Operational Guidance

for EUDR in the Natural

Rubber Supply Chain

Chapter 1:
Information collection
(article 9)

Note: This is a draft that is being made available

for public consultation. It is not final and is
subject to revision

April 2024
Introduction
Detail

This document provides operational guidance for processors, producer and traders (PPTs)
to initiate actions toward EUDR compliance, from the perspective of manufacturers in the
About this document role of ‘Operators (importers)’. The document is a result of consultation between the
manufacturers members of GPSNR (tire maker and rubber manufacturers) on a category-
specific process, consultations were also organized with PPTs members.

The document lays out steps for PPTs to begin the process of (1) geomapping (2)
collecting data (3) and supply chain management including segregation, for action
toward EUDR compliance. The authors understand that further guideline may be issued
Disclaimer for use
by regulators, and that legality requirements are country-specific; the elements
mentioned may not be exhaustive.

Focused on complex, multi-tier, smallholder supply chains.

• Farm mapping and data collection
Scope • Intermediaries
• Factory Process: reception, process, warehouse
• Factory output
Summary of slides
Slides (slide number) Topic

Basic requirements Summary of the basic requirements of the EUDR

Supply Chain Mapping How to map supply chain, how to sort farms to EUDR and non-EUDR

Data collection farm +

What data is to be collected from the farm
control

Identification:
Identification of DCF
Deforestation-free

Identification: Legality Identification of legality

01 Basic Requirements
Summary of Information collection
requirements
1. Geolocation of all plots of land*
2. Verifiable information that the products (from plots of land) are deforestation-free
3. Verifiable information that production has been conducted in accordance with the
relevant legislation of the country (including any arrangement conferring right to use
for production of the commodity.

* as well as the date or time range of production

Article 9: Information Collection for each farm
(1) (2) (3)

Geolocation Deforestation-free Legality

(polygon mapping) analysis
Requirements
a) Right-of-use b) Environmental +
(land documentation) Social/Labor laws,
Human rights/FPIC

Physical mapping on the Use (1) to cross-check with On-site visit: Collect land On-site visit: Collect data on
ground satellite monitoring tools. documentation information farmer practices, farm data
On-site
etc. visit: Collect data on-
Physical mapping on the Use (1) to cross-check with On-site visit: Collect land
How to check: site to assess farmer
ground satellite monitoring tools. documentation information
practices, labor pratices etc.

Other online databases or

Government land database Cross-checks with
On the ground checks spatial maps (e.g., watershed
Supplement (only for full-official land government land database
(ground truthing) and data map, topographical map,
with: deeds, still need on-site visits (applicable only for full-official
collection indigenous and land conflict
for correspondence) land deeds)
database)

(4) Other important information: identification data, volume quota

How to start?

Identify Deliver
Collect Segregate Segregate
Supply EUDR product
Data at farm to in factory
Chain Map Compliant with right
Farm factory process
Farms data
How to start: details
Step Details

Know who are the players in your supply chain. E.g.,

• For one large dealer direct supplier, how many sub-dealers (village dealers) do they
have?
Supply Chain Map
• Know how (approximately) how many farmers supply these dealers.
• You will need to eventually cascade down your 'approved farmer list' to the first
farmer-facing dealer (village dealer)

Collect Data at Farm Make sure to collect the correct data for EUDR requirements. Choose a tool that allows
(Plot) this.

After you collect data from farm plots, you will need to sort them to identify the EUDR
Identify EUDR compliant compliant farms. You will identify:
plots (1) plots that are deforestation-free (by satellite analysis)
(2) plots that are legal (rubber produced in accordance with local legislation)
02 Supply Chain Mapping
Supply Chain Mapping (1)
Step 1: Identify your target pool of direct suppliers, this can be direct smallholders,
farmers’ groups / cooperatives, or dealers (i.e., you may not map 100% of supply).

Step 2: Get the big picture. For each of these direct suppliers, interview them to
understand their supply chain and approximate the number of smallholders.

Step 3: Select a solution to collect data and map farmers.

• Select a solution that collects the right data (see '03_ Data Collection at Farm Plot').
• You can hire a service provider to do the groundwork or ultilize your own
staff. Either way, it is important that manpower is trained in SOPs, there will also
need to be verification of data.
• Mapping effort should be well socialized in the supply chain. Smallholders should
be engaged on the purpose of the exercise and understand their data
protection/ownership rights and the value of their data.
Supply Chain Mapping (2)
Step 4: Use the data collected to identify EUDR compliant farm plots vs. Non-
compliant farm plots. (see 'Identification of EUDR Compliant Farm Plots')

Step 5: Inform your suppliers (intermediaries or farmers groups) of the EUDR

compliant list of farmers. You should be able to extract out one list per village dealer
(the farmer-facing dealer) Provide training to intermediaries on how to identify and
segregate EUDR compliant volume (see 'Segregation for the Upstream')
Supply Chain Mapping: Get the big picture
Example of supply chain mapping exercise: note the aim of 'drilling down' to the farm plot
Tier 1 Tier 2 EUDR
Supplier Type # of suppliers Supplier Type # of suppliers # EUDR Status
code code farms
001 Big Dealer 3 suppliers 001-01 Small dealer 50 farmers 50/50 farm Full EUDR
plots
001-02 Small dealer 60 farmers 30/60 farm Partial EUDR;
plots segregation
required
001-03 Farmer 100 farmers 0/100 Non-EUDR
group
002 Small Dealer 50 farmers 50/50 Full EUDR

