Why Natural Rubber Must be Kept in the EU’s Anti-Deforestation Law

Why Natural Rubber Must be Kept in the EU’s Anti-Deforestation Law

Mighty Earth is deeply concerned that natural rubber has been excluded from the European Commission’s forthcoming anti-deforestation law to tackle EU-driven deforestation and ecosystem loss. Due for release in December 2021, the EC’s proposed new supply chain anti-deforestation law will apply to a list of key Forest and Ecosystem Risk Commodities (FERCs) – which until recently was anticipated would cover key known forest-risk commodities[1], including natural rubber.

However, a leaked impact assessment [2] shows rubber is omitted from the latest list of commodities covered by the new EU law. Instead, the leaked impact assessment shows the EU law will only apply to beef, palm oil, soy, wood, cocoa and coffee.

We believe this would be a major omission and a huge set-back in the fight against deforestation, biodiversity loss, and climate change. The briefing sets out the reasons why failure to include rubber under the new law poses a serious and significant threat to millions of hectares of tropical forests, ecosystems and habitats in Southeast Asia, West Africa and beyond over the coming decade.

Rubber booms cause mass deforestation

Fuelled by a boom in market demand, rapid expansion of rubber production since 2000 has had a devastating impact on millions of hectares of rainforests and wildlife habitats, as well as the human rights of hundreds of local and Indigenous communities.

Recent studies found over five million hectares of tropical forest were cleared in Southeast Asia and sub-Saharan Africa for rubber plantations between 2003 and 2017.[3] Similarly, a 2018 study [4] for the European Commission attributes some three million hectares of forest loss in Southeast Asia – including Cambodia, Indonesia, Laos, Myanmar and Vietnam – directly to an increase in rubber cultivation since 2000.[5] In Cambodia, for example, over half a million hectares of tropical forest was cleared and replaced with rubber trees between 2001-2015 – accounting for 23% of Cambodia’s gross forest loss.[6]

To highlight the devastating impact of poorly regulated rubber expansion, groups like Greenpeace, Global Witness, Oakland Institute and Mighty Earth have documented harrowing evidence of widespread deforestation, forced evictions, illegal logging, livelihoods destruction, harassment, human rights abuses, and biodiversity loss linked to the expansion of rubber plantations in numerous tropical countries, including Cambodia, Cameroon, Laos, Papua New Guinea and Indonesia.

Rubber demand set to boom by a third by 2030

Most natural rubber is used in auto tyres (about 70% of the total), but rubber is used in thousands of ways, from engineering and industrial applications, to boots, mattresses, condoms and latex gloves. Following a lull over recent years and a sharp contraction under Covid-19, global demand for natural rubber will soon exceed pre-pandemic levels [7] and is forecast to jump by a third by 2030. Based on industry figures, the latest International Rubber Study Group (IRSG) forecasts show global natural rubber demand is set to boom by 33 percent by 2030 – up from 12.7 million tonnes in 2020 to 16.9 million tonnes in 2030.[8] Similarly, global consumption of natural rubber is forecast to jump by 28% over the decade to 2030.[9]

Major deforestation predicted

Alarmingly, academics say millions of hectares of forest clearances are predicted as rubber demand rises, and warn of severe biodiversity and major species losses – including increased extinction risks for a host of extinction-threatened amphibians, birds, mammals and reptiles.[10]

To give a sense of the scale of the threat posed to forests, ecosystems and biodiversity, experts estimated in 2015 that 4.3–-8.5 million hectares of additional rubber plantations were required to meet rising demand by 2024,[11] while industry estimates in 2018 found 2.5–3.9 million hectares of additional land area will be required to meet rising demand by 2027.[12]

While the bulk of the additional demand for natural rubber will go to booming Chinese and Asia-Pacific markets,[13] consumption in the EU is still highly significant (some 318 million auto tyres were produced in European plants last year)[14] and global forecasts show EU consumption of natural rubber for auto tyres is set to rise steadily by 12% over the decade to 2030 – up from 742,000 tonnes in 2020 to 834,000 tonnes in 2030.[15]

Rubber was always considered a FERC

The EC’s decision to drop rubber from the EU’s anti-deforestation law has no logical basis. Rapid expansion of rubber production in Southeast Asia and other tropical areas has long been identified by the EC and other key actors[16] as one of the top seven agricultural imports into the EU associated with deforestation and forest degradation.

