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: July 2022

Start here for a full update on the working groups since the July 2022 General Assembly!

Strategy and Objectives Working Group

The Executive Committee (EC) approved the creation of the Assurance Model Task Force, which will look into finalizing GPSNR’s Assurance Model design by the end of this year. Members interested to join the Task Force should look out for a call-for-participation that should be sent out soon. The Risk subgroup also received feedback from the EC on its plans and will discuss the feedback while continuing to refine GPSNR’s risk-based approach.

Smallholder Representation Working Group

In July 2022, the Smallholders WG began discussions on the following developments: Smallholders Policy-equivalent Framework with HCVN; ‘Intro to Agroforestry’ pilot workshops with CIRAD and Dr Maria Wang; and HCSA Toolkit field trials with HCSA. Preparations are also being made for an onboarding workshop for smallholders in Malaysia to be held in the first week of August!

Policy Toolbox Working Group

On updates for the Policy Toolbox Working Group, the Implementation Guidance was approved by the General Assembly and the latest version of the guidance is available here. The guidance will continue to be updated regularly, starting with updates for section 7.1 and 7.2 for all categories. The Reporting Requirements process has also started and the Secretariat is processing the responses from the PPT category.

Capacity Building Working Group

The Capacity Building WG is currently reviewing proposals for the Comprehensive Disease Fighting Approach in Indonesia, and will formalize a decision in August 2022. Projects in Indonesia, Thailand and Cote d’Ivoire are also being advanced, with concrete developments expected to be shared in August. 

Shared Responsibility Working Group

The working group is putting forward the plans to implement the shared responsibility framework, which was recently approved by the General Assembly. 

Members

GPSNR Company Self Assessment Form: Aligning Your Company’s Policy with the GPSNR Policy Framework

The Policy Framework was approved and adopted via a membership vote at the 2nd GPSNR General Assembly on 23 September. As part of the resolution, companies were given 6 months to align their public policies to include all the components of GPSNR’s Policy Framework, with the possibility of two extensions if evidence of progress is shown. Based on this timeline, companies will have until 23 March 2021 to submit their public policies for evaluation by GPSNR’s Compliance Panel. Full instructions on how companies should submit their public policies and other public documents will be provided in early 2021. 

The Self Assessment Form is a tool designed to help companies evaluate and track the degree of alignment between their public policies and other public documents and GPSNR’s Policy Framework. Conducting a self-assessment using this form does not constitute GPSNR approval of a company’s policies, and companies should avoid making public claims about approval of the policies before final assessment by GPSNR. Compliance with this requirement can only be confirmed by the GPSNR Compliance Panel and this will only be possible after member companies submit to GPSNR their policies or other public documents that reflect conformance with GPSNR’s Policy Framework in March 2021.

A summary timeline of the company policy approval process is depicted below:

Compliance Panel

In early 2021, the Policy Toolbox and Implementation Guidance Working Group will share the terms of reference for the three members of the Compliance Panel. GPSNR members will then be invited to nominate individuals to serve on the Compliance Panel. An Extra-ordinary General Assembly will be called in February 2021 for GPSNR members to vote on the candidates and three candidates will be voted to form the Compliance Panel. The panel will then assess the policies submitted by GPSNR member companies and determine if they are in compliance with GPSNR’s Policy Framework. More details on this will be shared with members once they are available.

Click here to download the GPSNR Company Self Assessment Form

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Step 1: Commitment and Reporting