003 Farmer 150 farmers 50/150 Partial EUDR;

group segregate
004 Big Dealer 2 suppliers 004-01 Small dealer 10 farmers 7/10 farm Partial EUDR; seg
plot regate
004-02 Small dealer 50 farmers 50/50 farm Full EUDR
plot
Visualization of supply chain mapping
process

Farm plot
004-02-0001

Village Dealer
004-01

Farm plot
004-02-0002
Large Dealer 004

Village Dealer
Farm plot 004-02
004-02-0003
03 Data Collection at Farm
Data Collection: Summary
To meet the requirements of the EUDR, adequate data must be collected at the farm.

Main data categories

• Identification data: Data that will allow the processor (or their intermediaries) to
identify 'approved farmers (farm plot)' [name, ID#]
• Geolocalization data: polygon shapefile or GPS point [.geojson format]
• Data related to conformance with legislation
• Data related to identity and volume quota to avoid leakage

--> It is recommended that a dedicated tool/application be used for data collection.

Specific advice on database management or collection of geolocalization
Data Collection: Important check points
Ensure that:
1. Staff are well trained on the procedure. Including on any technical aspects of the
questions
2. Data collection complies with local and GDPR personal data collection regulation.
3. Staff are well trained on socializing farm-plot registration
Article 9 elaboration
Requirement Data required Methodology
1. Geolocation of all plots of land Boundary shapefiles*. Should be Dedicated geomapping tools
consolidated in .geojson format. (applications) are recommended.
[Article 9(1), (d)]/[Annex II (3)]
*note that single GPS point is allowed under the law for Otherwise, processors will need to carefully organize
plots of land less than 4ha, but the recommendation is for geographical data in dedicated software/databases.
full boundary data for all plots

2. Plots of land are deforestation-free Satellite analysis for each plot Dedicated satellite analysis providers
[Article 3 (a)] demonstrating that land was are recommended. Supplement with
developed prior to 31 December 2020 open-source data as needed: GFW, EU
observatory.
*it is preferrable to also align with the GPSNR cut-off date Also refer to slides: 'Identification of EUDR compliant
of 1 April 2019 farms: Deforestation-free'

3a. Conducted in accordance with Collect data/documentation from Data collection at farm level for land
legislation: Land use rights farmers that demonstrate a right to documentation.
[Article 3 (b)] use the land.
Supplement with analysis to show
plots are not overlapping with
restricted-use / illegal areas (e.g.,
protected areas)
Article 9 elaboration
Requirement Data required Methodology
3b. Conducted in accordance with • Environment protection: farm Collect data on-site, through trained
legislation: characteristics (proximity to surveyors, which assess legal aspects
• Environment protection waterways, slopes), permits (as along a predefined checklist.
• Forest-related rules…where directly applicable)
related to wood harvesting • Forest-related rules: location of farm Supplement with other spatial
• Third parties’ rights does not infringe on restricted use / datasets if applicable.
• Labor rights protected areas
• Human rights protected under • Labor and human rights: household
international law and labor structure, labor practices
• The principle of FPIC • FPIC: Data on land disputes (e.g.,
• Tax, anti-corruption, trade and databases)
customs regulations.
[Article 3 (b)]
Other important aspects covered Farmer identification detail. Production can be estimated from
other parts of the law: planted area * average production
Determine quota of production per
Controlling risk of leakage and farm. Note: in addition, include risk
ensuring accordance with other assessment on potential leakage
legislation Note: The above are initial data to be across borders
[Article 10(2), (i)], [Article 3 (b)] collected while on the farm, but will
need to be paired with strong
segregation controls.
Why boundary/polygons are preferred
1. Polygons are the best way to determine the size of the farm plot (i.e., if you only have one GPS point,
how do you prove the farm is really below 4ha?). They are also the best way to establish that a plot it
totally deforestation and degradation-free.
2. Polygons will result in less analysis and cost for analysis on deforestation and protected area risk. It
also reduces the instances of 'false positives', as the buffer may show overlap with forest when the
real farm does not. See below visualization.

Farm
Possibility 2 Polygo
n
Forest Forest Forest
Farm Farm Buffer
Polygo
n
Possibility 1

With a polygon, the 3ha For single point GPS, we This means we need a We need a much larger
farm plot is clearly outside of must take into account all buffer around the single area for a farm buffer vs. a
the forest. possibilities, including 'long GPS that takes into account real polygon. This means
length farms' these extremes. There is higher costs for analysis.
also risk of false positives.
Expected controls on Data Collection
Purpose: to ensure that adequate controls are in place in the upstream supply chain
to mitigate risks of inaccurate data.

