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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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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It’s a Wrap: GPSNR’s Fourth Smallholder International Call

Although it had been more than a month since the GPSNR smallholder members had met at the international level, they took their places in the online meeting with a sense of familiarity that was heartening to see. 

We had come a long way since the first international call in late August. Since then, the second and third international calls had taken place, focusing on preparing the smallholders for the General Assembly. In the weeks after the General Assembly, the Country Champions helped to organise national-level calls for the smallholders to recap the results of the resolutions and Executive Committee (EC) elections, and to discuss topics of interest to be brought up during the fourth and final international call as part of the series.

The fourth international call was held in the evening of 22 October, and attended by smallholder members from all seven countries. The call began with an update from the three smallholder EC representatives on the EC calls that they had attended thus far. Overall, the representatives had positive takeaways from the EC meetings, despite some language barriers remaining. 

Next, the Co-Chairs of GPSNR’s various Working Groups joined the call in order to introduce each of their Working Groups and briefly explain key focuses and projects. This generated some questions around the policy equivalent for smallholder members, as well as GPSNR’s approach towards traceability for smallholder producers. Several smallholder members also expressed interest in participating in these Working Groups. The Secretariat will get in touch with all smallholders members to facilitate their inclusion in the platform’s Working Groups.

The final half hour of the call was dedicated to a discussion on smallholder community dynamics and how to manage the exchange of information within the category while understanding the geographical and linguistic differences amongst the clusters of smallholder members. 

This concludes the series of preparatory calls designed by the Smallholder Representation Working Group to prepare smallholders for their first GPSNR General Assembly and outcomes. But as the saying goes: when one door closes, another opens. And in this case, the door has opened for the newest membership category to define the parameters and mechanisms of their involvement within the platform, with the support of the Secretariat and fellow GPSNR members.

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