Rubber

Industry Takes Another Step Towards Assuring Sustainable Natural Rubber 

Industry Takes Another Step Towards Assuring Sustainable Natural Rubber 

December 14, 2021 

Members of the multi-stakeholder Global Platform for Sustainable Natural Rubber (GPSNR) today took another important step towards ensuring the production, processing and consumption of natural rubber does not contribute to the destruction of tropical forests, land grabbing or human rights abuses. 

Following from 2020’s vote by GPSNR members – such as Michelin, Bridgestone, Continental and Pirelli – to introduce comprehensive sustainability policy requirements for rubber companies, today saw overwhelming support for a resolution in favor of new reporting requirements, which will set high standards for how companies gather information and communicate on the delivery of their policy commitments. Like the policy components, the reporting requirements cover issues such as ensuring zero deforestation, protecting critical natural habitats and freshwater resources, anti-bribery and corruption, respecting land rights, and upholding human and labor rights within members’ natural rubber operations and supply chains. 

Commenting on the successful outcome of the vote at the GPSNR Annual Assembly, Mighty Earth’s Senior Director for Rubber, Dr Julian Oram, stated: “Today marks a significant advancement in our efforts to transform the global rubber industry, and reflects a huge effort by both CSOs and industry members of the Working Group that designed these reporting requirements. It should provide a crucial springboard for developing a convincing model of sustainability assurance and monitoring in the rubber sector going forward.” 

GPSNR was co-founded in 2019 by Mighty Earth and several other CSOs, along with a small number of rubber producer/ processors, tire companies, and auto manufacturers. Its mission is to deliver improvements in the socioeconomic and environmental performance of the natural rubber value chain. Over the past twelve months, GPSNR’s membership has grown from 92 to 156 members, including 39 new smallholder farmer representatives from nine rubber producing countries. 

While encouraging, this latest step remains just that – a small step. Thus far GPSNR has registered some notable successes, such as the widespread adoption of sustainable rubber policies, the establishment of a Grievance Mechanism with teeth, the inclusion of smallholder representatives as equal stakeholders in GPSNR’s governance, the development of tools for rubber supply chain traceability, and the establishment of national groups to undertake concrete capacity building initiatives on sustainable natural rubber, including agroforestry. 

Nonetheless, the ultimate success of the initiative still hangs in the balance. GPSNR has yet to develop an assurance model to robustly assess members’ compliance with their obligations, or gauge how the Platform is adding value to local efforts to boost sustainability at the farm level. There is also much work to do in developing a shared responsibility model that delivers greater equity and “benefit-sharing” across rubber value chains; including ensuring smallholder growers are fairly rewarded for sustainability improvements on their farms. At a more fundamental level, there is still a great deal of resistance amongst industry participants to embrace full supply chain transparency – a crucial prerequisite in being able to understand where problems persist in rubber-growing regions.  

Dr Oram cautioned, “The coming twelve months will determine whether the promising groundwork laid at the GPSNR to date ultimately bears fruit in the form of a truly effective self-regulating and self-monitoring industry that improves the livelihoods of rubber smallholders and workers, whilst protecting tropical forests and wildlife habitats. Watch this space!” 


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

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

 

Read the full Mighty Earth report on the EU’s anti-deforestation law

Mighty Earth is gravely concerned that rubber has been excluded from the European Commission’s proposed new anti-deforestation legislation to tackle EU-driven deforestation – and joins civil society and Indigenous peoples’ groups calling for rubber to be restored to the EU’s flagship law designed to eradicate deforestation from its global commodity supply chains. Due for release on 17 November 2021, the EU’s new anti-deforestation law will apply to 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 European Commission Impact Assessment [2] shows rubber has been dropped from the list of commodities covered by the forthcoming legislation. Instead, the new law will only apply to beef, palm oil, soy, wood, cocoa and coffee. The EC’s ssessment ranked rubber as responsible for the second lowest amount of embedded deforestation out of eight forest-risk commodities assessed, and concluded that including natural rubber in the legislation,

“…would require a very large effort, with little return in terms of curbing deforestation driven by EU consumption.”

Listed as one of the EU’s critical raw materials, the EU is a key actor in global rubber markets. The EU consumed an estimated 1.02 million tonnes of natural rubber for vehicle tires and non-tire use in 2020,[3] some 318 million auto tires were produced in European plants last year, [4] and three of the six largest global tyre and rubber corporations – Michelin, Continental and Pirelli – are based in the EU. With latest industry forecasts showing rubber demand is set to boom by a third by 2030,[5] this briefing sets out key reasons why failure to include rubber in the EU’s flagship anti-deforestation law poses a grave threat to millions of hectares of tropical forests and biodiversity in Southeast Asia, Africa and Latin America over the coming decade.

Working with a global rubber and deforestation expert, Mighty Earth analysed the dataset used in the EC Impact Assessment to quantify the embodied deforestation figures for rubber. We found that the dataset used by the European Commission only covers unprocessed natural rubber imports into the EU, and so misses large quantities of imports of processed rubber tires and other products, much of which may include embodied deforestation. We estimate embodied deforestation data for about two thirds of all natural rubber imports into the EU are potentially missing in the EC's impact assessment for rubber. In the light of this incomplete and flawed data, we believe the EC’s assessment may significantly underestimate the amount of potential deforestation embedded within natural rubber imports to the European Union.

We believe dropping rubber based on flawed deforestation data would be a major mistake and a huge set-back in the fight against deforestation, biodiversity loss and the achievement of the EU’s climate change goals.