It is expected that verification checks will need to be performed on a sample of the

collected data to ensure accuracy

Applied on a % of supply at an annual frequency:

• Required: Justification is needed based on management approach
• Second (buyers) or third-party recommended (audit agency)

Examples of checks:
• Check that geolocation (e.g., polygons) are in the correct area and look aligned
with satellite landcover (e.g., not crossing roads etc.).
• Verify data collected with cross checks with farmers on the ground.
• If digital land databases exist in-country, cross check land document information.
04 Identification of EUDR
Compliant Farms
Deforestation-free, compliant with legislation
Identifying compliant farms from your list
Example of supply chain mapping exercise: note the aim of 'drilling down' to the farmers
Tier 1 Tier 2 EUDR
Supplier Type # of suppliers Supplier Type # of suppliers # EUDR Status
code code farms
001 Big Dealer 3 suppliers 001-01 Small dealer 50 farmers 50/50 farm Full EUDR
plots
001-02 Small dealer 60 farmers 30/60 farm Partial EUDR;
plots segregation
required
001-03 Farmer 100 farmers 0/100 Non-EUDR
group
002 Small Dealer 50 farmers 50/50 Full EUDR

003 Farmer 150 farmers 50/150 Partial EUDR;

group segregate
004 Big Dealer 2 suppliers 004-01 Small dealer 10 farmers 7/10 farm Partial EUDR;
plots segregate
004-02 Small dealer 50 farmers 50/50 farm Full EUDR
plots
Identification of EUDR compliant farm
plots
After geolocalization and data collection has been completed for an intermediary /
group of farmers, analyze each for compliance with:
• (1) Deforestation-free
• (2) Legality: for smallholders, material legality risks include right-of-use as well as
other environmental and labor/human rights risks (see following slides). [Article
1(2), (40)]

The list of EUDR compliant plots should then be consolidated and communicated to
intermediaries (or farmers groups etc.). They should be instructed to only purchase
from those farms /plots when they are purchasing EUDR volume.
Identifying compliant farms from your list
Example of Identification of EUDR Compliant farm plots: e.g., supplier 004-01
• Each farmer-facing dealer should be provided a list of 'approved farmers'
Farm plot Geolocalized + data Legality check?* Deforestation-free EUDR Complaint?
collected? check*
004-01-0001 ✓ ✓ ✓ Yes, inform dealer
that farmers are
004-01-0002 ✓ ✓ ✓ EUDR compliant.
004-01-0003 ✓ ✓ ✓ Dealer can either:
004-01-0004 ✓ ✓ ✓ (1) source exclusively
from these farmers
004-01-0005 ✓ ✓ ✓
(2) or ensure that
004-01-0006 ✓ ✓ ✓ rubber from these
farmers are
004-01-0007 ✓ ✓ ✓ segregated
004-01-0008 ✓ x ✓ No, inform dealers
and ensure rubber
004-01-0009 ✓ ✓ x from these farmers
does not enter EUDR
004-01-00010 x Nil, data not collected Nil, data not collected supply chain

*For how to determine legality (including FPIC) and deforestation-free please refer to next slides
Identification of EUDR compliant farms:
(1) Deforestation-free
Within long-developed rubber areas, there exist two main scenarios of land use patterns:

Scenario 1 (100% agriculture): The plot of land is 100% under agricultural use (100% developed)
• This is quite common with smallholder farms in South-east Asia, and implied that no forest remains on the
farmer's plot.
• In this case, compliance requires proof that the land had been developed prior to the cut-off date.
• This means that such plots only need to be analyzed once, and that after, there is no further risk
of deforestation since no forest remains.

Scenario 2 (mixed): The plot of land is mixed, having both land under agricultural use and land covered by natural
forests.
• This would be common in large industrial plantations and farms in some jurisdictions like Brazil, which require
landowners/users to maintain some natural/native forest in their plot.
• In this case, compliance requires proof that (1) land under agricultural use had been developed prior to the cut-
off date and (2) there is not ongoing deforestation in the land covered by natural forest.
• Importantly, this means that such lands will require regular monitoring of the land covered by natural
forest. In the lands already developed for agricultural use, there is no further risk of deforestation.

Note: In deforestation fronts, land use change can be very dynamic, and will require additional surveillance. Farms
adjacent to protected areas or forest may also be indicative of high risk of encroachment.
Identification of EUDR compliant farms:
(1) Deforestation-free
Scenario Description Compliance means How to check

1. 100% Agriculture Plot is 100% planted by Proof that the entire plot Satellite providers can either:
rubber trees (or otherwise was 100% developed • Identify the actual land cover:
developed). No natural before the cut-off date. e.g., identify that a plot is 100%
forest remains. covered by rubber as of the cut-
off date
Note: Common to many • Identify the first instance of
smallholder farms in SE forest lost and indicate that this
Check once that plot
was planted before
Asia. happened on 100% of the plot
cut-off date before the cut-off date.

2. Mixed Plot is mixed, with some (2.1) Proof that the land For 2.1, refer to steps set out in
Check that rubber was area planted by rubber (or used for agriculture was scenario 1
planted before cut-off
date (once) otherwise developed), and developed before the cut-
some area covered with off date. (as in scenario 1) For 2.2, The area within the plot
natural forest. covered by natural forests should
(2.2) Continued be regularly monitored for new
Note: Common in large regular monitoring of deforestation. Many satellite
industrial plantations and in natural forest area to providers and solutions provide
some countries like Brazil ensure no deforestation. 'deforestation alerts'. There is no
Natural forest area requires
continuous monitoring
need to monitor the agricultural
(deforestation alerts) area.
What if satellites wrongly identify a farm as
being deforested?
If you suspect that a farm has been wrongly identified as deforested after the cut-off date (or wrongly identified as
forest), you should collect, provide and retain evidence.

