CLECAT SUBMITS COMMENTS ON DRAFT ESRS
Today, CLECAT submitted its feedback to the European Commission on the draft delegated act setting out the first set of European Sustainability Reporting Standards (ESRS), for the implementation of the Corporate Sustainability Directive (CSRD).
CLECAT recognises the effort made by the Commission to make the standards more practical, reducing non-added value reporting by introducing materiality assessment, thus reducing administrative burden. We also welcome the longer phase-in for some reporting requirements, allowing companies to get acquainted on certain specific standards before full reporting later. Finally, we welcome the changes brought by the Commission in order to ensure a high degree of interoperability between the ESRS and the international standards, allowing for better comparability at global level.
However, simplification is still necessary especially with regards to value chain and workers (especially for SMEs in the value chain): As many SMEs will be tasked to provide data to bigger companies subject to reporting requirements (especially transport companies as their subcontractors), it is important that the Commission also provides guidelines and support to SMEs, also not in the scope of the CSRD.
CLECAT also suggests recognising the ISO 14083 standard (Greenhouse gases — Quantification and reporting of greenhouse gas emissions arising from transport chain operations) as a proper methodology to calculate and report GHG emissions from transport operations (both upstream and downstream). CLECAT has been supporting a uniform, harmonised and transparent methodology to calculate CO2 footprint across the logistics supply chain, notably via its membership to the GLEC Framework and the development of the ISO 14083 standard. In addition, a full alignment with the upcoming Commission initiative on a harmonised framework for the calculation and reporting of transport emissions – so-called “CountEmissions EU” – is necessary to ensure clarity for transport operators in the EU legal framework regarding the reporting of transport emissions.