How does the Sup­ply Chain Act affect the rub­ber industry?

The SCA pre­scribes a num­ber of mea­sures to pre­vent eth­i­cal­ly ques­tion­able busi­ness prac­tices along the sup­ply chain. These essen­tial­ly include the issuance of a pol­i­cy state­ment, inter­nal risk analy­ses, sys­tem­at­ic risk man­age­ment, the estab­lish­ment of a com­plaints pro­ce­dure, and doc­u­men­ta­tion and report­ing to third-par­ty bodies.

Imple­ment­ing pre­ven­tion and doc­u­men­ta­tion mea­sures on an inter­nal lev­el is read­i­ly achiev­able for most large and medi­um-sized rub­ber pro­duc­ers as well as their cus­tomers. They can also man­age the mon­i­tor­ing of direct sup­pli­ers with man­age­able effort, espe­cial­ly if they are based in the EU and thus oper­ate with­in the same legal framework.

The real chal­lenge is the mon­i­tor­ing of indi­rect sup­pli­ers, i.e. Tier 2 and high­er. The most impor­tant grow­ing areas for rub­ber are in Thai­land, Indone­sia and Viet­nam. In most cas­es, the har­vest is done by hand by small farm­ers who sell their goods to local mid­dle­men. These struc­tures pre­vent Euro­pean com­pa­nies from exert­ing direct influ­ence on rub­ber min­ing. There are no cen­tral actors with whom they can inter­act. Main­tain­ing con­tact with a large num­ber of small farm­ers over such a long dis­tance is sim­ply not practical.

Under such con­di­tions, mon­i­tor­ing the entire sup­ply chain is hard­ly pos­si­ble for small and medi­um-sized rub­ber pro­duc­ers. Instead, it is con­ceiv­able that inter­na­tion­al indus­try asso­ci­a­tions could inspect sup­pli­ers on site and issue cer­tifi­cates that com­pa­nies could refer to. In this way, Euro­pean pro­duc­ers could out­source part of their super­vi­so­ry duties and thus reduce their expens­es. The extent to which this approach sat­is­fies the require­ments of the SCA remains to be seen.