Examples of farms that may be wrongly categorized by satellites:

• Jungle Rubber
• Mixed crops or Agroforestry

Examples of evidence:
• Documented presence of mature or old rubber trees (e.g., satellite picks up forest but farm is actually agroforesty.
Trees are >50cm DBH and are producing, they must be 6-7 years old)

How to present evidence

• Data should be organized in formal reports per farm, with included evidence.
• For example, a report can have a description of on the ground finds, and relevant evidence (e.g., pictures of old
growth rubber or agricultural trees)
Identification of EUDR compliant farms:
(2) Legality
Methodology: two main methodologies to collect data needed for
determining legality.
1. Farm plot level data collection: likely required for 'right of use' (land
rights)
2. Data collection (or surveys) at jurisdictional level / remote sensing data
Identification of EUDR compliant farms:
Legality
This table may not be an exhaustive list, legality requirements will differ by jurisdiction
Category Legality concern Data required Farm level Juris. Remote
survey sensing

Land use Right-to-use the land for Land ownership (or demonstration of ✓
rights production native or customary right). Refer to Likely only
Annex B at farm level

(related to above) Not in Determination that farm not in protected

'exclusion zones' areas or national parks. If required, refer ✓
GIS analysis
to Annex B

Labor practice No child labor, no forced -Labor structure (e.g., no worker risk if no
labor workers, age structure of workers) ✓ ✓
-Practice (e.g., wages, work done)

FPIC (may be (not generally defined as Presence of indigenous or native ✓

less material such by national law) communities? Land conflict hot spots? ✓
On the
Datasets
for ground
available
smallholder) study

Env. Presence of waterways, Identification if farm overlaps or contains

steep slopes (typically env. sensitive areas as defined by law ✓
✓
GIS analysis
exclusion or buffer required)
 Identification of EUDR compliant farms:
Legality (annex B)
Country equivalent and description of governing laws /
Unified use rights
Type of document Controls / mitigation
class
Thailand Indonesia Cote d’Ivoire
Nor Sor 4 (N.S.4) –
Sertifikat Hak
Chanote, or full Certificat Foncier - Nil (as long as no internal
1 Land ownership Milik (SHM Title) –
land ownership Land Certificate conflict of laws in country)
Freehold Title
rights
Nor Sor 2 (N.S.2) – Hak Guna Usaha
Right for agricultural Temporary land (HGU) – Land Baux emphytéotique - Nil (as long as no internal
2
use rights Cultivation Rights Emplyteutic Lease conflict of laws in country)
reservations title
Surat Keputusan
Sor Por Kor 4 – 01
Kepala Desa (SK Land registration Provide second check
Village level (S.P.K 4-01):
3 Kepala Desa) – process varies greatly against illegal areas (e.g.,
document Agricultural Title
Village Chief’s by regions. protected area boundary)
Deed
decree
Customary right
Provide second
Also to consider Sor Kor 1 (S.K.1) – Hak Ulayat –
Customary Rights check against illegal areas
4 separately challenges Claim Certificate Customary Land
Holder (e.g., protected area
with protected are Rights
boundary)
designation
5 Other right (etc.)
Example of how right-of-use can be queried

Q1: Does the farmer have land documentation?

- Yes
- No
If YES

Q2: What is the land documentation

- List of documentation from Annex B

Q3: Upload land documentation # or picture

- To specify minimum requirements
- If not available, provide list of options why, or provide and open field for more
evidence or alternative evidence: (e.g., held in custody)
Example of how right-of-use can be queried

Q1: Does the farmer have land documentation?

- Yes
- No
If NO, it may be helpful to collect further data related to native or customary
rights

Q2: Is there an indication of native or customary rights?

- Yes, village documentation or customary demarcation (e.g., land markings)
- Yes, >5 years of occupation
- Yes, >10 years of occupation
- Yes, >20 years or multigenerational occupation
- No

Q3: [open field] please indicate additional evidence

Such cases to be cross checked with protected/restricted area analysis.

 Operational Guidance
for EUDR in the Natural
Rubber Supply Chain

Chapter 2:
Segregation

Note: This is a draft that is being made available

for public consultation. It is not final and is
subject to revision

April 2024
Summary of slides
Slides (slide number) Topic

Summary of concept of
Why use segregation and what does it mean
segregation

Upstream segregation +
How should dealers and farmers groups segregate production
Control

In the factory How are factories (TSR and RSS) supposed to carry out segregation within their factory?
segregation + Control What constitutes segregation-compatible batch processing?
Segregation: concept

DRAFT ONLY, Do not distribute beyond GPSNR

Segregation and GPSNR’s Trajectory
GPSNR aims to improve sustainability of the natural rubber supply chain as a whole. Segregation is a
practice essential for the EUDR, but the ultimate goal of the work is to eliminate deforestation from
natural rubber supply chains amongst GPSNR members and the industry as a whole.

That means segregation practice should work to prevent entry of unwanted product into the supply
chain in the first place. Companies use the information generated from implementing segregation
to design appropriate actions to rapidly and progressively eliminate the unwanted portion which
cannot be designated as deforestation free.

The goal should be to reduce the level of segregated non-compliant material incoming into supply
chains as processes mature.

