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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Members

GPSNR Working Groups Update: March 2021 (Members Version)

Strategy and Objectives Working Group

The S&O Working Group has received inputs to the platform Theory of Change from the Smallholders Representation, Capacity Building, and Traceability and Transparency Working Groups. A task team from the S&O Working Group will now work to synthesize these different contributions into a single document. This compiled Theory of Change template will then be developed into the platform Theory of Change through a workshop which will involve representatives from all the working groups.

The Equity Sub-Working Group completed a summary of the Living Income studies that the platform commissioned in 2021 and presented the summary through a webinar. The webinar recording and slides can be found here. The reports are also available here on the member’s portal. The Equity Sub-Working Group will now work to develop recommendations on how GPSNR can address priority risks and boost equity in the value chain.

‘Policy Toolbox’ Working Group

The Policy Toolbox Working Group has selected a combined consultant team of Proforest and Are We There Yet to lead the development of the Implementation Guidance for GPSNR. The development is expected to be a consultative process that concludes with a set of draft guidance that will be ready by July 2021.

To facilitate consultation on the Implementation Guidance, the Working Group will set up category-specific focus groups that members are encouraged to join. The focus groups will meet twice to review the draft guidance and provide feedback and inputs to improve the document. Each focus group is only expected to meet twice and members are only required to spend a few hours before each meeting reviewing the draft documents. The focus groups will be set up in the following manner:

Focus Group 1
Growers
Traders of Raw Materials

Focus Group 2
Processors
Traders of Processed material

Focus Group 3
Tire makers and other manufacturers

Focus Group 4
End users (incl. car makers and other downstream stakeholders).

Members can sign up to participate in a focus group here.

In line with the assessment of policy documents against the policy framework, the Secretariat has collated company policy documents that were submitted and will proceed to review the policy documents submitted for review. The Secretariat has received responses from all 29 ordinary member companies that were required to submit documents and will spend the next month assessing the submissions.

‘Capacity Building’ Working Group

The Capacity Building Working Group has created three separate task forces that will work on working group tasks. The first task force will focus on developing mechanisms to measure impacts of capacity building activities, the second task force will develop a strategy to attract and recognize GPSNR members’ funding of capacity building activities, and the final task force will develop systems to ensure that the national sub-groups tasked with implementing capacity building activities in each country remain aligned with the broader working group. In addition to the Good Agricultural Practices Task Force, the Working Group now has four Task Forces that will work to deliver on their tasks in the coming months.

‘Traceability and Transparency’ Working Group

The Traceability and Transparency Working Group will continue to meet in its sub-groups to develop recommendations on minimum benchmarks for traceability tools and data sharing in the platform. With the submission of the Working Group’s input to the Theory of Change, the Working Group is pleased to announce that its first sub-group has completed the assigned tasking and will no longer meet.

Smallholder Representation Working Group

The Smallholder Representation Working Group has now onboarded smallholders from Indonesia and Vietnam into the Working Group. The Working Group has also divided into two groups within the working group. The first sub-working group will work to develop a strategy to onboard smallholders from countries that are not represented in GPSNR yet. The second group will work to deepen engagement with smallholders who are already members of the platform and also develop strategies to improve representation among minority groups in countries that are already represented in GPSNR

View the March 2021 Working Groups Update Slide Deck for more details on the progress of each Working Group

GPSNR Staff March 30, 2021
News

Smallholders Representation Working Group Update – December 2019

The Smallholders Representation Working Group has agreed to propose the new main characteristics for potential representatives of GPSNR smallholders as below:

Smallholder: individual natural rubber farmers with all following characteristics:

  • The primary source of income for the smallholder is the farm (not only Natural Rubber); 
  • The Natural Rubber production unit size is less than 50ha (although the farm may be larger);
  • Profits from the farm accrue primarily to the owner of the farm and their family.

The new definition combines the qualitative and quantitative aspects with the intention to offer a pragmatic and standardized definition. The working group members understand that average farm size differs from country to country, hence having a universal threshold in farm size might not guarantee that the farmer is a small grower in that particular country. However, a quantitative indicator should be in place in order to give an objective and clear understanding to all audiences. The threshold of 50 hectares is established as an interim quantitative indicator based on the discussion in the working group that more than 80% of natural rubber supply comes from the farm which is smaller than 50 hectares.

The Country Champion is collecting application form from the smallholders that have been nominated durinng GPSNR Smallholder Workshop.  While membership fee is waived to smallholder member, funding to participate the General Assembly in March 2020 in Singapore is limited to 20 seats. The Working Group will further look at the profile of the smallholders  to design the criteria for funding mechanism.

GPSNR Staff December 26, 2019
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