1) Rubber booms cause mass deforestation and biodiversity loss

Fuelled by a boom in market demand, rapid expansion in rubber production since 2000 has had a devastating impact on millions of hectares of forests, ecosystems, habitats and biodiversity, as well as the human rights and livelihoods of hundreds of local and Indigenous communities.[6]

A study last year found over five million hectares of tropical forests were cleared across mainland Southeast Asia and sub-Saharan Africa for rubber plantations between 2003 and 2017.[7] Similarly, a 2018 study [8] for the European Commission attributes some three million hectares of forest loss in Southeast Asia alone – including in Cambodia, Indonesia, Laos, Myanmar, Thailand and Vietnam – directly to an increase in rubber cultivation since 2000.[9]  In one of the worst-hit countries, Cambodia, 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.[10]  Studies show much of the rubber now grown in Cambodia ends up in European auto tyres; an estimated 25% of the rubber land share harvested in Cambodia goes to produce tyres in the EU.[11]

To highlight the devastating impact of unrestrained rubber expansion, groups like Greenpeace, Global Witness, Oakland Institute, Inclusive Development International and Mighty Earth have documented harrowing evidence of widespread deforestation, land degradation, forced eviction, illegal logging, livelihood destruction, harassment, threats, intimidation, criminalisation, human rights abuses, and biodiversity and habitat loss linked to the expansion of monoculture rubber plantations in numerous tropical countries, including in Cambodia, Cameroon, Cote d’Ivoire, Laos, Myanmar, Papua New Guinea and Indonesia.

2) Rubber demand set for 33% boom by 2030

There is a lack of official, openly available data on most aspects related to natural rubber use and production. Currently operating within these constraints, academics find nearly three quarters of global rubber production is used to produce tyres,[12] however, rubber is also used in numerous other ways, from engineering and industrial applications, to boots, mats, condoms, apparel and latex gloves. Following a recent lull in expansion and a sharp contraction under Covid-19, global demand for natural rubber will soon exceed pre-pandemic levels[13] and is forecast to jump by a third by 2030.[14] Based on latest industry figures, the International Rubber Study Group (IRSG) forecasts global natural rubber demand is set to boom by 33% by 2030 – up from 12.7 million tonnes in 2020 to 16.9 million tonnes in 2030.[15] Similarly, IRSG figures show global consumption of natural rubber for tires and tire products is forecast to jump by 28% over the decade to 2030 – rising from 9,125,000 tonnes in 2020 to 11,720,000 tonnes in 2030.[16]

3) Mass deforestation, carbon emissions, biodiversity loss & species extinction predicted

Geographically restricted to growing Havea brasiliensis rubber trees in the tropics and within certain latitudes, smallholder farmers produce about 80% of the world’s rubber on about 12 million hectares of land – often competing for land and forests with other tropical crops such oil palm, cocoa or cassava.[17] With rubber yields not increasing,[18] scientists say meeting increased demand still requires more land area and will not be met by increased yields on existing planted rubber area.[19]

Alarmingly, leading rubber academic experts say millions of hectares of forest clearances are predicted as rubber demand rises and warn of associated damaging carbon emissions[20] and catastrophic biodiversity [21] and major species losses – including increased extinction risks for some 74 extinction-threatened mammals, birds, amphibians and reptiles – including threatened bats, frogs and forest shrews.[22]  Scientists estimate conversion of intact forest to rubber will generate carbon losses of 141.5 tC per ha in dense forest and 51.5 tC per ha in open forest, [23] and found conversion of lowland forest to rubber generates soil organic carbon emissions, too.[24]

To give a sense of the scale of the dire threat posed to forests, ecosystems and biodiversity, academics estimated in 2015 that 4.3–-8.5 million ha of additional rubber plantations were required to meet rising demand by 2024,[25] while industry estimates in 2018 found 2.5--3.9 million ha of additional land area will be required to meet rising demand by 2027.[26]

4) EU rubber consumption to grow 14% by 2030

While the bulk of the additional demand for natural rubber will go to booming Chinese and Asia-Pacific markets,[27] consumption in the EU is still highly significant. As the second largest rubber trading block to China, the EU consumes some 9% of the natural rubber produced globally. [28] Furthermore, the IRSG forecasts EU consumption of natural rubber is set to rise steadily by 14.5% over the decade to 2030 – rising from 1.023m tonnes in 2020 to 1.171m tonnes in 2030.[29]  A recent study demonstrates that mobility in the EU (for personal and goods transport) uses nearly a fifth of the annual harvest of natural rubber in several producer countries, contributing to the expansion of rubber plantations in the tropics.[30] The study finds car use is the main driver of natural rubber consumption in the EU and notes that car use is likely to increase with the economic development of eastern EU countries (see Fig.2).[31]

5) EU’s rubber land footprint set to grow

The EU’s global rubber land footprint is already large and is expected to grow. An estimated area of 594,000 ha is required to produce the natural rubber consumed annually through tire use in the EU,[32] corresponding to 5% of total global area harvested annually.[33] This land footprint is mainly located in Indonesia (32%), Thailand (23%), Malaysia (11%), Cote d’Ivoire (10%), and China (10%).

