Natural Rubber and the European Union Deforestation Regulation: Perspectives from a young sustainability advocate working on natural rubber

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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.

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GPSNR supports the inclusion of smallholder farmers in EU natural rubber supply chains, and affirms their customary and native land use rights

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. 

GPSNR Secretariat April 12, 2024
Members

Embracing our Shared Responsibility: GPSNR’s newest Working Group (Members Version)

Before the second General Assembly on 23 September 2020, the GPSNR Executive Committee had approved the creation of a Shared Responsibility Working Group that would be tasked to define the principles of shared responsibility for GPSNR.

The term ‘shared responsibility’ is relatively new to the sustainability scene, and as such, there is currently no commonly accepted definition for it. In general, shared responsibility is a value-driven concept which recognizes that supply chains are structurally imbalanced in terms of value and benefit, risk, burden of compliance, climate change impacts, power of negotiation, and access to information and resources. A shared responsibility approach strives for value, benefits, risks and improvement investments to be equitably distributed across all actors within the supply chain.​

In order to establish the foundational work that would enable the creation of the Shared Responsibility Working Group, the Executive Committee formed a Task Force comprising several of its members. Over a series of weekly calls, the Task Force has developed a Terms of Reference (ToR) and a set of Guiding Principles to inform the work of the new Shared Responsibility Working Group.

It is envisioned that the Shared Responsibility Working Group will draw from the Guiding Principles for Shared Responsibility (currently being developed by the Executive Committee’s Shared Responsibility Task Force), as well as the GPSNR Equity Definition and the studies launched by the Equity Working Group, to develop an implementation framework for the platform with respect to shared responsibility.

GPSNR is now looking for members interested in joining the Shared Responsibility Working Group, to register with the Secretariat. If you are interested to join the SR WG, please email Aidan (aidan@gpsnr.org) to indicate your interest. The deadline for expressing interest is Wednesday 24th February, after which the WG will nominate co-chairs and kickoff as soon as possible.

The Shared Responsibility Working Group Terms of Reference can be found here.

Shared-Responsibility-WG-TORDownload

GPSNR Staff February 16, 2021

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