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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Updates on the GPSNR Baseline Reporting Requirements Pilot Test

In early June 2020, GPSNR member companies were invited to participate in pilot testing a set of draft Baseline Reporting Requirements developed by the Policy Toolbox and Implementation Guidance Working Group. Along with the newly approved Policy Components, the Baseline Reporting Requirements will constitute a key requirement for GPSNR membership. 

“By having robust reporting requirements and a system to transparently report on progress, GPSNR member companies will be able to demonstrate leadership, monitor and further the effective implementation of their sustainability commitments, and ultimately drive positive impacts in the natural rubber value chain,” explained Amy Smith, Policy Toolbox Working Group Co-Chair.

The Working Group proposed pilot testing the Baseline Reporting Requirements with a group of volunteer member companies to better understand any constraints companies may have in obtaining and sharing certain information. The goal of the pilot was to refine and finalize the Baseline Reporting Requirements based on company feedback.

“In addition to pilot testing with member volunteers, we will also be assessing and evaluating the potential of existing certification schemes and reporting systems to adopt as part of GPSNR reporting requirements,” added Policy Toolbox Working Group Co-Chair, Pierre Bois d’Enghien. “This evaluation, together with the feedback we received from the pilot, will help us build a reporting system that is credible and useful for all stakeholders.” 

We are pleased to announce that a total of 11 GPSNR members volunteered for the pilot test. These members, who include Continental AG, Ford Motor Company, Halcyon Agri Corporation Limited, Hevea-Tec Indústria e Comércio LTDA, Industrias de Exportacion Universal, S.A., ITOCHU Corporation, Michelin, SIPH, Socfin SA, Sumitomo Rubber Industries Ltd, and The Yokohama Rubber Co., Ltd., represent all the membership categories to which the Baseline Reporting Requirements would apply. 

In mid-July, the reporting platform was opened to the pilot participants, who were given three weeks to submit the required data. Concurrently, the Secretariat conducted one-on-one interviews with the participants to gather feedback about their experience using the baseline reporting platform as well as their suggestions on ways to improve the process. 

“Our volunteer member companies were instrumental in helping to refine the Baseline Reporting Requirements and ensuring that the platform’s reporting mechanisms are relevant and meaningful for all our members,” said GPSNR Director Stefano Savi. “This improvement will help us achieve our shared objectives of ensuring a sustainable and equitable natural rubber supply chain.”

Following the approval of the policy requirements at the General Assembly in September, the Policy Toolbox Working Group will review the compiled company feedback from the pilot and the member consultation process conducted earlier this year, and will refine and finalize the Baseline Reporting Requirements for Executive Committee approval by the end of 2020. Once the Executive Committee has approved these requirements, ordinary company members will submit their baseline reporting data for 2020 to GPSNR in Q1 of 2021.

The Baseline Reporting Requirements will enable GPSNR to understand what its member companies currently know about their natural rubber supply chains, and what they are doing to move towards sustainable practices. Having a rigorous and transparent reporting process in place will strengthen the credibility of GPSNR and contribute to the development of a robust Assurance system for the platform.

GPSNR Staff November 25, 2020

Empowering Smallholder Farmers: The Path to Deforestation-Free Rubber Supply Chains to Meet the EUDR

On Wednesday, 19 April 2023, the European Union approved the upcoming Deforestation-Free Regulation (EUDR) to prevent companies from placing products linked to deforestation onto the EU market. As part of the wider vision of the EU Green Deal, it will demand companies who import rubber or rubber-based products (e.g., tires) to verify that their supply chain is deforestation-free. It’s a push towards an era of environmental accountability, yet it also sparks debates about the path forward for the rubber industry.

The EUDR requires companies to have traceability to the farm level, including geo-location data and proof of land legality. According to the regulation, every plot below 4 hectares requires at least a GPS point coordinate, while plots above 4 hectares must have a polygon.

Fulfilling these traceability requirements is no small feat. There is concern from the industry that smallholder farmers may be unintentionally excluded from global sustainable supply chains. Ensuring smallholder farmer inclusion requires a holistic sustainability approach.  There is no doubt that the rubber industry has begun moving towards sustainable rubber sourcing through combined industry efforts like the Global Platform for Sustainable Natural Rubber (GPSNR). However, the reality is that most imported rubber to the EU currently does not meet the regulatory requirements as the industry lacks traceability to the farm level. As 85% of the global natural rubber supply is supplied by approximately 6 million smallholder farmers, the implications of this regulation could be far-reaching and severe, particularly for these smallholder farmers.

However, there is a lot of hope.

Firstly, even though it might seem challenging, traceability to the farm level is doable – even for the rubber industry. This has been demonstrated in a GPSNR-funded farmer training and coaching project primarily focused on supporting smallholders to apply Good Agriculture Practices (GAP). Koltiva, the company I am working for and who was selected to be the implementing partner for this project, has mapped more than 4,000 farmers and their farms to help them to prepare for the EUDR in less than a year.

Secondly, we believe that traceability to the farm is scalable. In our work with clients in 51 countries, we were able to map almost 1 million smallholder farmers through our KoltiTrace platform. Platforms such as KoltiTrace allow companies to map and verify their supply chain, including transaction traceability from Seed to Tire and deforestation-free analysis.

Finally, EUDR could have a long-term positive impact on smallholder farmers. Currently, many rubber farmers do not have proper land titles. Due to the EUDR geolocation requirements, many smallholders will, for the first time, have access to a map of their own plantation, allowing them to legalize their land.

And it doesn’t stop there. Smallholders have largely been invisible in global supply chains. Traditional development programs have tried to engage them, but they have not reached the expected results. Many smallholders still have no access to knowledge, no access to capital,  and soon will also be excluded from the carbon economy.

I believe that it’s possible to bridge these gaps. Traceability to farm level and digitalizing the first mile of agricultural value chains can lay the foundation for holistic sustainability interventions. Enabled by technology and data, the sector can equip farmers with critical knowledge, improve their access to finance, actively support farmers to apply low-carbon practices and enable them to reap the benefits of the growing carbon economy.

While traceability cannot be achieved overnight, the rubber industry is in a unique position. At GPSNR, the major industry players are sitting at one table. Through combined efforts and data-sharing agreements of shared supplier data, the rubber industry can become a leading example of how to meet the EUDR.


About the Author:
Luca Fischer is Koltiva’s Program Manager, leading Koltiva’s boots-on-the-ground implementation projects in the rubber sector globally. He bridges the gap between the client, product, and field teams.

Luca has over five years of work experience in sustainable sourcing, smallholder livelihood, and climate-smart agriculture development. He graduated with an M.Sc. in Sustainable Resource Management from the Technical University of Munich, Germany.

About Koltiva (click here for more information)
Established in 2013, Koltiva is a leading agritech company for enterprises to make their global supply chains traceable, inclusive, and climate-smart. Backed by Koltiva’s human-centered technology with boots-on-the-ground professional service, Koltiva supports some of the largest multinational companies by digitizing and verifying global supply chains, focusing on enhancing traceability, inclusiveness, and sustainability. Koltiva combines triple-tech (AgriTech, FinTech, and ClimaTech) to improve producers’ outcomes and profitability while building more sustainable supply chains.

GPSNR Secretariat July 4, 2023
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