Statement by the Global Platform for Sustainable Natural Rubber on Proposed new EU Deforestation Regulation

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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.

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News

GPSNR Working Groups Update: December 2020

Strategy and Objectives Working Group

The Working Group has received several bids in response to the Request for Proposal (RFP) for a study on environmental impacts, and risks, in the natural rubber value chain that was published in November. The Working Group has shortlisted three candidates and, as part of the evaluation process, will be conducting with these candidates in January 2021 before awarding the bid to the successful candidate. 

The Working Group is also starting on the Theory of Change document update, an exercise which will involve all other Working Groups. This will take place in January 2021. The Equity sub-Group is preparing summary documents for the living income studies and is planning to present the studies to GPSNR members in early 2021.

‘Policy Toolbox’ Working Group

The Working Group has finalized the Baseline Reporting Requirements and these will go to the Executive Committee for review. The Working Group is also developing a Request for Proposal for a consultant to work on the implementation guidance and reporting requirements.

‘Capacity Building’ Working Group

Since the last update, the Good Agricultural Practices (GAP) Task Force has had their first kickoff call and is beginning the work to identify and/or refine guiding principles for GAPs appropriate for the sustainable production of natural rubber.

The Working Group is also engaging the Executive Committee on their comments regarding the proposed capacity building strategies for four focus countries.

‘Traceability and Transparency’ Working Group

In early December, the Working Group onboarded smallholders from Indonesia and Côte d’Ivoire into the group, with the smallholders participating in their first meeting on 10 December. 

Aside from reviewing the Working Group’s Terms of Reference (ToR) and its objectives moving forward, the Working Group will also be starting to develop recommendations for members on traceability and transparency tools in early 2021.

Smallholder Representation Working Group

The revised ToR for the Working Group is undergoing a final review, following which it will be sent to the Executive Committee for approval. 

The Working Group has also formalised a document that defines the role and key tasks of a Country Champion. So far, Country Champions have been actively involved in organizing and arranging national calls, supporting smallholder engagement, and providing technical and linguistic assistance.   

As part of the Working Group’s revamp, it will be undergoing a membership refresh. Part of this will also involve smallholders being onboarded into the Working Group in 2021.  The Working Group is also looking into onboarding smallholders from Cambodia. Any GPSNR members who have operations in Cambodia or partners working in Cambodia who can help to identify potential smallholders for an onboarding workshop are welcome to reach out to the Working Group’s Co-Chairs, Ulrich Antoni and Julian Oram.

News

GPSNR Working Groups Update: February 2021

Strategy and Objectives Working Group

Further to the receipt of several submissions in response to the Environmental Risk Study request for Proposals, the Strategy and Objectives Working Group has now  selected the Proforest team, together with consultant Liza Murphy, to conduct the environmental risk study. The team will be reaching out to GPSNR members to have initial scoping conversations in support of the study.

The Equity Sub-Working Group has drafted a summary for the Living Income studies undertaken in Thailand and Indonesia next year. Pending approval from the Sub-Working Group and S&O Working Group Members, the summary will be released to all GPSNR members and a webinar will be held to present the responses.

Representatives from each of the platform’s other Working Groups have started to draft their Working Group’s Theory of Change. At the end of the month, the Strategy and Objectives Working Group will consolidate this information and develop a platform-wide Theory of Change.

‘Policy Toolbox’ Working Group

The Policy Toolbox Working group has received initial proposals for the development of Implementation Guidance request for proposals (RFP) and will be meeting to discuss and select a proposal.

The Working Group will be setting up focus groups for category members to participate in the development of the implementation guidance. The call to join will be in the newsletter and also in the other article to be published.

In the next weeks, the Working Group will also be developing a new RFP for a consultant to help refine the reporting requirements based on the BRR pilot done last year. The consultant will work to bring the questions into alignment with other reporting systems (e.g. CDP and Ecovadis) and ensure that the questions are phrased in a suitable manner.

‘Capacity Building’ Working Group

The Capacity Building Working Group conducted a webinar to share about the national CB strategies and recruit members to the national sub-groups.

‘Traceability and Transparency’ Working Group

The ‘Traceability and Transparency’ Working Group has now set up 3 sub-groups that will focus on different tasks: refining the WG theory of change, developing a definition of traceability and minimum acceptable levels of traceability, and developing a data collection process with Policy Toolbox Working Group members.

Smallholder Representation Working Group

The Smallholder Representation Working Group has completed logistical organization of the Smallholders caucus call, that will happen tomorrow, 25th February. The caucus call will allow sharing and collaboration among smallholders across national lines.

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