At the national level the share of land harvested to produce tires for use in the EU is particularly high in Cambodia (25%), while in Cote d’Ivoire (see Fig.4), Guinea and Cameroon, more than 15% of the area under mature rubber plantations serves European mobility (for passenger cars, trucks and vans).[34] While the primary hotspot for rubber expansion is Southeast Asia, scientists say similar trends are being observed in Africa.[35] Furthermore, the EU’s strategy to reduce its dependence on Southeast Asia[36] means that Africa is likely the new deforestation frontier. An estimated 25% of the natural rubber imported into Europe now originates from Africa,[37] and expansion could occur in climatically suitable but highly biodiverse new frontiers such as Guinea [38] or Central Africa, where foreign investment in industrial plantations is welcome, threatening vast areas of forested land that are not adequately protected by governments.[39]

6) Rubber was previously considered a FERC by the EC, and is still considered a FERC by the US and UK

The European Commission’s decision to drop rubber from the EU’s flagship anti-deforestation legislative proposal has little logical basis. Rapid expansion of rubber production in Southeast Asia and other tropical and sub-tropical areas has long been identified by the EC and other key actors [40] as one of the top seven agricultural imports into the EU associated with deforestation and forest degradation.

As early as 2013, a major report [41] for the European Commission on imported deforestation identified rubber as an important contributor to deforestation, while a key follow-up study for the EC in 2018 [42] 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.[43]

Most importantly, the European Parliament passed a Resolution[44] 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.[45] 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.” [46] Furthermore, other key countries that are currently drawing up similar supply chain anti-deforestation draft legislation, such as the US and UK, currently both include rubber as a key forest and ecosystem-risk commodities.

 7) Flawed deforestation data used in EC Impact Assessment

Mighty Earth has reviewed a copy of the leaked European Commission Impact Assessment and assessed the key research dataset with which the EC based their cost-benefit analysis to assess the share of embodied deforestation for a list of eight forest-risk commodities between 2008-2017 (see Fig.1).

Figure 1: Individual share of EU-embodied deforestation due to the eight pre-selected commodities between 2008-2017, Source: Pendrill F, Persson U M, Kastner T, 2020 (EC Impact Assessment, 2021)

The EC Impact Assessment cost-benefit analysis finds that rubber and maize contain the least amount of embodied deforestation out of the eight commodities (see Fig.2).

Figure 2: Cost-benefit analysis of commodities for the scope other than wood

Source: Pendrill F, Persson U M, Kastner T (2020) and own elaboration (EC Impact Assessment, 2021)

The EC Impact Assessment cost-benefit analysis concludes:

“Maize and rubber account for the smallest fraction of embodied deforestation among the commodities analysed, while their trade volumes are very large (around EUR 2.8 billion per year for maize and 17.6 billion for rubber). Including these two commodities in the scope would require a very large effort, with little return in terms of curbing deforestation driven by EU consumption.” 

However, having confirmed with a lead author [47]of the Pendrill et al (2020) [48] embodied deforestation dataset and research[49] – used in the EC Impact Assessment cost-benefit analysis – and taken advice from a global academic expert in natural rubber, deforestation and sustainability issues,[50] Mighty Earth’s considered position is that the Pendrill et al (2020) dataset [51] used by the EC for their analysis of embodied deforestation for natural rubber in particular has specific limitations that mean that they may significantly underestimate the amount of embodied deforestation for rubber imported into the EU.

The key flaw in the use of the Pendrill et al (2020) dataset [52] to assess embodied deforestation for rubber imported to the EU is that the dataset only assessed data from the FAOSTAT database relating to trade to the EU in unprocessed natural rubber. An author of the Pendrill et al dataset recently confirmed to Mighty Earth that “processed rubber imports are not included in our numbers.” [53] This confirmation is significant because it means that large quantities of processed new rubber tire products imported into the EU – which potentially contain large amounts of embodied deforestation – are left out entirely from the dataset and its use therefore may significantly underestimates the embodied deforestation risk for rubber in the EC’s key assessment.

A more recent and in-depth analysis of the rubber supply chain for tires into the EU from the same research group, drawing on FAOSTAT but also COMTRADE databases of processed rubber products, shows that very substantial shares of processed natural rubber produced in countries with expanding rubber area (Cote d’Ivoire, Thailand, Indonesia) are imported to the EU.[54] It is highly likely that a re-analysis by the EC of embodied deforestation in processed rubber products captured by the COMTRADE database would substantially increase embodied deforestation risk, and that this risk is particularly high in Africa where deforestation for agro-industrial plantations is actively encouraged, and where the EU seeks to increase its share of rubber imports from.

Mighty Earth recently searched the Eurostat database for both unprocessed rubber and processed rubber imports – including processed new tires, inner tubes, apparel, hygiene and pharmaceutical articles and vulcanised rubber – and found 5.9 million tonnes in total were imported into the EU in 2019, including 2.3 million tonnes of unprocessed natural rubber, as well as 1.2 million tonnes of processed new rubber tires, and 841,000 tonnes of processed rubber inner tubes, pharmaceutical articles, apparel, retreaded tires and vulcanised rubber products.[55] in short, we found the rubber-related data referred to in the EC assessment captures less than three quarters of gross natural rubber imported into the EU, and so may significantly underestimate the amount of embodied deforestation from all natural rubber coming into Europe. Dropping rubber from the EU’s anti-deforestation law on the basis of inaccurate or incomplete deforestation data for rubber seems entirely flawed and unscientific.

