Statement by the Global Platform for Sustainable Natural Rubber on Proposed new EU Deforestation Regulation

The Member Consultation period for the proposed GPSNR Policy Components and Baseline Reporting Requirements closed on 3 July 2020. All comments received as part of the consultation exercise were discussed by the Policy Toolbox Working Group over several rounds of calls. There has also been healthy dialogue between various membership categories and the Working Group on the alignment of the Policy Components. 

Meanwhile, pilot testing for the Baseline Reporting Requirements is in progress, with 10 GPSNR member volunteers participating in the exercise. The Secretariat will be interviewing each of the volunteers in the coming weeks to gather feedback on their experience in submitting the Baseline Reporting Requirements data. More updates will be shared in due course.

At this stage, finalized versions of the Policy Components and related documents have been submitted by the Policy Toolbox Working Group to the Executive Committee for review and further discussion at the Executive Committee level. The Policy Components will then be brought to the GPSNR General Assembly for voting.

The formulation of Policy Components is a critical piece in fulfilling GPSNR’s vision of a fair, equitable and environmentally sound natural rubber value chain. 

All GPSNR members, at the time of joining the Platform, committed to this very vision, as well as 12 principles of sustainable natural rubber as defined by GPSNR. The Policy Components were developed to provide more specificity to the 12 Sustainable Natural Rubber Principles. Within the proposed Policy Components are key commitment details to no deforestation/ conversion/ degradation, upholding human rights, supply chain transparency and monitoring and reporting. 

If approved, the Policy Components will act as a clear and guiding framework for GPSNR company members to establish or update supply chain commitments through their natural rubber purchasing policies. 

Adopting a policy allows a company to signal that the issues covered by the policy are important to the company, and that resources and capacities will be dedicated to addressing the issues in order to comply with the policy. Policies, while illuminating the goals that a company is working towards, also enables these commitments to be channelled upstream to suppliers and downstream to buyers, with the potential to transform the entire supply chain.

Following the Policy Toolbox Working Group’s observation that common questions and concerns were raised by GPSNR members during the Members Consultation period, the Working Group has developed a supplementary FAQ document to provide detailed responses to address these concerns, in a bid to provide greater clarity on the Policy Components. These will be circulated to the GPSNR membership in August, along with all other proposed resolutions.

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

Strategy and Objectives Working Group

The group has made good progress by establishing the new risk task force that will evaluate the exact scope of GPSNR’s risk based approach. It has also got its new Terms of Reference approved by the Executive Committee, and is now working on contracting a consultant for the Economic Risk Study and conducting a gap analysis of GPSNR’s current activities based on the platform’s Theory of Change.

Smallholder Representation Working Group

Having published the RFP to develop the GPSNR Smallholders Policy Framework equivalent, the group is focussing on the first Smallholders International Call of the year in March 2022, workshops in Liberia and Malaysia, and on developing country-specific smallholder engagement activities with smallholders and Country Champions.

Policy Toolbox Working Group

This group is continuing discussions among its three new subgroups: Transparent reporting roadmap, Implementation Guidance and RR Guidance & Tools. In the coming months, they will finalize guidance for the reporting requirements and share it with companies

At the same time, they are working with the smallholder representation working group on the Smallholder Policy Framework equivalent.

Capacity Building Working Group

After publishing the GAPs as living documents in English and Bahasa and selecting SNV-Proforest and Koltiva as consultants to work on the GAPs coaching in Indonesia, the working group continues to develop capacity building plans for Indonesia, Thailand and Ivory Coast.

They are also seeking your inputs for GPSNR’s knowledge sharing platform, which you can provide here.

Traceability and Transparency Working Group

Having finalized the traceability and transparency primer, the WG will wind down its operations.

Shared Responsibility Working Group

The Shared Responsibility has completed a review of the Shared Responsibility Framework, incorporating feedback from the Executive Committee. The Working Group will present an updated proposal to the EC as the next step, with a view to prepare a resolution at the 2022 General Assembly.