Sustainability

regulation outlook
2024
Leveraging EU regulation to conquer sustainability
reporting, drive decarbonisation and prevent greenwashing
ARTICLE • 40-MIN READ
Time is running out to act on climate change. In Europe, the transition to a lower
carbon and more sustainable society is reshaping the economy, creating new
opportunities, and altering the cost of doing business. For companies, the implications
are stark. Failing to become more sustainable will leave them vulnerable to the loss of
revenue and reputation, as well as to litigation and regulatory penalties.

Regulation is an important driver of these changes, and a critical consideration for

companies as they plan how to meet the commitments they have made to transition
their own businesses. 2024 will be a pivotal year for the roll out of sustainability-
related regulations. Several key sustainability initiatives will be finalised and EU
Parliament elections in June will determine the direction and level of ambition of the
next wave of the EU’s sustainability legislative activity. Our Sustainability Regulation
Outlook explores the most pressing developments in the year ahead and what these
mean for business strategies and operating models.

EMEA Sustainability Regulation Hub

 Visit the EMEA Sustainability Regulation Hub for more insights into
the expanding universe of European mandatory regulatory
requirements, voluntary codes and standards.

The EU’s response to the imperative on climate begins with enhanced sustainability
reporting and the EU Corporate Sustainability Reporting Directive (CSRD). For most
companies, work remains to be done to meet new reporting requirements in full. What
is more, sustainability reporting sits at the heart of the EU’s green strategy and the
information companies need to disclose draws on data and activities across the
organisation. CSRD can be exploited to generate change and efficiencies across other
regulatory-driven developments.

Beyond reporting requirements, our outlook highlights four themes for companies to
focus on this year.

Circularity is now a clear imperative. In 2024, companies should focus on

understanding what circular design means for their products and services, with EU
regulatory initiatives establishing requirements for product design, packaging and
packaging waste, the ability to repair products, and provisions on end-of-life waste
disposal, among other things. The focus on circular design can also create opportunity
for companies. For example, in sourcing secondary materials, designing products using
other companies’ waste, and providing repair services.

The EU is a frontrunner globally in shaping supply chain sustainability as part of its

strategy to decarbonise the economy. CSRD obliges companies to report not only on
their own operations but also their upstream and downstream supply chains. This
means companies must invest more resources in relationships with their suppliers and
integrate sustainability-related risk assessment into their purchasing decisions. Use of
rare earth metals, contributions to deforestation and relationships with companies
within countries with human rights abuses are amongst the factors companies need to
assess. The deforestation-free regulation, for example, prohibits the sale, import or
export of certain commodities unless it can be proven they are deforestation-free and
produced in compliance with the relevant legislation of the producer country.

Decarbonisation is the ultimate goal of many of the EU initiatives. CSRD will affect
most industries, obliging companies to track emissions and report their reduction
targets. The carbon border adjustment mechanism is one of many other relevant EU
regulatory initiatives. It makes it necessary to report emissions data on imported
carbon-intensive products such as aluminium, steel and cement, which will be taxed
on their carbon content from 2026. Buildings and real estate also present major
challenges. From 2024 the Energy Performance of Buildings Directive will seek to
ensure that buildings across the EU meet minimum energy performance standards. To
reach net zero, companies should look to invest in projects or take action to avoid and
reduce or remove from the atmosphere and store greenhouse gas (GHG) emissions.

Finally, to minimise their exposure to greenwashing risk, companies must ensure there
is no mismatch between what they say they are doing and what they are doing. The
EU Directive for Empowering Consumers for the Green Transition means that
corporate communications must change to avoid greenwashing. As from 2026, generic
phrases such as ‘green,’ ‘carbon neutral’, ‘biodegradable’ and ‘eco-friendly’ will no
longer be permitted. Companies will have to ensure that their environmental
messaging is clear and fully substantiated.

Companies need a plan of action that connects the moving parts on sustainability
across regulation and business strategy, and identifies opportunities for increasing
collaboration between finance, internal risk management and procurement
departments. Within this plan, companies can factor in what leading practice looks
like, the most effective way to manage and sequence the changes required and what
further changes to requirements are expected.

Sustainability reporting enters a decisive

phase
Sustainability reporting sits at the heart of the EU’s green strategy. Over the next few
years, the journey towards greater transparency of companies’ sustainability
credentials through disclosures will accelerate. The focus for companies in 2024 is to
address corporate sustainability reporting requirements. Significant effort and
resources will need to be dedicated to meet these requirements. The real opportunity
for companies from reporting requirements, however – and the longer-term
effectiveness of their approach – will come from looking beyond the compliance task
to consider the broader ramifications of the regulations across their entire business and
operating models. If positioned correctly, these projects can help drive a wider set of
changes to harmonise understanding of and embed a firm’s sustainability strategy
across the organisation. The European and international reporting landscape is
changing.

