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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Secretariat Update – January 2020

We can draw parallels to the coffee industry, which similarly comprises small plantation owners and more profitable downstream actors. In his recent sustainability report on the coffee industry, economist Jeffrey Sachs’ proposal for a global fund to fill the financial gaps for sustainability investments in coffee producing regions garnered vivid discussion.  

Currently, low and unpredictable rubber prices are a constraint to smallholders who produce the bulk of global rubber output. Transparency is critical in the purchasing process, and this kind of disruption typically comes hand in hand with embracing new strategies. 

Under the purview of the Strategy & Objectives Working Group, capacity building and extension services have been identified as potential measures to mitigate the root causes of the social and environmental impact from the natural rubber supply market. Implementing these at scale for the whole industry will require considerable financial investment.   

With the above considerations in mind, GPSNR is exploring new approaches to funding that would not be borne by a single segment of the industry, but in a manner incorporating the spirit of our shared responsibility. 

Enterprise Singapore organized an industry meeting on 14 January 2020, and invited GPSNR and Singapore Exchange to better understand the available options of an e-trading platform that could contribute to our funds. The meeting also discussed what could be the options, through GPSNR, to increase the uptake of the e-trading platform.

Tapping the vast potential of digitalization could present an exciting avenue of possibilities for GPSNR to better advance our vision of a fair, equitable and environmentally sound rubber value chain.      

The meeting was initiated by representatives from Enterprise Singapore, and panel speakers comprised representatives from GPSNR, Singapore Exchange and HeveaConnect. Participants included GPSNR members as well as other Natural Rubber buyers, producers, processors and traders .

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GPSNR Working Groups Update: November 2023

Strategy and Objectives Working Group: Following the approval of the Assurance Model resolution (5b), the Assurance Model Task Force is working with ASI in developing the Assurance Model including aligning with current normative documents, engaging members for consultation, and pilot testing.

In parallel, the Risk Subgroup hosted a webinar focused on traceability and shared findings from their traceability pilot projects. 

The Risk subgroup has decided to temporarily pause its activities until December, allowing time for ASI to complete the Assurance Model alignment. ASI has commenced its task of aligning key GPSNR documents. These documents aim to lay a solid foundation for the complete Assurance Model. Upon the completion of this alignment process, the fully drafted Assurance Model will be presented to the members for consideration and approval.

Smallholders Representation and Capacity Building (SCB) Working Group: The Indonesian subgroup presented their quarterly reports for two GAP Coaching projects and one Disease Fighting project on October 27, 2023. In addition, GPSNR secured a joint collaboration letter with RAOT and invited all member companies to participate in the Thailand GAP coaching project in Bueng Kan and Chiang Rai provinces. The Thailand agroforestry project also received additional funding for further sub-projects.

The Digital Knowledge Sharing Platform (KSP) task force conducted a pilot user acceptance test and initiated socialisation sessions and training for smallholder farmers in Indonesia. They also announced a Request for Proposal (RFP) for KSP’s third phase, focusing on content development, with submissions due by November 24, 2023.

Rubber agroforestry workshops were held in Côte d’Ivoire from October 25-27, 2023, and information on capacity-building projects open for funding was shared with all members. The SCB WG will continue to oversee all ongoing projects, with efforts to plan logistics for smallholder representatives attending events in Thailand and France. The Thailand agroforestry subgroup is working on a supplemental agreement for additional projects.

Members interested in the Thailand GAP project in Chiang Rai and Bueng Kan are encouraged to contact cheewei@gpsnr.org for more information. The KSP task force plans to continue socialisation sessions and training in Indonesia and Thailand, aiming for the final user acceptance test by the end of November 2023. By the end of November, the task force will begin evaluating proposals for KSP’s third phase.

The Income Diversification and Rubber Agroforestry task force is preparing for its second Indonesian agroforestry workshop of 2023, scheduled for November 22-24. Additionally, a webinar is planned for November 30, 2023, to present findings from the HCSA-HCVN field trial.

Policy Toolbox Working Group: On November 22nd, WG1 met to discuss the  quantification of the RR, data aggregation methodologies, and updates relating to the RR in the context of the Assurance Model. During the meeting, operational timelines and survey to gather information were set up.

Currently, Agridence is developing the digital platform, and the Secretariat plans to provide updates on the RR to ensure the platform is operational before the 2024 reporting cycle.

WG1 is also working on revising the Code of Conduct to include non-conformance measures for failing to update the Reporting Requirements, in line with the non-conformance measures approved by the Executive Committee in 2022.

Lastly, following the approval of the revised reporting requirements, the WG will proceed to develop the disclosure requirements for the Year 3 reporting cycle.

Shared Responsibility Working Group: The Assurance Model will be meeting with ASI to provide feedback on the proposed Assurance Model under development. Additionally, the Working Group has an open co-chair seat and is calling for volunteers to fill this position.

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