Conclusion: The European Commission should restore rubber to EU anti-deforestation law

The EU plays a central role in the global rubber and tire supply chain. Seven out of ten of the top global tire and rubber corporations have their headquarters or key rubber and tire plants in Europe – including industry giants such Bridgestone, Continental, Goodyear, Hankook, Michelin, Pirelli and Sumitomo. [56] With global rubber demand set to boom by a third by 2030 and steady growth in EU consumption forecast, the threat of millions of hectares of deforestation of biodiversity and carbon-rich forests and ecosystems over the coming years is real, and extremely urgent. That’s why we’re urging the EU to restore rubber to the EU’s flagship anti-deforestation law and pressing the EU to act now to do its part to eliminate deforestation and rights abuses from global rubber supply chains and consumer markets.

 Author:

Alex Wijeratna, Mighty Earth, Director of Special Projects


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

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

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

[6] Millard E (2019) Recent Experiences from the Natural Rubber Industry and its Movement Towards Sustainability, Sustainable global value chains, 1st ed. Ed. M. Schmidt, 499-520. Springer: New York

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

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

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

[10] 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

[11] Laroche P et al (2021) Assessing the contribution of mobility in the European Union to rubber expansion, Ambio, A Journal of the Human Environment, 12 June 2021

[12] Laroche P et al (2021) Assessing the contribution of mobility in the European Union to rubber expansion, Ambio, A Journal of the Human Environment, 12 June 2021

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

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

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

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

[17] Millard E (2019) Recent Experiences from the Natural Rubber Industry and its Movement Towards Sustainability, Sustainable global value chains, 1st ed. Ed. M Schmidt 499-520. Springer: New York

[18] FAOSTAT global natural rubber yield data, downloaded 6 October 2021

[19] Personal communication, Dr Eleanor Warren-Thomas, School of Natural Sciences, Bangor University, 6 October 2021

[20] Warren-Thomas E et al (2018) Protecting tropical forests from the rapid expansion of rubber using carbon payments, Nature Communications, Art. 911 (2018), 2 March 2018

[21] 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

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

[23] Warren-Thomas E et al (2018) Protecting tropical forests from the rapid expansion of rubber using carbon payments, Nature Communications, Art. 911 (2018), 2 March 2018

[24] van Stratten O (2015) Conversion of lowland tropical forests to tree cash crop plantations loses up to one-half of stored soil organic carbon, PNAS, 11 August 2015, 112(32) 9956-9960, 27 July 2015, Proceedings of the National Academy of Sciences of the United States of America (PNAS)

[25] 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

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

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

[28] ETRMA (2019) Sustainable Natural Rubber & European Commission Deforestation Agenda, 21 February 2019, ETRMA: Brussels

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

[30] Laroche P et al (2021) Assessing the contribution of mobility in the European Union to rubber expansion, Ambio, A Journal of the Human Environment, 12 June 2021

[31] Laroche P et al (2021) Assessing the contribution of mobility in the European Union to rubber expansion, Ambio, A Journal of the Human Environment, 12 June 2021

[32] Laroche P et al (2021) Assessing the contribution of mobility in the European Union to rubber expansion, Ambio, A Journal of the Human Environment, 12 June 2021

[33] ETRMA (2019) Sustainable Natural Rubber & European Commission Deforestation Agenda, 21 February 2019, ETRMA: Brussels

[34] Laroche P et al (2021) Assessing the contribution of mobility in the European Union to rubber expansion, Ambio, A Journal of the Human Environment, 12 June 2021

[35] Laroche P et al (2021) Assessing the contribution of mobility in the European Union to rubber expansion, Ambio, A Journal of the Human Environment, 12 June 2021

[36] ETRMA (2019) Sustainable Natural Rubber & European Commission Deforestation Agenda, 21 February 2019, ETRMA: Brussels

[37] Laroche P et al (2021) Assessing the contribution of mobility in the European Union to rubber expansion, Ambio, A Journal of the Human Environment, 12 June 2021

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

[39] Feintrenie L (2014) Agro-industrial plantations in Central Africa, risks and opportunities, Biodiversity and Conservation, Ed. Hawksworth DL, June 2014, 23:1577-1589

[40] 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

[41] 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

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

[43] 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

[44] 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

[45] 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

[46] 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

[47] Personal communications with Florence Pendrill, PhD student, Department of Space, Earth and Environment, Chalmers University of Technology, Gothenburg, Sweden, 30 September 2021 to 6 October 2021

[48] Pendrill F et al (2020) Deforestation risk embodied in production and consumption of agricultural and forestry commodities 2005-2017, see: https://bit.ly/3lcP96U

[49] See: Pendrill et al (2019) Deforestation displaced: trade in forest-risk commodities and the prospects for a global forest transition, Environmental Research Letters, 14 (2019) 055003, 1 May 2019; Pendrill F et al (2019) Agricultural and forestry trade drives large share of tropical deforestation emissions. Global Environmental Change, Vol. 56, May 2019, 1-10

[50] Personal communication, Dr Eleanor Warren-Thomas, School of Natural Sciences, Bangor University, United Kingdom, 6 October 2021

[51] See: Pendrill F et al (2020) Deforestation risk embodied in production and consumption of agricultural and forestry commodities 2005-2017, see: https://bit.ly/3lcP96U; Pendrill et al (2019) Deforestation displaced: trade in forest-risk commodities and the prospects for a global forest transition, Environmental Research Letters, 14 (2019) 055003, 1 May 2019; Pendrill F et al (2019) Agricultural and forestry trade drives large share of tropical deforestation emissions. Global Environmental Change, Vol. 56, May 2019, 1-10

[52] Pendrill F et al (2020) Deforestation risk embodied in production and consumption of agricultural and forestry commodities 2005-2017, see: https://bit.ly/3lcP96U