Now is the time that ambition for greater transparency needs to be put into practice.
In 2024, all eyes are on the CSRD and corresponding European Sustainability
Reporting Standards (ESRS). Even though the European Commission has reduced the
scope of the reporting burden in the short term, around 50,000 companies are
expected to publish data under CSRD – more than four times the number that
reported sustainability information under the Non-Financial Reporting Directive
(NFRD) that CSRD is replacing. For the largest companies the obligation, at this stage
with a requirement for limited assurance, begins as early as January 2025, for the
2024 fiscal year. The Commission plans to evaluate the shift from limited assurance to
reasonable assurance no later than October 2028.

CSRD has a material extraterritorial impact. Large companies headquartered outside

of the EU with listed equity and debt securities on an EU-regulated market are in
general also captured by the CSRD reporting rules. Further, subsidiaries outside of the
EU may need to provide sustainability information to parent companies based in the
EU, in addition to complying with disclosure requirements prescribed by the
jurisdiction in which they are incorporated.
Enhanced CSDDD due diligence rules will also come
into play
The Corporate Sustainability Due Diligence Directive (CSDDD) is a major piece of EU
legislation that will require large EU companies (those with a net global turnover of
over €150m and more than 500 employees) and large non-EU companies (those with
an EU-wide revenue of over €300m) to conduct environmental and human rights due
diligence across their operations, subsidiaries and value chains already from 2027. The
scope of the CSDDD will extend to more companies in the years to follow. We expect
the compliance burden the CSDDD presents to be significant, especially for companies
with extensive, international value chains. Consequently, the 2027 implementation
date is challenging. The requirements of the CSDDD are expected to dovetail with
CSRD and will also be the first piece of EU legislation that mandates companies to
adopt a climate transition plan. Companies should consider whether they are looking
at sustainability reporting holistically and understand the links between the CSRD and
other regulatory requirements, such as the CSDDD, or the EU Taxonomy Regulation
(EU Taxonomy).

Interoperability of European and international

standards is in focus for policymakers
Looking beyond the EU, international standards are also evolving. The International
Sustainability Standards Board (ISSB) is expected to build on the two standards it
published in 2023, with work underway on several topics: biodiversity, ecosystems,
and ecosystem services; human capital; human rights; and connectivity in reporting.

The ISSB has collaborated closely with the European Financial Reporting Advisory
Group (EFRAG) – the body responsible for creating the ESRS – to ensure that the ISSB
standards and ESRS are consistent as far as possible, and to avoid duplication in
reporting against both sets of standards. In 2024, EFRAG and the ISSB are expected to
publish a table showing how the standards align and where incremental disclosures
may be needed to meet both sets of standards. Several countries, including the UK,
have committed to adopting the ISSB standards.

Reporting on emerging topics

We expect clarity in 2024 on whether or how the finalised framework from the
Taskforce on Nature-related Financial Disclosures will be implemented in EU and
international reporting frameworks. We expect it to be incorporated into the ISSB. As
a result, companies may choose to focus on broader environmental issues beyond their
initial climate change disclosures and consider their capability to report on other
emerging topics such as biodiversity or circularity, among others.

Taxonomy reporting gains traction

The EU Taxonomy is a classification system that includes a reporting mechanism and
criteria for economic activities that can be considered as environmentally sustainable.
Article 8 of the EU Taxonomy requires companies in scope of CSRD to disclose
information on how and to what extent their activities are associated with
environmentally sustainable economic activities, considering metrics such as capital
expenditures (CapEx), operating expenses and turnover. This information will also be
subject to independent assurance as required by CSRD.

In 2024 companies affected by EU Taxonomy reporting rules should turn their

attention towards improving their data frameworks and data quality with the aim of
increasing over time their EU Taxonomy alignment. Further, they should consider how
to use the EU Taxonomy as a tool to design their transition plans. The quality of a
company’s transition plan could also have a direct impact on lenders and bond
investors’ assessments of the riskiness of a company from a transition planning
perspective. Beyond 2024, the EU Taxonomy sector coverage and list of sustainable
activities will be expanded, bringing more companies into scope.

