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

Share This Post

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.

More To Explore

GPSNR Working Groups Update: October 2023

Strategy and Objectives Working Group:

Drafts of the proposed KPIs and Due Diligence System for the platform have been finalised and are now pending further discussions following the expected approval of the Members Journey Model at the 2023 General Assembly. These discussions aim to achieve document finalisation and alignment.

As for the Risk Subgroup Traceability Pilot Field Trials, both consortiums, Agridence and Koltiva, have submitted their final reports and signed off on these projects. They will be presenting the results of the Traceability Pilot Field Trials in an upcoming webinar session open to the public.

Simultaneously, the Risk Subgroup have been gathering and analysing user feedback for the initial version of the Risk Tool.

In the event that the Assurance Model resolution (5b) receives approval, the Assurance Model Task Force is poised to collaborate with ASI in developing GPSNR’s comprehensive Assurance Model. This endeavour will encompass alignment with existing normative documents, member consultation, and pilot testing. Ongoing discussions are currently underway to establish an operational plan and timeline for this initiative.

Furthermore, the Risk Subgroup has embarked on preliminary discussions exploring a potential collaboration with the Basel Institution to investigate corruption risks within the supply chain.

Lastly, the Risk Subgroup is currently awaiting alignment on normative documents by ASI before proceeding with further development of the Risk Tool. This step ensures that the tool complies with the requirements of the Assurance Model.

Smallholders Representation and Capacity Building (SCB) Working Group:

The SCB WG has efficiently organised both national and international calls with smallholder members in preparation for GA2023. To enhance comprehension among smallholder members, the GA Booklet has undergone translation in accessible languages.

In addition, the Thailand Agroforestry subgroup has conducted the first two rounds of coaching sessions for 100 smallholders in Songkhla. Similarly, the Thailand Good Agroforestry Practices (GAP) subgroup has initiated its activities with a kick-off meeting.

On the technological front, the Digital Knowledge Sharing Platform (KSP) task force has convened multiple times to review the developed features, with plans to address bugs and enhance the platform’s functionality. The HCSA-HCVN Field Trial report has received official endorsement.

Looking ahead, the SCB WG will continue to oversee all projects within its purview. The Indonesia subgroup is scheduled to present quarterly reports for all three projects on October 27, 2023. Additionally, a webinar is slated for November 30, 2023, to present the findings of the HCSA-HCVN field trial.

Regarding the Thailand GAP project, GPSNR is in the process of finalising an official joint letter with RAOT. Members interested in joining the Thailand GAP project, specifically in Chiang Rai and Bueng Kan provinces, are encouraged to contact the secretariat for further details.

The KSP task force has plans, including pilot training for smallholders in Indonesia and Thailand, along with soliciting feedback on the Rubber Wiki app.

Lastly, the Income Diversification and Rubber Agroforestry task force is organising its first agroforestry workshop of 2023, set to take place in Cote d’Ivoire at the end of October 2023.

Policy Toolbox Working Group:

The Policy Toolbox Working Group (WG) collected input on the reporting process, utilising surveys and stakeholder-specific meetings as part of the Year 1 reporting review process. This feedback played a critical role in shaping the disclosure requirements for Year 2 reporting data and will also be a central consideration in the forthcoming discussions concerning revisions to the Reporting Requirements (RR) matrix.

The WG, under the guidance of selected consultant Petra Westerlaan, submitted a proposal aimed at making the RR matrix more quantitatively oriented. This proposal is partially based on a crosswalk with other reporting frameworks like CDP Forest, GRI, and ZSL-SPOTT. The shift toward quantification is intended to simplify data aggregation and streamline the assessment of annual progress.

Additionally, Agridence has proposed the development of a digital platform and dashboard for the RR, with a focus on enhancing the process of reporting data collection and aggregation. This proposal received approval from the Executive Committee, and Agridence is slated to commence work in late October 2023.

The disclosure requirements for Year 2 reporting have been approved by WG1 and the Executive Committee, and they will be included as a Resolution for vote at the 2023 General Assembly.

Looking ahead, WG1 is preparing to revise the RR matrix based on Petra’s proposal for a more quantitative framework and in alignment with the Assurance Model. Once approved by the WG, the revised matrix will undergo circulation to the broader membership for consultation with the aim is to secure approval for the revised reporting requirements at an extraordinary General Assembly in early 2024.

Following the approval of the revised reporting requirements, the Policy Toolbox WG will proceed with the development of disclosure requirements for Year 3 reporting.

Shared Responsibility Working Group:

The Governance Framework and In-Kind Contribution components have been integrated into the Assurance Model framework, slated for voting at the 2023 General Assembly. This integration serves as a robust foundation for further discussion, particularly due to its close alignment with the KPIs.