[53] Personal communication with Florence Pendrill, PhD Student, Department of Space, Earth and Environment, Chalmers University of Technology, Gothenburg, Sweden, 6 October 2021

[54] Laroche P et al (2021) Assessing the contribution of mobility in the European Union to rubber expansion, Ambio, A Journal of the Human Environment, 12 June 2021

[55] Eurostat data on natural and process rubber imports into EU from Jan-December 2019, accessed by Dr Eleanor Warren-Thomas on 8 October 2021

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


Hat Yai sustainable rubber workshop

Learning how to 'do' sustainable rubber

July 27, 2021

Read the Report

As part of Mighty Earth’s continuing efforts to advance sustainability within the natural rubber sector, we are thrilled to be co-publishing a new practical guide for rubber industry actors, entitled “Sustainable Natural Rubber: pathways, policies and partnerships”.

The guide is based on expressed demand from stakeholders following a workshop of the same title, held in Hat Yai, Thailand, in September 2019, which was co-hosted by Mighty Earth, Rainforest Allianceeinhorn ProductsEarthnet Foundation, and the Prince of Songkla University. This event brought together over one hundred rubber farmers, traders, processors, CSOs representatives, government officials, academics, and consumer brand companies to share knowledge and and potential solutions to environmental, social, and economic challenges in the industry.

Like the workshop itself, the guide is a collaborative piece, consisting of four distinct yet complementary perspectives on the proactive steps companies purchasing natural rubber can take to engage with their supply chain. These are just four potential ways out of a long list of courses of action a company may find themselves interested in pursuing. The ultimate goal of this guide is to encourage companies interested in establishing sustainability initiatives to expand their knowledge of potential paths, and further learn how they can best accomplish each route.

Mighty Earth and our partners hope that this resource will equip companies interested in sourcing sustainable natural rubber with additional tools and ideas for doing so.


Lobby group representing Michelin, Goodyear and Continental pressures EU Commission to exclude rubber from deforestation law

A row has erupted between NGOs and the rubber industry following lobbying by the EU tyre and rubber industry association to the European Commission, pressing for natural rubber to be excluded from forthcoming new EU due diligence regulations designed to stamp out deforestation, ecosystem loss and human rights abuses in key global commodity supply chains.

Civil society organisations from Europe, Africa and the US are highly alarmed that rubber dropped out of the list of the Commission’s high forest-risk commodities and urged senior officials to keep rubber in the upcoming regulations. New research published by Greenpeace highlights the role of the industry in pushing for this change.

A key European Parliament resolution adopted in October 2020 had identified rubber as one of the main drivers of deforestation. More recently, on 25 February 2021, the Commission included rubber in a presentation detailing the preliminary list of key forest and ecosystem-risk co commodities covered under the draft EU Regulation.

However, the European Tyre & Rubber Manufactuers’ Association (ETRMA) – whose members  include powerful EU and global rubber and tyre makers such as Bridgestone, Continental, Goodyear, Michelin and Pirelli – issued public statements in late 2020 urging European Commission officials to drop rubber from its target list of key forest and ecosystem-risk commodities covered by the EU’s new mandatory due diligence Regulation.

The Greenpeace report shows how ETRMA further argued to the European Commission that rubber is now considered a “low-risk commodity” in relation to deforestation, [1] and instead said it supports a more focused approached to EU policy measures on deforestation and so supports the call for the EU to act on products ‘that have “the most proven impact.”’ [2] The ETRMA conclude that regulatory action to combat rubber-related deforestation instead should be done locally, in producing countries, or at the global level. [3]

The CSOs point out that ETRMA’s stance that rubber is a low forest-risk commodity runs counter to the widely accepted evidence. A major report for the European Commission in 2018 highlighted that an estimated three million hectares of forests were cleared to make way for rubber cultivation in the Mekong region of Southeast Asia since 2000. Environmental groups  such as Global Witness, Greenpeace and Mighty Earth have also documented harrowing evidence of widespread deforestation, illegal logging, human rights abuses, habitat loss, and biodiversity and livelihoods destruction linked to the expansion of rubber cultivation in numerous countries, such as Cambodia, LaosVietnam, CameroonIndonesia and Papua New Guinea.

In response to public indications from senior officials that the European Commission is about to heed ETRMA’s advice and drop rubber from its target list of key forest and ecosystem-risk commodities covered by its new regulation, a global coalition of CSOs have written an urgent open letter to European Commissioner for Environment Virginijus Sinkevičius, urging him to keep rubber in the EU’s deforestation law.

“It’s outrageous that ETRMA has aggressively lobbied the European Commission for rubber to be dropped from new EU regulations designed to stamp out rampant deforestation, ecosystem loss and human rights abuses in global supply chains,” said Dr Julian Oram, Campaign Director for Mighty Earth. “If the EU Commission bows to ETRMA’s lobbying pressure and shamefully drops rubber from its new deforestation law, then we’ll see more deforestation of rainforests, more destruction of ecosystems, and more violations of the rights of local and Indigenous communities.”

Mighty Earth approached ERTMA for comment but, at the time of publication, the lobby group had not responded.

The EU plays a key role in the global rubber supply chain: a quarter of global rubber production goes to the EU and five of the six largest global tyre and rubber corporations – Bridgestone, Continental, Goodyear, Michelin and Pirelli – have headquarters or key markets in the EU. With global demand for rubber products – which is predominantly for auto tires – projected to increase significantly post-pandemic, Governments and corporations need to adopt all the tools, laws and regulations at their disposal to help avert a destructive new wave of rubber-related deforestation in the coming years.