The EU Taxonomy currently covers 13 sectors. Significant industries are missing,

among them agriculture. The sectors currently in scope include: Forestry;
Environmental protection and restoration; Manufacturing; Energy; Water supply,
sewerage, waste management and remediation; Transport; Construction and real
estate; Information and communication; Professional, scientific, and technical
activities; Financial and insurance activities; Education; Human health and social work
activities; Arts, entertainment and recreation. However, companies in sectors not
captured by the Taxonomy still have an obligation to report on their capital
expenditure if they have investments in activities included in the Taxonomy.
Looking beyond the EU, new taxonomies are proliferating globally, with varying
objectives and priorities, aligned with the characteristics of national economies.
However, the EU Taxonomy, as the most expansive and advanced framework, is often
seen as a source of inspiration for others. The UK, for example, is expected to align
with the EU Taxonomy, albeit with some revisions to reflect local economy
specificities. Companies operating globally should monitor the developments at
national level and the effect they may have on their business operations. The
International Platform on Sustainable Finance – a dedicated working group
comprising public authorities across the globe – is expected to promote best practices
and compare different taxonomies to identify opportunities for the mobilisation of
private capital towards environmentally sustainable investments and any obstacles.

What companies should do now

Sustainability reporting is more than a compliance exercise.

To respond fully to CSRD and the ESRS, companies need to consider how
implementing the reporting requirements extends beyond the immediate compliance
exercise and will drive broader changes to strategy, governance, operations, and data.
In particular:

• Embrace a strategic approach: There is no “one-size-fits-all” approach. A business

strategy that is both effective and cohesive should rely on the development of a
suitable data framework that supports sustainable transformation of the business. In
addition, a disclosure strategy embedding an understanding of the overall disclosure
landscape will help firms to plan. Finance is likely to lead these projects but other
parts of the business, such as procurement, accounting, legal, compliance,
communication and human resources, should be involved.

• Evaluate the governance structure: Companies need to ensure they run an

adequately resourced programme with appropriate governance in place, addressing

key dependencies between different functions and projects. This extends to
considering the relationship with boards of their subsidiaries that may need to sign
off consolidated sustainability reports, depending on the reporting strategy taken at
a group level. Given the broad impact of sustainability reporting requirements across
all sectors, the skills required are likely to be in short supply.

• Get ready for assurance and manage mis-reporting risks: If they have not done so,

companies should set up due diligence processes to identify and mitigate reporting
risks in their supply chains. A closer look into engagement processes with their
suppliers to ensure the transfer of information for reporting purposes is crucial.
Companies should also allow sufficient time to build their internal capacity and test
their assurance models. Investments made to upskill the organisation and embed
relevant KPIs in the management and control cycle will pay off.

Making circularity and circular design the

norm
Circularity is evolving rapidly, driven both by consumer demand and new regulatory
requirements. As recent research from Deloitte UK discusses, consumers are
increasingly focusing on the circularity of products and services and are changing their
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behaviour in many areas. Some examples of these behavioural changes are set out
below (Figure 3).

Most legislative actions proposed under the EU’s Circular Economy Action Plan have
now been published by the Commission. They have either entered into force or are
under consideration by the European Parliament and/or the European Council.
Companies are in a position where they must determine how the regulations affect
them and how best to prepare. For 2024 companies should focus on understanding
what circular design means for their products and services and how best to
incorporate new processes into their data and governance systems.

Linking regulatory priorities to business concerns

The flagship regulations within the Circular Economy Action Plan are expected to
enter into force ahead of the end of the current European Parliament this year. These
include the Ecodesign for Sustainable Products Regulation (ESPR), Right to Repair,
and Packaging and Packaging Waste (PPWR). The following table shows the expected
timeline for the setting of targets and application requirements, alongside the timeline
for CSRD.

What is the link between circularity

and CSRD?
Companies in scope of CSRD will have to report sustainability information using the ESRS
developed by the European Financial Reporting Advisory Group (EFRAG). ESRS 5 requires
companies to report on resources use and circular economy action plans. EFRAG has also
provided some detailed circularity metrics that could be used by companies. Further, sector-
specific standards will be adopted by the EU in 2026. Companies should focus now on creating
robust data frameworks that can be leveraged in future for detailed reporting as needed by
sector-specific standards.

