV-IRRI in Indonesia, after having recently completed the first milestone of the SNV-Proforest GAP coaching 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.
Shared Responsibility Working Group
The group has completed 40% progress on the agreed deliverable for each pillar, and is continuing to work towards completion ahead of the meetings in January. The WG is also working to align with the Assurance Model Task Force to advance the Shared Responsibility agenda.
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Global Platform for Sustainable Natural Rubber
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