Furthermore, the Governance Framework and In-Kind Contribution Requirements for the Shared Investment Mechanism have reached finalisation and are set for a vote at an extraordinary General Assembly in 2024.

The WG is developing a protocol in collaboration with the SCB WG. This protocol will be used to filter and evaluate proposals based on the Equity definition and stakeholder criteria as defined by the Executive Committee (EC).

Additionally, the Secretariat is in the process of creating operational guidance for the implementation of the Shared Investment Mechanism. This guidance will subsequently be shared with the Working Group.

Lastly, there is currently an open co-chair seat, and we are inviting volunteers to step forward.

abby October 25, 2023
News

In favour of disagreement

Why conflict is crucial for meaningful sustainability initiatives

— Aidan Mock, Impacts and Assurance Manager

Since joining the Global Platform for Sustainable Natural Rubber in July 2020, I have spent about 3,000 hours working for the organization. Malcolm Gladwell popularized the controversial idea that it takes 10,000 hours to become an expert at something which means that I still have a long way to go. Reflecting on these two numbers at the end of last year, I started to wonder how much time it takes GPSNR as a whole to demonstrate progress. I was most curious about our brand new Reporting Requirements (RRs) which were approved at the General Assembly last year. The RRs will ensure that all GPSNR members have standardised sustainability data which can be tracked, monitored, and analysed to meet our goals on sustainability and equity. Needless to say, this is a crucial piece of work for the global rubber industry.

 In June 2021, ZSL conducted 1.5-hour long focus group calls with each stakeholder category within GPSNR on the RRs. On average a total of 72 work hours were spent on this segment alone, with 12 people attending each of the four calls (12 x 4 x 1.5). In July, the Working Group convened its first meeting to discuss the proposed RRs in detail,  resulting in another 43.5 work hours spent on the RRs. 

The truly difficult months were October and November, where members met almost daily. An average of 19 people joined each of the 22 calls, which lasted about 1 hour and 45 minutes each time. In these two months, members spent a staggering 750 work hours discussing and negotiating the questions. 

By the time Reporting Requirements were sent out for General Assembly vote, GPSNR members had spent more than a thousand hours discussing the RRs at the working group level. The actual number is likely higher as I didn’t include the time spent in category-specific meetings, executive committee discussions, and meetings that ran over their intended time limit. The time taken to complete the RRs eventually amounted to a third of the time that I’ve been working at GPSNR.

Image 2: A screenshot of the tabulation on hours spent discussing the RRs

With members all across the world, these meetings meant sacrificing hundreds of hours of family dinners, early morning sleep, and mid-afternoon siestas! Yet members made the choice to show up for meetings day-after-day, demonstrating remarkable commitment to the mission of GPSNR.

From an outside perspective, one thousand work hours of meetings were needed to create 100 questions, which means we had a progress rate of 10 work hours per question! Sceptics of GPSNR would be quick to point out this “slow progress”, and I will admit that there are faster ways to formulate a hundred questions. However, if you want to get more than 100 members across different stakeholder categories to agree on reporting questions for the entire industry, this is the fastest that it can go. I observed something similar at a grand scale at the COP 26 negotiations in Glasgow in October. Parties spent hours discussing the choice of wording in key phrases and some even used valuable time to simply express disagreement with the text. 

If we are to achieve multi-stakeholder progress, we must adopt the same philosophy and spend time listening to the concerns and disagreements of all parties before we collaboratively develop  solutions to address these concerns. This process of listening to each other and finding solutions will take time, maybe even a thousand hours, but this is the fastest and most thorough way to do it while still honouring the multi-stakeholder principles of the platform.

One of our greatest strengths at GPSNR is that members can disagree with each other openly. I believe that disagreement and healthy negotiation is a sign of a diverse membership that trusts each other to listen and address their concerns. Being able to work towards solutions across “category lines” is also a sign that GPSNR is maturing as we approach our 10,000 work hours of collective practice. I hope we can carry forward this momentum and growth into the new year. I hope we continue to treat the disagreements that will inevitably arise as opportunities to listen, demonstrate empathy, and build trust. I hope we come to see the multi-stakeholder enterprise as one that is conflicting by design and slow by default.

This year, we will work to define the Implementation Guidance and the Transparency Roadmap for the reporting requirements and I expect these topics to involve extensive discussions and quite possibly extensive disagreement. For members already part of this work, I look forward to speaking with you on our calls. If you are not yet part of these discussions but feel  excited by the idea , feel free to write to us and we will ensure that you are included in the meetings that are soon to follow.

See you on a Zoom call soon!

GPSNR Staff January 25, 2022

© 2022 All rights reserved

Global Platform for Sustainable Natural Rubber

Scroll to Top