Designing for circularity

ESPR will encompass a range of new product categories, including 12 end-use
products such as textiles, cosmetic products and detergents, and seven intermediary
2
products such as iron, steel and plastics, among others. The impact of ESPR on
companies’ core operations is therefore expected to be significant. Beyond specific
traceability elements, the requirements will directly affect products at all stages in the
value chain, including recyclability, the use of recycled contents, and durability. Also,
the legislative Right to Repair measure makes producers responsible for ensuring cost-
efficient repair services are available to consumers post-sale, to extend the product’s
3
life.

Together the regulations create new opportunities for companies throughout the
product life cycle, such as sourcing (and eventually scaling) secondary material or
components for production, designing products based on other companies’ waste
streams, and providing repair services. There will also be challenges. For instance,
creating a market for secondary materials may be difficult for some products due to a
lack of specialised recycling or of the ability to extract and reuse materials at identical
material compositions.

In early 2024 the Commission is expected to announce its priority product groups for
product-specific Delegated Acts (DAs) under ESPR. The Commission will refer to the
preliminary ranking provided by the Joint Research Centre for this product
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prioritisation. The ranking is reproduced below. Companies will need to stay abreast
of these developments to identify how their operations may be affected and focus on
data foundation and data governance policies that need to be in place.
Cross-sector partnerships
The new circularity requirements will oblige companies to make a systemic shift, away
from virgin materials to reliable, quality secondary materials for products and
packaging. To comply with the new requirements, companies could benefit from
assessing whether cross-sector or cross-value chain partnerships may ease the burden.
Such partnerships may include organisations from more than one sector, harnessing
the competencies of different organisations and sectors to help solve complex
challenges. Companies could, for example, assess whether such partnerships would be
viable to set up joint hubs where products of multiple Original Equipment
Manufacturers can be refurbished at reduced cost. Which segments of the value chain
will benefit best from such partnerships needs to be assessed.
Branding, positioning and marketing
PPWR requirements include targets for the use of specific quantities of recycled
content in different types of packaging products. These targets will rise progressively
over time. Companies will want to assess the quality and durability of new packaging
and market responses to it before scaling up production. This will be critical for
products where packaging is a differentiator that drives revenue.

Similarly, companies will need to ensure any green claims made for a new product can
be verified so that their marketing is in line with the requirements of the Green Claims
Directive and, more generally, avoids greenwashing. The Empowering Consumers on
the Green Transition Directive bans generic phases such as ‘green’ and ‘eco-friendly’
on packaging and in social media and advertisements.

The PPWR also aims to reduce the amount of packaging, promote reuse and refilling,
and prevent packaging waste. The regulation sets reuse targets, introduces mandatory
deposit return systems for plastic bottles and aluminium cans, and restricts over-
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packaging and use of unnecessary wrappings. Companies will need to consider how
they can create business and operating models that can incorporate packaging reuse
requirements and identify potential cost constraints in this transformation. Similarly,
for industries such as e-commerce, companies will need to assess how to reduce
packaging waste and design compact packaging for shipping.

End-of-life waste management

The EU Waste Shipments Regulation and targeted amendments to the EU Waste
Framework Directive harmonise Extended Producer Responsibility for textiles across
all EU Member States. These are expected to enter into force in 2024 and will set new
rules for the export of non-hazardous waste outside the EU and treatment of textile
waste inside it. As circular economy requirements oblige the use of recycled content,
linking waste recycling units with production units will be essential. These regulatory
developments will therefore be especially relevant to textile companies with
production clusters in third countries.
 Reviewing international plastic targets
Many plastic producers, packaging producers, brands and retailers have set ambitious targets
for 2025 to tackle the plastic in their packaging through the United Nations’ New Plastics
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Economy Global Commitment. Targets include: ensuring that 100% of plastic packaging is
reusable, recyclable or compostable; decreasing the use of virgin plastic in packaging based on
determined percentages; and increasing the share of post-consumer recycled content across all
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plastic packaging used.
As companies finalise the details of targets for their 2025 Global Commitment, they should keep
abreast of developments on the EU Waste Shipments Regulation. The proposed regulation
includes a ban on EU exports of plastic waste to non-OECD countries and phases out such
exports to OECD countries within four years of its entry into force. When implementing
strategies to meet their global commitment, companies will need to ensure that their
operational strategies are aligned with EU regulations.

What companies should do now

With myriad sustainability regulation requirements becoming applicable in the near
term, companies need to focus on the following for 2024:

• Identifying the design challenges: ESPR and the PPWR target companies’ core

products and services. Companies need to assess their readiness to transform to a

circular business model.

• Assess the impact of circular transformation on their business models: For

instance, the impact of new packaging rules on the product portfolio, logistics and
operations; or that of operational fees arising from packaging-related Extended
Producer Responsibility and Deposit Return Systems.