Notes:

[1] In a supporting submission to the European Commission on 10 December 2020 in relation to an EU consultation question about which key commodities contribute to deforestation, the ETRMA said:

“Whilst ETRMA does not have any direct information on the impact of deforestation of the chosen conglomerate of commodities, there are several studies that were carried out by both EU Institutions (European Commission’s public consultation and European Parliament’s EPRS), international organisations (such as FAO) and NGOs (eg. WWF). All of these studies indicate that commodities such as cattle, soybeans and palm oil contribute to the bulk of deforestation (40% according to FAO). Furthermore, the summary report of the public consultation in the context of the Communication on stepping up EU action against deforestation shows that rubber is considered as a low-risk commodity.”

[2] See supporting submission ‘Deforestation and Forest Products Impact Assessment Consultation, Explanation supporting ETRMA’s responses to the questionnaire, 10 December 2020’, which says in relation to the range of products to be covered by the future EU policy measures:

“ETRMA supports the call to act on products that have “the most proven impact”, through specific measures designed to meet the specificities of each products’ value chain, on the condition that such impact is carefully studied in terms of recent and  current developments.” 

[3] In a supporting submission to the European Commission on 10 December 2020, the ETRMA argue against the wider need for EU due diligence regulation of rubber:

“The main issue with the approach taken in this consultation is that it looks for EU actions that should have an impact on countries on which the EU does not regulate and on which the EU has no control on. It is for this reason that the work should be done locally – in producing countries – or globally.”


Contact: Nico Muzi, Mighty Earth, [email protected] or + 32 (0) 484 27 87 91 (m)


Towards Accountability?

While the world watched the devastation caused by the COVID-19 pandemic and people globally sheltered in place, companies like Vietnamese rubber and agribusiness giant HAGL Agrico quietly took to destroying lands and forests in Cambodia belonging to Indigenous communities, disrupting ecosystems, and desecrating sacred places in order to use the land for unsustainable mono-cropped industrial agriculture.

One member of the Indigenous Ka Chork ethnic group in Ratanakiri, Cambodia, where most of the destruction took place, described the devastation caused by HAGL:

“The company's investment has affected the burial ground of our people, our farms, streams, ponds, grasslands for raising cattle, and so on. We lost our forest, we don’t have wood to build our houses, or places to look for non-timber forest products. Women in my village do not dare to walk into the forest because they are afraid of the [HAGL] company workers. This year, there was a case where a company worker raped a woman in a nearby village. 

“Currently, we can’t look for natural vegetables, fish, or crabs as before because the company uses chemical pesticides in the plantation which flow into the streams, so when our villagers walk down to the streams, we get rashes on our hands and feet. Since the company came in, our people have become poorer... and many have moved as they are afraid of the company clearing.”

Unfortunately, without strong action from their global business partners – in this case French auto giant Peugeot and other car makers - this story is and could become even more common in the rubber industry: a company with an unrecognizable brand decimates the environment and violates human rights, while their partners, buyers, and those profiting from their destruction can sit on the sidelines of an opaque value chain and wash their hands of any responsibility.

In short, there is a huge accountability gap.

However, one important step towards industry accountability happened this month. In June 2021, the Global Platform for Sustainable Natural Rubber (GPSNR) announced the implementation of a grievance mechanism. This mechanism will provide access to remedy for individuals or groups negatively impacted by members of the platform or GPSNR itself, and will guarantee accountability to membership requirements and principles. This is a huge step forward for the rubber industry as an open, predictable, and just system for processing complaints can help ensure that the over 100 members of GPSNR adhere to supply chain requirements that will protect communities and farmers and advance environmental sustainability.

This significant achievement comes as GPSNR recently celebrated the second anniversary of its founding in March 2019 and, to date, there have been several major accomplishments. These include the passage of a comprehensive set of sustainability and human rights-based policy requirements, the formal inclusion of smallholder representatives from rubber producing countries in the platform and on the Executive Committee, and now, the launch of the grievance mechanism.

While these are all important and signal strong movement forward by the industry, GPSNR has yet to overcome a few critical challenges. One of the biggest of these is a reluctance to move towards supply chain transparency and data sharing that would help identify and solve some of the major environmental and social issues associated with the production of natural rubber, and which make the need for a formal grievance mechanism so great.

To date, GPSNR has not meaningfully increased transparency in the natural rubber industry. While movement towards transparent reporting is a core principle of the Platform (as highlighted in the Founding Members statement), as of 2021, the London Zoological Society’s SPOTT assessment reported that, for example, just 14% of companies they reviewed provided comprehensive detail on how they are supporting smallholders and even fewer have reported clearly where their natural rubber is coming from. Without clear obligations for reporting or commitments to disclose information for public knowledge, it is much harder to identify problems on the ground - such as those experienced by the Indigenous communities in Ratanakiri - or take steps to solve them.

Perhaps companies will get there on their own, but in order to act with the requisite urgency, they will need to feel pressure to take responsibility for environmental degradation and human rights violations – whether by themselves directly, in their supply chains, or by their business partners. This is why GPSNR has high standards for all members of the platform and will need to quickly develop a system to ensure implementation of those expectations.

We believe the GPSNR grievance mechanism can help resolve some issues that arise after the fact, but the goal should be to understand and share enough about corporate supply chains and business practices that GPSNR can help ensure proactive compliance with membership requirements before complaints need to be filed.

