Tire & rubber industry ‘needs tailored EU anti-deforestation laws’
21 Mar 2022
ETRMA: Traceability requirements should be “as inclusive and as actionable as possible.”
Brussels - Proposals to extend legislation on deforestation associated with products placed on the EU market to more commodities would be impractical to apply to natural rubber (NR), the European Tyre & Rubber Manufacturers’ Association believes.
Instead of the EU’s traceability ‘to the plot of land’ approach, ETRMA wants “inclusive and actionable” legislative measures against deforestation, which also support responsible and sustainable sourcing of NR.
According to ETRMA secretary general Fazilet Cinaralp, EU lawmakers should develop “a mandatory risk-based due diligence model based on ‘jurisdictional traceability’ coupled with mitigation programmes.”
This, she said, would effectively “accelerate and scale up initiatives for sustainable commodity production” involving individual suppliers/smallholders, while limiting unintended consequences on the latter.
In a position summary, ETRMA advises that the possible extension of the EU regulation should ensure that the traceability requirements are “as inclusive and as actionable as possible.”
The NR supply-chain, notes ETRMA, involves six million small holders and up to 10 layers between the tree and the final consumer.
Each batch of rubber bought by tire and rubber goods’ makers contains NR from several plots of land within a certain jurisdiction.
Manufacturers buy from the same factories, which in their turn source rubber from the same plots of land, ETRMA points out.
This means that “the costs of this traceability practice would be multiplied several times for each manufacturer while offering very limited or no benefits to prevent and mitigate deforestation.”
The EC proposal to require traceability to the plot of land, would, therefore, not be an effective solution for the natural rubber supply chain, due to its complexity, ETRMA insists.
The industry association, therefore, recommends that the requirements be tailored to each commodity and that traceability is required down to the ‘jurisdictional unit’ rather than to the rubber plot of land.
In this regard, the role of local dealers, processors and traders should be reinforced, according to the industry association.
To this end, ETRMA advises “effective international trade agreements and intergovernmental cooperation would need to play an essential role to ensure the commitment of third countries’ governments and local authorities.”