Global Platform for Sustainable Natural Rubber DRAFT ONLY, Do not distribute beyond GPSNR
EUDR FAQ

No mass balance. Only segregation or identity preserved.

Global Platform for Sustainable Natural Rubber DRAFT ONLY, Do not distribute beyond GPSNR
GPSNR Supply Chain Requirements
a)

Legend: Mixed Mixed

source Output
EUDR compliant
EUDR non-compliant Factory / Smallholder
Processor farmers

❌ Mass Balance: mixing with non-compliant NR not allowed

b) c)
Source A Output A EUDR
compliant
source Output A+B

Source B Output B

EUDR non-
Source C Output C compliant Output C
source

✅ Identity Preserved: good to have, but not necessary ✅ Segregated: Mixing between compliant sources permitted
(minimum requirement)
Global Platform for Sustainable Natural Rubber DRAFT ONLY, Do not distribute beyond GPSNR
Important notes on implementation:
The following slides on segregation on the upstream and in the factory give processors some leeway
to choose the operational process that works for their situation.

However, once the process is chosen, all Standard Operating Procedures (SOP) must be fully
written down and documented, and there must be auditable evidence of implementation (e.g.,
supervisor logs for line clearance, clear and permanent signage).

The following slides also account for the FAQs provided by the commission on 29 Jun 2023, where it
was mentioned that with segregation would be required, "mass balance is therefore to be ruled out,
(and) full identity preservation is not needed". The guidance therefore takes the approach to declare
all potential plots in a particular catchment area/node (as rubber may potentially originate from any
plot in the catchment). Strong segregation must still be fully implemented at all stages from farmer
to factory.

Global Platform for Sustainable Natural Rubber DRAFT ONLY, Do not distribute beyond GPSNR
Segregation: Upstream
From farmer to dealer to reception at
natural rubber processing factory

DRAFT ONLY, Do not distribute beyond GPSNR

Trajectory of Upstream Segregation
The following guidance is given in the context of existing low-tech and non-digitalized supply
chains. It is also primarily directed at the more complex, multi-tier supply chains that are common in
the natural rubber supply chain in South-east Asia, and occasionally other regions. In this context,
the guidance aims to provide recommendations that are rigorous with appropriate leakage controls,
yet implementable where smallholders and intermediaries may not have access to technology. This
is in the vein of ensuring that smallholders remain included in global supply chains.

As processes mature and as digitalization levels allow, it is recommended that companies look to
gradually transitioning to methodologies and systems that facilitate higher frequencies of
accounting and reporting of flows through the supply chain.

Global Platform for Sustainable Natural Rubber DRAFT ONLY, Do not distribute beyond GPSNR
Segregation of material from Farmer à
Dealer à Factory
• It is expected that EUDR material shall not be mixed with non-EUDR material at
any point in the supply chain.
• Any mixing of material will render the product non-compliant

DRAFT ONLY, Do not distribute beyond GPSNR

Recording of volume collected
Example of sheet that can be provided to an intermediary (cascade down to farmer-facing dealer). Note: in the
segregation method, the farmer-facing dealer only retains this data at their site, they will not identify which
farmers contribute to particular shipments (i.e., they do not pass down this data)
List provided to: Intermediary 004-01
Effective date: 9 September 2024
EUDR Compliant Farm plot List
Farm plot Name of farmer Vol. (kg wet) Vol. (kg wet) Vol. (kg wet)
Oct 2024 Nov 2024 Dec 2024
004-01-0001 Herman Tono

004-01-0002 Supardi

004-01-0003 Agus Budi

004-01-0004 Tono

004-01-0005 Sri Agus

004-01-0006 ...

004-01-0007 ...

Global Platform for Sustainable Natural Rubber DRAFT ONLY, Do not distribute beyond GPSNR
Segregation of material within dealer
At Farmer-facing Dealer During storage and transport
Segregate raw materials based on given list
Segregation between EUDR compliant and
Transaction recording (EUDR compliant bin): non-compliant raw materials, with clear labels
• Farmer ID / Name
• Weight (Volume) ● Cup lumps: Physical barrier / 1m gap
• Date ● Latex: Designated tanks / barrels

Smallholders

Transportation EUDR
EUDR
EUDR
Volume
50kg

nth Dealer
EUDR
If latex: EUDR Volume
200kg

Mixing should not

Farmer-facing Dealer be allowed during
(village dealer) transportation
DRAFT ONLY, Do not distribute beyond GPSNR
Segregation of material within dealer
Verification of farmer (EUDR Accounting of EUDR Volume Storage and segregation
volume) identity
§The intermediary (dealer/coop) §Upon receipt of raw material §EUDR raw material should be
must have a clearly defined list from EUDR compliant plot, the segregated and demarcated
of EUDR compliant farms/plots intermediary should record the from non-compliant material
transaction (farmer ID/name + §Physical separation and clear
weight + date) 'EUDR' labels

Segregation: Cup Lumps Segregation: Latex Delivery and transport

§Designated 'bin' for EUDR raw §Designated tank(s) for EUDR §Intermediary must ensure no
material: Physical separation by latex. If non-EUDR tanks are mixing of raw material even
barrier is preferred (or at least converted for EUDR use, they during transport. Each trip
1m gap). A basic sign should be must be washed should be dedicated for EUDR
placed / non-EUDR volume. EUDR
material should be labelled.