For true accountability and to ensure that companies are not just riding the coattails of a platform with “sustainability” in its name, companies must commit to concrete actions that will increase public knowledge of the supply chain, the risks, and the bad actors that are enabling environmental destruction and human rights abuses. The grievance mechanism published this month puts an emphasis on transparency of process and outcome: ensuring that all stakeholders understand how far a complaint has made it through the mechanism, what the findings are, and what actions are being taken. This will allow all parties to have the same information and be able to understand the credit or consequences for actions that need to be taken to remain in good standing with GPSNR. Hopefully, this step will get the industry closer to embracing transparency and enable it to learn from existing concerns.

If we seek to really solve problems in the natural rubber supply chain, like the deforestation and human rights abuses we see in Cambodia and across the rubber-producing world, we need big ambition and a commitment to transparency and accountability.


Mighty Earth submit $1bn ‘Green bond’ application to convert Central Park and Hyde Park into rubber plantations

LONDON – Two of the world’s most famous recreational parks – Central Park in New York and Hyde Park in London – could be razed and transformed into huge new industrial rubber plantations under a proposed $1 billion ‘Green bond’ application submitted today by environmental campaign group Mighty Earth.

US-based Mighty Earth released a set of images including of New York's iconic Central Park, and Hyde Park in London, of their audacious plan to deforest and replace these two historic parks with lines of rubber trees as they submitted their $1bn application to the Climate Bonds Initiative (CBI) in London – the body that oversees the booming $1.3 trillion global ‘green bond’ market.

“We’re following in the footsteps of other financiers that have used green bonds to back industrial rubber projects that destroyed rainforests in Indonesia,” said Mighty Earth Campaign Director Alex Wijeratna. “We’re asking the CBI to rubber-stamp a $1 billion ‘Green bond’ to finance the flattening of Central Park and Hyde Park so we can plant thousands of rubber trees.“

“Millions of visitors to these famous parks might be a bit peeved by our rubber reforestation plans,” said Wijeratna. “But we promise we’ll keep a small part of the lake in Central Park intact and leave the Duke and Duchess of Cambridge’s sprawling Royal pad, Kensington Palace, in Hyde Park, untouched, too.”

Mighty Earth’s images show a scarred and unrecognizable landscape and the potentially catastrophic impact of their outlandish plans to bulldoze and industrially ‘reforest’ the iconic 340-hectare Central Park in New York and 253-ha Hyde Park/Kensington Gardens in London, which are renowned for their abundant trees, lakes, wildlife and natural beauty, and together are visited by over 55 million people each year.

Mighty Earth’s application to the CBI and green bond principles standard setting body the International Capital Market Association (ICMA) is designed to draw attention to the burgeoning issue of ‘greenwashing’ linked to self-labelled green bonds and the failure of the CBI to investigate and respond to Mighty Earth’s formal complaint and allegations of widespread deforestation linked to a $95 million CBI-screened ‘green bond’ on French tire maker Michelin’s 70,716-ha joint venture natural rubber project in the rainforests of Jambi, Indonesia.

Mighty Earth alleged in their complaint to the CBI on March 11, 2021, that over five thousand hectares of rainforest in Jambi – a globally significant biodiversity hotspot, that was home to two forest-dependent Indigenous communities and critically endangered Sumatran elephants, tigers and orangutans – was industrially deforested by a subsidiary of Michelin’s local partner. The complaint claims that Michelin’s knowledge of this deforestation was never publicly disclosed to investors when the bonds were sold to green investors on the Singapore Exchange in 2018, in a bond offering arranged by French bank BNP Paribas and facilitated by financiers ADM Capital.

Mighty Earth call for the $95m bond on Michelin’s rubber project to be struck off and delisted as an official CBI-screened green bond. Mighty Earth have had no formal response from the CBI to date and were recently told by CBI’s CEO Sean Kidney that their complaint about massive deforestation was “not a priority” for the CBI.

“Green bonds are plagued by greenwashing and the Climate Bonds Initiative has absolutely no interest in investigating our highly credible but inconvenient allegations of deforestation linked to Michelin’s flagship green bond-financed rubber project in Sumatra,” said Alex Wijeratna. “We’d like to test the CBI’s willingness to turn a blind eye to the deforestation of precious and iconic green spaces by seeing if they would approve of Hyde Park and Central Park being razed, bulldozed, and replanted with a massive industrial rubber tree plantation!”

About Mighty Earth

Mighty Earth is a global environmental campaign organization that works to protect forests, conserve oceans, and address climate change. We work in Southeast Asia, Latin America, Africa, and North America to drive large-scale action towards environmentally responsible agriculture that protects native ecosystems, wildlife, and water, and respects local community rights. Mighty Earth’s team has played a decisive role in persuading the world’s largest food and agriculture companies to dramatically improve their environmental and social policies and practices. More information on Mighty Earth can be found at www.mightyearth.org/.

Contact: Campaign Director, Alex Wijeratna, [email protected] or + 44 (0)1753 370 824.

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Peugeot Must Act Against Land-Grabs in Cambodia

On June 10, 2021, Mighty Earth, Equitable Cambodia, and Inclusive Development International sent an open letter to Peugeot, a global automobile brand. Despite new leadership and a strong commitment to sustainability, Peugeot has repeatedly refused to publicly condemn land grabbing and environmental damage perpetuated and caused by a subsidiary of their business partner, Truong Hai Auto Corporation (THACO). Recently, mediations restarted between the Indigenous communities and THACO, but so far they have refused to return Indigenous land in Ratanakiri in Cambodia. It is time for Peugeot to hold their partners accountable for land grabs and human rights abuses. Read our open letter to Linda Jackson, CEO of Peugeot, to learn more.

