The Thai Rubber Association (TRA) has been following up on the progress of the EU regulation on deforestation-free products. The products exported from Thailand that may be affected include rubber, wood, cattle, cocoa, coffee, palm oil, and soy. Rubber and rubber products will be the most affected, as the value of Thailand's exports to the EU exceeded 1,700 million USD in 2022.

The essence of the regulation on deforestation-free products is that it requires operators to use mandatory due diligence throughout the production process to ensure that it does not contribute to deforestation or forest degradation by being able to locate the geographic coordinates of the plantation area that is the source of product production. Furthermore, the EU has set examination guidelines using a combination of geolocation and satellite images. In addition, plantation data is needed to be used to analyze and assess risks in the supply chain. The regulation is set to be adopted and enter into force by June or July 2023. However, operators will have 18 months after the regulation comes into force to prepare to comply with the requirements (Department of Trade Negotiations, 2023). Non-compliant operators will be subjected to fines proportional of damage to the environment and product value, not less than 4% of the operator's annual income in the EU. However, the EU still lacks clarity on the details of the measures; moreover, the information is not being distributed thoroughly. In addition, third countries exporting goods under the scope of the regulation have raised concerns about the negative impacts on the producing countries as it may cause trade barriers and inequality between imported and manufactured goods in the EU. Furthermore, it burdens the verification mechanism, biased risk assessment, cost for attribution, and inadequate transition periods (Office of Commercial Affairs, Royal Thai Embassy, Brussels, 2023).

As for Thailand, the Thai Rubber Association (TRA) has received news that representatives from the EU are confident and appreciate the handling of Thailand's rubber data for supporting the regulation. The Rubber Authority of Thailand (RAOT) has been collecting data to register rubber farmers, rubber farmer institutes, and rubber entrepreneurs in the information system of RAOT, which currently has more than 90% of Thai rubber farmers registered. The system can display the type of legal document and identify the location of the rubber plantation, which RAOT has surveyed and prepared a map of the plantation coordinates to verify the location of the plantation that does not encroach on forests by comparing with the conservation forest maps of Royal Forest Department of Thailand and Global Forest Watch. In addition, RAOT has partnered with the private sector to assess risk management under the "Rubber Way" project to assess and build a social and environmental map of the value chain, which is the Sustainable Development Goals (SDGs) (Rubber Authority of Thailand, 2023).

The Thai Rubber Association (TRA) will keep following up on the progress of the EU regulation on deforestation-free products and the EU environmental, trade, and other relevant laws to notify our TRA members and all stakeholders in order to prepare for the law that may affect the export of rubber and rubber products to the EU. Furthermore, it is to raise the level of Thailand's environmental standards in a holistic approach for both economic and environmental sustainability for the future.

Mr. Chaiyos Sincharoenkul

President

The Thai Rubber Association