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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Presentation on the High Conservation Value Approach (Members Version)

In discussing the proposed member requirements and reporting requirements, the Policy Toolbox Working Group has touched frequently upon the topics of High Conservation Value (HCV), no deforestation, no conversion of non-forested ecosystem, and other issues around developments on post-disturbance vegetation/ land cover. 

To establish a common understanding about HCVs, the High Conservation Value Resource Network (HCVRN) Secretariat took the initiative to organize a video presentation to the Working Group members on the HCV Approach. The presentation touched on governance and historical aspects of the HCV Approach, and its implementation in forest and non-forest ecosystems in the landscape, concession and smallholder contexts.

Watch the presentation here.

Download the slide deck here.

GPSNR Staff May 26, 2020

Rubber, representation and reform – What smallholders bring to the sustainability conversation

By Febrius Wibisana, GPSNR Executive Committee Member & Co-Chair, GPSNR Smallholder Inclusion Working Group

For those who do not know me yet, my name is Febrius Wibisana and I have been a rubber smallholder in Indonesia for over 25 years. At GPSNR, I represent the smallholder category at the Executive Committee level. I am also the co-chair of the Smallholders Representation working group.

In June 2022, I was invited by the Partnership for Forests or P4F to the P4F Forum with their partners and projects from across the world. They wanted me to speak about my experience at GPSNR on smallholder inclusion in the sustainability conversation in natural rubber. The experience gave me the opportunity to put some thought into our work over the last three years – the challenges, the successes and carving the path forward.

I am writing this to share some of those reflections with my fellow GPSNR members.

Reflection 1: It is impossible to have holistic sustainability solutions in natural rubber without smallholder participation

GPSNR Impacts & Assurance Associate Si Yuan and myself at the P4F Forum in London

We live in a world where 6 million smallholder farmers produce almost 90% of the world’s natural rubber. In such a world, any conversation on change in this supply chain has to include smallholders. 

In its second General Assembly in 2020, GPSNR members passed a resolution to include smallholders as a category within the membership. We started with 28 odd smallholders, including myself, engaging in conversations on sustainability, capacity building and the meaning of true inclusion and having the smallholder voice heard at various decision making levels. Today, I represent over 130 smallholders across 10 countries in the GPSNR Executive Committee. 

To bring smallholders into each conversation, we work closely with country level champions and local government entities for outreach and engagement. Interpretation facilities and key documents being translated to smallholder languages are some small but significant steps we take at GPSNR to further facilitate smallholder participation.

Reflection 2: Membership does not guarantee active participation

While many of our smallholder members are actively engaged in core decision making and at the working group level, many find it difficult to do so. The digital divide, language barriers and a skewed equation of structural power could be some key reasons for this. Some smallholders simply may not have the time for it. 

Yet, as we embark on transforming the entire supply chain, we need active smallholder voices to join and remain in the GPSNR fold. To this end, the smallholder representation working group has put forward a resolution with proposed changes in smallholder membership structure, where smallholders will have to participate in the General Assembly to take up ordinary membership. All others will be classified as affiliate members by default. You can take a look at the resolution here. 

Reflection 3: Making a supply chain sustainable requires thorough capacity building at all levels

There are more than 2 million smallholders in Indonesia. Yet, despite being the largest producer, it has the lowest productivity in the world. This is because of diseases and poor planting materials. Many other rubber producing nations face similar problems. 

If we are to make this supply chain sustainable, equitable and fair, and achieve the desired state that the GPSNR Theory of Change spells out, smallholders have to be equipped with the skills and resources. The capacity building working group has already kicked-off the first such projects in Indonesia with SNV-Proforest and Koltiva. GPSNR has also received funding pledges from Renault, Goodyear, Michelin and Pirelli for other projects, but scaling them requires more. Funding information is available here for any one in the natural rubber industry. 

Capacity building will also equip smallholders to participate further in GPSNR decision making and other processes. 

As we move forward, I am energised by the progress GPSNR has made so far on smallholder participation. In our attempt to move towards more active engagement, we need the support of all our members. Our ability to meet in person will further strengthen this support, and I look forward to working with all of you to transform the supply chain. 

GPSNR Secretariat June 27, 2022
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