Open to letter to Linda Jackson, CEO of Peugeot.


Looking at Opportunities for Sustainability in Rubber

Sustainable Natural Rubber- Pathways, Policies and Partnerships is being held from 24-26 September 2019 hosted by Rainforest Alliance, Mighty Earth, Einhorn Products, Prince of Songkla University, and Earth Net Foundation, Thailand. RSVP here!

Over a decade ago, when I started working with coconut farmers in Ban Krut, Prachuab Khiri Khan, Thailand to develop an organic coconut value chain, many of these farmers also grew rubber. Despite the work on organic coconut, there was no interest or discussion about sustainable or organic rubber. It didn't seem to merit any interest at the time, in part because rubber is not eaten, and also because it needs to be processed with chemicals to yield rubber-based products such as tires and wetsuits.

Today looks very different than 10 years ago. Many key business stakeholders are beginning to understand the need for sustainability in rubber and are adapting their sourcing policies to address this in their supply chains. The newly established Global Platform for Sustainable Natural Rubber is evidence of this and has brought together the largest number of actors from this sector so far. However, end users outside of the tire industry as well as rubber farmers and tappers remain missing voices in the platform. There are other mechanisms today for sustainable rubber as well. Thai organic coconut farmers who also grow rubber can have their latex certified as part of the “Fair Rubber” initiative. The Forest Stewardship Council® (FSC) has taken an early lead in sustainable rubber certification by actively working to engage market players.

These policies and platforms reflect a growing trend of leaders in sustainability looking deeper into their purchasing and supply chains—and this demand is coming from all sides. Consumers want to know more about the brands and products they choose: what it is, where it comes from, and the impact that it has on our planet and its people. Research shows that companies that demonstrate and communicate sustainability leadership in new areas have a clear market advantage, along with other benefits such as secure supply chain, engaged employees, and stakeholder confidence.

This growing interest in more sustainable agricultural and forestry supply chains represents a massive opportunity for positive impact on communities, local watersheds, biodiversity, and national economies. Across commodities, agriculture effects massive areas of land. For rubber alone, over 14 million hectares are cultivated, and there are millions of associated farmers and laborers.

Unless we can link investment in sustainable practices with demand from responsible markets, it is difficult to move toward sustainability or achieve certification. Farmers, particularly small-scale farmers, are on the economic edge, usually laden with substantial debts and facing the constant risks of poor yields and low prices, either of which could lead to failure and bankruptcy. Even without a significant shift in practices, achieving certification adds a cost in time, training, and resources. If major shifts in practices are also needed, this requires an even greater investment and effort.

Much of the initial focus has been on preventing additional deforestation, similar to efforts with oil palm, and these commitments are critically important. However, with low rubber prices in the market for several years now, pressure to clear more land for rubber has been reduced. As such, it is also critically important to look at the management of rubber lands and practices that support biodiversity, watershed and soil health, and carbon sequestration. This must be done alongside consideration of the economics of the supply chain and developing goals that ensure farmers realize financial stability and improved livelihoods through rubber cultivation, regardless of fluctuations in the market and price.

An interesting possibility for improving the ecology and economics of rubber cultivation for farmers lies in exploring how diversity and ecology can be brought back to the millions of hectares that have already been transformed to monoculture. Here we see a huge opportunity, as demonstrated in research from the Prince of Songkla University and the experience of many farmers in Thailand. Both show that rubber can be effectively grown in diverse agroforestry systems to deliver comparable latex yields and much better performance on ecological measures such as erosion, water sequestration, biodiversity, carbon sequestration, and microclimate, while providing beneficial secondary yields of other commodities grown on the same land.  This should not be surprising at all, as the rubber tree’s (Hevea brasiliensis') native habitat is in the most diverse forests of the Amazon.

It is critical that we begin transforming the rubber sector and send signals from the market that there is a demand for sustainability managed rubber farms and latex. This is fundamental to the long-term viability of natural rubber overall, as it is apparent that rubber farmers, like many types of farmers, are an aging population. Many farmers do not want or expect any of their children to farm and tap rubber. This perspective is not overly surprising given the low returns and difficult work of rubber cultivation. In addition, the job of a rubber tapper is not always seen as reputable work. These factors can have a negative impact on the future supply of natural rubber, despite the expected growth in market demand for rubber. We have a massive opportunity to improve the livelihoods and labor conditions for rubber tappers, to introduce new methods of management and technologies to improve yields, and to make rubber tapping a more sought-after job.

In truth, we are just starting this exploration for natural rubber and many other solutions are still yet to be developed.   When the key actors and supporters of value chains from farmers to processors, from enterprises to final consumers, work together, and when government agencies and NGOs help facilitate the right environment and provide key support where needed, the potential for rapid and dramatic shifts towards sustainability or even the step beyond sustainability—to regeneration—is frankly amazing.

It is not clear where we will go, but in the next decade we can and will dramatically shift the natural rubber value chain and its impact on our planet to be far more sustainable. If you would like to join us in exploring this potential and discussing some of the solutions proposed at a multi-stakeholder dialogue taking place near some of the most interesting sustainable rubber farming innovation in Hat Yai, Thailand, please contact Margaret Kran-Annexstein ([email protected]).

Michael B. Commons,  Earth Net Foundation, Thailand