As early as 2013, a major report [17] for the EC on imported deforestation identified rubber as an important contributor to deforestation, while a key follow-up study for the EC in 2018 [18] and a subsequent EC Communication report to the EU Parliament in 2019 included rubber alongside palm oil, meat, beef, soy, cocoa, coffee, maize and timber as key agricultural imports into the EU associated with deforestation and forest degradation.[19]

Most importantly, the European Parliament passed a Resolution [20] on 22 October 2020 which recommended the European Commission draw up a legal proposal to tackle imported deforestation and instructed the EC that the proposal should cover all commodities that are most frequently associated with deforestation, degradation of natural forests and conversion and degradation of natural ecosystems.[21]Significantly, the Resolution instructed the EC that the list of commodities covered by the law should “comprise at least palm oil soy, meat, leather, cocoa, coffee, rubber and maize.” [22]

Restore rubber to EU anti-deforestation law

The EU plays an absolutely central role in the global tyre and rubber supply chain. Seven out of ten of the top global tyre and rubber corporations have their headquarters or key tyre plants based in Europe – including Bridgestone, Continental, Goodyear, Hankook, Michelin, Pirelli and Sumitomo. [23] With global rubber demand set to boom by a third by 2030, the threat of millions of hectares of rubber-related deforestation and degradation of carbon-rich ecosystems is real, and extremely urgent. That’s why we’re urging the EU to restore rubber to the EU’s anti-deforestation law and pressing the EU to act now to help drive out deforestation and human rights abuses from global rubber supply chains and consumer markets.

[1] European Commission (2019) Communication from The Commission to the European Parliament, The Council, The European Economic and Social Committee and the Committee of the Regions, Stepping up EU Action to Protect and Restore the World’s Forests, 23 July 2019

[2] “Leaked EU anti-deforestation law omits fragile grasslands and wetlands’, The Guardian, 14 September 2021, Jennifer Rankin

[3] Wang M H et al (2020) Reconciling Rubber Expansion with Biodiversity Conservation, Current Biology 30, 3825-3832, 5 October 2020

[4] COWI (2018) Feasibility study on options to step up EU action against deforestation, Final Report, COWI A/S, Denmark

[5] COWI (2018) Feasibility study on options to step up EU action against deforestation, Final Report, COWI A/S, Denmark

[6] Grogan K et al (2019) Unravelling the link between global rubber price and tropical deforestation in Cambodia, Nature Plants, Vol 5, January 2019, 47-53

[7] IRSG (2021) World Rubber Industry Outlook: Review and Prospects, July 2021, International Rubber Study Group: Singapore

[8] IRSG (2021) World Rubber Industry Outlook: Review and Prospects, July 2021, IRSG: Singapore

[9] IRSG (2021) World Rubber Industry Outlook: Review and Prospects, July 2021, IRSG: Singapore

[10] Wang M H et al (2020) Reconciling Rubber Expansion with Biodiversity Conservation, Current Biology 30, 3825-3832, 5 October 2020

[11] Warren-Thomas E et al (2015) Increasing Demand for Natural Rubber Necessitates a Robust Sustainability Initiative to Mitigate Impacts on Tropical Biodiversity, Conservation Letters, July/August 2015, 8(4), 230-241

[12] IRSG (2018) World Rubber Industry Outlook: Review and Prospects to 2027, June 2018, IRSG: Singapore

[13] IRSG (2021) World Rubber Industry Outlook: Review and Prospects, July 2021, IRSG: Singapore

[14] ETRMA (2020) The European Tyre Industry Facts and Figures 2020 Edition, European Tyre & Rubber Manufacturers’ Association (ETRMA): Brussels

[15] IRSG (2021) World Rubber Industry Outlook: Review and Prospects, July 2021, IRSG: Singapore

[16] See: WWF (2021) Deforestation Fronts, Drivers and Responses in a Changing World, WWF: Gland, Switzerland; WRI (2020) Estimating the Role of Seven Commodities in Agriculture-linked Deforestation: Oil palm, Soy, Cattle, Wood Fiber, Cococa, and Rubber, Technical Note, October 2020, World Resources Institute: Washington DC, United States

[17] EC (2013) The impact of EU consumption on deforestation: Comprehensive analysis of the impact of EU consumption on deforestation, Final Report, Technical Report 2013, 063, European Commission, DG Environment: Brussels

[18] COWI (2018) Feasibility study on options to step up EU action against deforestation, Final Report, COWI A/S, Denmark

[19] European Commission (2019) Communication from The Commission to the European Parliament, The Council, The European Economic and Social Committee and the Committee of the Regions, Stepping up EU Action to Protect and Restore the World’s Forests, 23 July 2019

[20] European Parliament resolution of 22 October 2020 with recommendations to the Commission on an EU legal framework to halt and reverse EU-driven global deforestation 2020/2006(INL), see: https://bit.ly/2YLl5pV

[21] European Parliament resolution of 22 October 2020 with recommendations to the Commission on an EU legal framework to halt and reverse EU-driven global deforestation 2020/2006(INL), see: https://bit.ly/2YLl5pV

[22] European Parliament resolution of 22 October 2020 with recommendations to the Commission on an EU legal framework to halt and reverse EU-driven global deforestation 2020/2006(INL), see: https://bit.ly/2YLl5pV

[23] ETRMA (2019) European Tyre & Rubber Industry Statistics, Edition 2019, ETRMA: Brussels