Global Platform for Sustainable Natural Rubber DRAFT ONLY, Do not distribute beyond GPSNR
 Flow of data: Village Dealer as Gatekeeper
Defined list of EUDR
compliant smallholders
/ farmers

Records:
004-01-0001: 10 kg EUDR
Farm plot 004-01-0002: 20 kg Volume
004-02-0001 004-01-0003: 20 kg 50kg Volume per
Total for Nov 2023:
50kg Village Dealer delivery
004-01

Farm plot
004-02-0002 EUDR
Large Dealer 004 Volume Records:
EUDR 150kg B. Dealer 004: 150 kg
Volume Records:
100kg V. Dealer 004-01: 50 kg
V. Dealer 004-02: 100 kg
Village Dealer
Farm plot Total for Nov 2023: 150kg
004-02
004-02-0003

Farmer-facing dealer (village Large Dealer Factory

dealer) Retain: Volume for each delivery Retain: Volume for e
Retain: Volume per approved farmer received (also summarize volume ach delivery
per delivery (and summarized by received by month/year). Best received, recorded
month/year). 5 years. practice is to track by supplier per direct supplier.
(village dealer). 5 years. For 5 years.
Send to next tier: Volume of EUDR
rubber per delivery Send to next tier: Volume of EUDR
rubber per delivery
Global Platform for Sustainable Natural Rubber DRAFT ONLY, Do not distribute beyond GPSNR
Flow of data: Village Dealer as Gatekeeper
• In this mode, the processing factory is the primary organizer and coordinator of data, and of the
EUDR compliance status of individual farmers or plots of land.
• After completing a supply chain mapping process, and identifying and assessing EUDR compliant
farmers/plots, the processing factory will cascade a list of approved farmers and their approved
plots to each stage in the supply chain (dealers). It does to the level of the village dealer (the first
farmer facing dealer).
• This village dealer (farmer facing dealer) is the gatekeeper for EUDR compliant volume.
• They will be issued a list of farmers, and should be noting down deliveries and collections over a
certain time frame. This record should either be kept on site, or the processing factory can provide
means to collect and archive the data at the processing factory (e.g., providing carbon copy
capable receipts.
• As these village dealers sell volume downstream of the supply chain, the subsequent transactions
are supposed to reflect the exchange of EUDR volume. The identity of the farmer does not
necessarily have to be transferred along the supply chain (that would be an identity preserved
methodology or transactional traceability methodology), but there is strict segregation
throughout, and volumes will tally down the supply chain.

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Expected controls on Segregation
Stage Target Check Practical guidance (details)

Raw material reception EUDR compliant status of raw • There is a clear process to identify whether incoming raw material 1. Manage by supplier management
material are identified at originated from plots that are EUDR compliant. system (if some suppliers are clearly
reception. • There should be a clear list on site with EUDR compliant farmers, with designated 100% EUDR)
an appropriate way to identify farmers 2. Require that suppliers clearly mark
• Dealer should consult the list before purchase and farmer's name (e.g., EUDR compliant raw material shipments
on ID) tallies to the list. 3. Record of receipts of EUDR material
• Other systems could include EUDR approved farmers possessing an should be clearly differentiated in the
ID card/tag that is presented to the dealer raw material receiving section.
• Dealer records down transaction with the volume and date details.
Records should be maintained.

Raw material storage EUDR compliant raw material Cup lumps: Signage or labels should clearly state 'EUDR'.
warehouse are clearly segregated and • EUDR raw material should be segregated by physical barriers (bins) or
demarcated. held in containers. If no barrier (not recommended), material should Clearest method would be to dedicate
be at least 1m apart from other piles. permanent enclosures or warehouses to
• Clear signage and demarcation. Either (1) Designated locations (whole EUDR (so there is no risk of mixing).
warehouse or enclosures) with permanent signage, or (2) clearly
labelled temporary signage for designated bins.

Latex:
Dedicated EUDR latex tanks are required. These should be clearly labelled
and not used for non-EUDR latex.

Transport EUDR compliant raw material In the loading process, either the whole transport is EUDR rubber, or there
is not mixed with non- is appropriate segregation carried out (bundling / containers).
compliant material during
transport to next node (next Driver needs to know that the volume is EUDR (there should be an
dealer or factory) established system) (e.g., clear labelling with sign or placard, delivery slip
with stamp, tags on individual containers/nets/barrels). Other systems:
dealer informs the factory of the shipment : Picture of car plate over
whatsapp etc/ picture of whole shipment.

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Expected controls on Segregation
Stage Target Check Practical guidance (details)

Volume audits (quota Leakage risks are mitigated. • Regular reviews (annual / monthly) of the volume quota at various Processor should establish a regular timetable
audits) Checks to ensure farms are not nodes of checks.
selling in excess of their • Regular check on direct supplier / tier 1 level: each tier 1 should have a
theoretical yield. consolidated volume based on the total number of farmers registered
under the,
• Occasional checks on upstream nodes (e.g., checks of the paper
records at village dealer level to show that they are tracking purchases
from farmers and clearly indicating volume)
• Records of transactions can be either maintained in each dealer node,
or the processing factory could look to assisting the supply chain to
archive transactional records (e.g., by providing carbon copy receipt
templates)

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Segregation: Processing
TSR
Segregation within the factory:
reception, raw material storage,
process, finished goods storage
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Segregation of material within factory - TSR
Raw material Receiving Wet process (wash tank, Hanging shed or maturing
equipment machinery)
§Data is collected. EUDR §Line clearance before §EUDR rubber (crumb/blanket)
compliant Raw Material shall processing of EUDR compliant shall be segregated with clear
segregated and stored with rubber identification
clear identification §Inspect the line thoroughly §example: EUDR dedicated
before process can begin shed/space or minimum
distance from other
noncompliant source.

