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: September 2021

What an interesting month has passed us by! As we step closer to the General Assembly of 2021, here’s what the working groups have on their plate:

Strategy and Objectives Working Group

After conducting 2 sessions of the Theory of Change (ToC) Workshop this month, the Strategy and Objectives working group will soon finalise the ToC document and potentially identify new strategies for GPSNR.

Smallholder Representation Working Group

After two successful smallholder onboarding workshops for smallholders from Indonesia and Cambodia, the working group is formally incorporating new smallholders from the two countries as GPSNR members. The group is also conducting onboarding workshops for India at the end of September and Sri Lanka and Thailand in October. 

At the same time, they are developing workshops to onboard more smallholders from Vietnam, Thailand, Ivory Coast, and Ghana and organizing the third Smallholders International Call next month. 

Policy Toolbox Working Group

As the General Assembly of 2021 comes closer, the group is continuing to develop the Implementation Guidance, Reporting Requirements and Compliance Panel Guidance. 

Capacity Building Working Group

As they develop key deliverables and milestones for Thailand National Subgroup and the Agroforestry Task Force, the Capacity Building Working Group is also busy with the Good Agricultural Practices (GAP), a system to monitor impacts of capacity building activities and implementation plans for Ivory Coast and Indonesia.

Traceability and Transparency Working Group

This working group has developed a Traceability Benchmark to support member uptake of traceability and provided draft input and received feedback for Implementation Guidance on traceability. They are now working on finalising the draft and conducting member consultations on the Benchmark. 

Shared Responsibility Working Group

The group is currently exploring and discussing detailed  solutions to identified root causes for each focus area of shared responsibility. It is also drafting activities and a framework for Shared Responsibility for integration into other processes such as the Implementation Guidance.

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GPSNR Working Groups Update: February 2022

All GPSNR working groups have a large chunk of work ahead of them. Here are all their updates: 

Strategy and Objectives Working Group

After completing the intensive task of publishing the Theory of Change, the strategy and objectives group is working on developing its own next steps based on this Theory of Change. In the same spirit, the group has also updated its own Terms of Reference and membership. It is now focused on developing the RFP for the Economic Risk Study, which will be published soon. Currently, they are developing GPSNR’s approach to managing and evaluating risk (commonly known as the risk-based approach in meetings!). 

Smallholder Representation Working Group

Apart from initiating outreach to smallholders with a view to organise onboarding workshops in countries such as Liberia, Ghana, Malaysia and Colombia, the group is focussed on its newly formed task force to develop the GPSNR Smallholders Policy Framework. The first meeting of this task force will be in March 2022. The group is also preparing for the first Smallholders International Call of the year in March 2022.

Policy Toolbox Working Group

This group has already recruited new members for three of its subgroups: Transparent reporting roadmap, Implementation Guidance and RR Guidance & Tools. In the coming months, they will be developing guidance for the reporting requirements and a transparency reporting roadmap before the reporting cycle begins in the middle of 2022. 

At the same time, the group continues to refine a major part of the assurance model: the Implementation Guidance, which it aims to have ready before the General Assembly of 2022. Additionally, this group is busy finalising the compliance panel’s operational guidance.

Capacity Building Working Group

As we begin a year of implementation in Thailand, this group is working on reviewing and finalising strategy and approach for Capacity Building in Thailand, including the integration with Agroforestry Task Force workstream based on discussions with the Rubber Authority of Thailand on 24 February 2022.

The working group is also continuing to develop and implement capacity building plans for Indonesia and Ivory Coast, and will soon appoint service providers for GAP Coaching in Indonesia

Traceability and Transparency Working Group

Having received members’ input on the traceability guidance, representatives from the working group are now finalizing the benchmark based on the feedback.

Shared Responsibility Working Group

The Shared Responsibility working group has completed the first draft of the Shared Responsibility (SR) framework, and has presented the same to the Executive Committee. The consultant is now working on incorporating feedback from the Executive Committee into this draft.

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