Pre shedder / dryer process Post dryer / Finish Product Storage

§Line clearance before processing §Line clearance before processing §EUDR compliant Rubber shall
of EUDR compliant rubber. of EUDR compliant rubber be keep apart from other
Records kept. •Inspect the line thoroughly Finish Product with clear
§Inspect the line thoroughly before process can begin identification
before process can begin •All finish product information
§Continuous dryer process with (unit pallet number, lot number)
segregation (gap/label) shall be documented.

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Segregation of material within factory
Segregation of raw material stage-
Receiving raw material
- Factory designates approved supplier based on their system. Arrival of EUDR compliant
material must be accompanied by proper labelling/identification/documentation.
- Record volume of receipt tagged to direct supplier in processor's
supplier management system (for internal tracking: e.g., information of RM source,
volume, date of purchase)
- Dedicated bin for EUDR compliant cup lumps/sheet with clear ID.
- Physical barriers are recommended to prevent mixing and outflow
- If put on open space, there should be extremely clear area designation to prevent
outflow/mixing: recommendations include: covering with canvas, and adequate
distance between piles (1-5m between piles depending on size of heap).

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Segregation of material within factory
Processing
- Batch processing shall be implemented for EUDR compliant rubber
- Line clearance shall be implemented before processing of EUDR compliant rubber
- Clearing - The physical removal of any raw materials from the previous process
that are necessary for the next process (washing tank, machinery equipment,
creper and others.
• Hanging Shed – EUDR rubber must be clearly segregation in the hanging shed.
Examples include: dedicated room/floor/section that is clearly labelled, or physical
distancing with labels (e.g., 1m gap). If there is a management board EUDR rubber
identification and movement should be noted on records

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Segregation of material within factory
Dry process (after dryer process)
• Clearing - The physical removal of any raw materials from the previous process
(from trolleys)
• Continuous dryer process should be clearly segregated as well. Some
examples running the dryer for only the EUDR batch, clear labels, demarcated by
trolley number, 1 trolley gap.
• Checking - A supervisor/quality manager is notified to inspect the line
thoroughly before the next scheduled process can begin. The date and time of line
clearance completion is documented.
• Packing line: in the case of where multiple drying lines feed into single packing
line, packing line must also ensure segregation. If possible a unique identification
mark should be provided on bales upon compression.
- All finish product information (unit pallet number, lot number) of EUDR compliant
rubber shall be documented

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Segregation of material within factory
Storage
- EUDR compliant Rubber shall be keep apart from other FG/NC etc. with clear
identification. Examples: markings on floor, traffic cones to demarcate area, and
include 'EUDR' label or signpost.

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Expected controls on Segregation
Stage Goal Check Practical guidance (details)

Raw material reception EUDR compliant status of raw There is a clear process to identify whether incoming transports 1. Manage by supplier management system (if
material are identified at reception. are EUDR compliant some suppliers are clearly designated 100%
EUDR)
Staff are clearly aware of the process 2. Require that suppliers clearly mark EUDR
compliant raw material shipments
3. Record of receipts of EUDR material should
be clearly differentiated in the raw material
receiving section.

Raw material storage EUDR compliant raw material are EUDR raw material is segregated by physical barriers (bins). If no Signage or labels should clearly state 'EUDR'.
warehouse clearly segregated and demarcated. barrier, material should be at least 1m apart from other piles.
Clearest method would be to dedicate
Clear signage and demarcation. Either (1) Designated locations permanent enclosures or warehouses to EUDR
(whole warehouse or enclosures) with permanent signage, or (2) (so there is no risk of mixing).
clearly labelled temporary signage for designated bins.

Wet process There is no mixing of EUDR and non- Option 1 Dedicated line(s) for EUDR rubber: The line is used
EUDR in the process (no purely for EUDR Rubber
contamination). Batch processing
follows clear guidelines. There is a strong line clearance process in between process of

Checks on timings (start, stop, checks), documentation from

supervisors that clearance checks were done (already part of ISO
9001/IATF requirements every time there is a product
changeover there needs to be a release)

Dryer/packing There is no mixing of EUDR and non- Changeover (for trolley): if there is a clear demarcation.
EUDR in the process Trolleys are clear of material for changeover
(no contamination). Batch Timing for line clearance (as indicated in supervisor records)
processing follows clear guidelines.

Storage No mixing occurs during storage. Clear areas or signposts. Staff can accurately identify specific Examples of marked areas: cones with white tape,
EUDR material is clearly segregated. areas allocated for EUDR material. All material in EUDR marked painted markings on floor, permanent signage
zones are indeed EUDR. with 'EUDR' label, clear removable signage with
'EUDR'.

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Segregation: Processing
RSS
Segregation within the factory:
reception, raw material storage,
process, finished goods storage
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Segregation of material within factory RSS
Raw material Receiving Wet process (either ) Smoking and grading

§EUDR compliant Raw Material §Line clearance before §Clear batch process (either
shall segregated and stored processing of EUDR compliant dedicated smoke oven or
with clear identification. If rubber clearly labelled racks)
latex, in a designated storage §Inspect the line thoroughly §Grading and packing should
tank, if unsmoked sheets, before process can begin follow batch process.
clearly segregated and labelled

Finish Product Storage

•All finish product information (unit §EUDR compliant Rubber shall be

pallet number, lot number) shall be keep apart from other Finish
documented. Product with clear identification

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Segregation of material within factory -RSS
Reception
• Refer to TSR process for data collection
• If latex: Either dedicated reception tanks or if no dedicated tanks, the
reception tank must be cleared (washed) before the receipt of EUDR rubber.
Arrange for each batch to be dedicated for EUDR/non-EUDR rubber.
• If USS: follow TSR recommendations for physical segregation. Designated bin and
physical barriers with clear labelling recommended.

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Segregation of material within factory -RSS
Wet process: Coagulation to sheets
• Typically multiple coagulation tanks/troughs, which can be filled dynamically from
either reception tank
• Ensure that coagulation tank is clear and washed, if previous use was non-EUDR
• Ensure that coagulation tanks with EUDR latex are clearly marked or identified
clearly on a management board.

Wet process: cutting, rolling and hanging:

• Batch-wise only, with clearance of line in between process
• Hanging: no mixing on hanging rack
• Trolley rack numbers should be recorded: Recommended that each smoking
process is for one type (EUDR) but if not, EUDR trolleys should be clearly identified.
• Grading: fully batch wise, unless there are very distinct lines.

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Segregation of material within factory -RSS
Audit checks
• Check records of line clearing with supervisor signature + time/date
• Clear labelling
• Staff area aware of batch process requirements
• At receipt of USS/latex they should have a record of receipts: to check this during
audit
• Refer to TSR table for more info

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Land tenure and legality

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 Operational Guidance
for EUDR in the Natural
Rubber Supply Chain

Chapter 3:
Land Tenure and
Documentation for
Smallholder Farmers
Note: This is a draft that is being made available
for public consultation. It is not final and is
subject to revision
Due diligence for land legailty
● Assess the practical state of producing countries’ efforts to formalize land tenure for
smallholders;
● Prioritize objective screenings of potential illegality (e.g., agriculture-prohibited
areas such national parks, wildlife reserves or other protected areas, or other
restricted-use areas defined by local laws). Particularly where producing countries
(a) currently lack structured or complete land registers, (b) are in the midst of
transition to more structured forms of land tenure, or (c) where key regulatory
bodies in producing countries have indicated general acceptance that smallholder
farmers may produce and sell rubber possessing customary and native land tenure
rights; and
● Where available, gather evidence of land tenure or customary rights through the
collection of documentation recognized by local authorities, or other evidence of
locally recognized land tenure.
 Identification of EUDR compliant farms:
Legality (annex B)
Country equivalent and description of governing laws /
Unified use rights
Type of document Controls / mitigation
class
Thailand Indonesia Cote d’Ivoire
Nor Sor 4 (N.S.4) –
Sertifikat Hak
Chanote, or full Certificat Foncier - Nil (as long as no internal
1 Land ownership Milik (SHM Title) –
land ownership Land Certificate conflict of laws in country)
Freehold Title
rights
Nor Sor 2 (N.S.2) – Hak Guna Usaha
Right for agricultural Temporary land (HGU) – Land Baux emphytéotique - Nil (as long as no internal
2
use rights Cultivation Rights Emplyteutic Lease conflict of laws in country)
reservations title
Surat Keputusan
Sor Por Kor 4 – 01
Kepala Desa (SK Land registration Provide second check
Village level (S.P.K 4-01):
3 Kepala Desa) – process varies greatly against illegal areas (e.g.,
document Agricultural Title
Village Chief’s by regions. protected area boundary)
Deed
decree
Customary right
Provide second
Also to consider Sor Kor 1 (S.K.1) – Hak Ulayat –
Customary Rights check against illegal areas
4 separately challenges Claim Certificate Customary Land
Holder (e.g., protected area
with protected are Rights
boundary)
designation
5 Other right (etc.)
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Example of how right-of-use can be queried

Q1: Does the farmer have land documentation?

- Yes
- No
If YES

Q2: What is the land documentation

- List of documentation from Annex B

Q3: Upload land documentation # or picture

- To specify minimum requirements
- If not available, provide list of options why, or provide and open field for more
evidence or alternative evidence: (e.g., held in custody)

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Example of how land tenure (including native
or customary land tenue) can be queried
Q1: Does the farmer have land documentation?
- Yes
- No
If NO, it may be helpful to collect further data related to native or customary
rights

Q2: Is there an indication of native or customary rights?

- Yes, village documentation or customary demarcation (e.g., land markings)
- Yes, >5 years of occupation
- Yes, >10 years of occupation
- Yes, >20 years or multigenerational occupation
- No

Q3: [open field] please indicate additional evidence

Such cases
Global to be cross
Platform checked
for Sustainable with
Natural protected/restricted area
Rubber analysis.
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