• Review data foundation and governance policies: Assess data and data governance

processes to identify how best to incorporate additional procedures. Investments in

technology to address traceability- and transparency‑related requirements, such as
the Digital product passport (DPP), may be needed. Once data gaps are identified,
 conduct an alignment exercise to determine ambition of transformation against
reporting and regulatory requirements.

• Improve baseline reporting for circularity data: Business and sustainability KPIs

need to be reconsidered to ensure that circularity is embedded. This will also help
companies report on the Resource Use and Circular Economy standard under the
European Sustainability Reporting Standards (ESRS E5).

• Prepare a road map for a circular transformation strategy: To go beyond

regulatory compliance and complement their business strategy, companies can use
metrics on the use of recycled material in production, assess the need to scale
sourcing of recycled material, and ensure the availability of reliable suppliers for
recycled materials.

Digital product passport

The DPP is a proposed tool for sourcing and sharing product-level data across a product’s life
cycle, including raw material sourcing, emissions footprint, and supplier information. While the
compliance timeline will vary by product group, it is expected that for all non-medical consumer
products placed on the European market, companies will require DPPs in the near-to-medium
term in order to do business in the EU.

Making supply chains sustainable and resilient

Supply chain disruptions, evident in particular during the COVID-19 pandemic and
recent geopolitical upheavals, coupled with high inflation and interest rate volatility,
are obliging companies to revise their approach to their supply chains. In 2024
companies also need to consider several EU sustainability policies and regulatory
initiatives that in future will be crucial to selling products or services in the EU market.
An integrated view of relevant regulatory developments can also unlock commercial
opportunities that might be missed if companies only have compliance in mind.
 What is the difference between a value
chain and a supply chain?
Value chain encompasses the full range of activities, resources and relationships a company
relies on to create its products or services, from conception to delivery, consumption and end-
of-life. The value chain includes upstream and downstream actors. Downstream actors are
distributors or consumers, among others, who receive products or services.

The supply chain comprises upstream actors only – providing components or services that are
used by a company in the development of its own products or services.

This definition of the value chain is based on the one included in the ESRS, which is aligned with
the ISSB and Global Reporting Initiative frameworks.

Sustainability regulation is shaping the future of supply

and value chains
The EU is a frontrunner globally in shaping supply chain and value chain
sustainability as part of its strategy to decarbonise the EU economy. The table below
provides an overview of the portfolio of regulations relating to companies’ supply and
value chains. Companies need to identify how these regulations apply to their business
and subsequently tackle them in an integrated way.
Realising synergies between corporate reporting and
supply chain data
In 2024 companies need to collect data across their operations, including their supply
chains, to comply with the reporting requirements under the Corporate Sustainability
Reporting Directive (CSRD).
 The link between CSRD and supply
chains
CSRD creates a requirement for companies to report on the sustainability of their activities. As
part of this, companies are required to report information on their own operations as well as
their upstream and downstream value chain, including supply chains. In order to be able to
satisfy these reporting requirements, companies will need to take a more comprehensive
approach to managing their supply chain than is typically the case currently. Companies will
need to dedicate significant resources to managing relationships with their suppliers, especially
those exposed to economic, environmental and/or social risks, and integrate risk assessments
into their purchasing decisions. In 2024, EFRAG will publish final guidance on how to navigate
value chain reporting and this will have an important bearing on supply chains.

Meanwhile EFRAG continues its work on voluntary reporting requirements for unlisted SMEs
(ESRS) and mandatory reporting requirements for listed SMEs, small banks and captive insurers
(ESRS) which will provide a cap on the information that can be required from SMEs by their
larger counterparts, subject to CSRD reporting requirements.

Data points linked to suppliers’ carbon and environmental emissions could help
companies respond to provisions in the ESPR, and the DPP within it. The DPP will
require companies to provide detailed product-level data across a product’s life cycle,
including raw material provenance, the carbon and environmental footprint and
supplier information. The new rules may become applicable as early as 2025 for
certain priority product groups that will be determined by the Commission in 2024.
Similar provisions are also present in the EU Batteries Regulation, which is already in
the implementation phase. Manufacturers of batteries or their components need to
improve the traceability of the materials used in their products and ensure actors along
the value chain can access ecodesign information relevant to them.

Critical raw materials and the green energy transition

The EU’s green energy transition is highly exposed to the risk of disruptions in the
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supply of selected materials and components. The upcoming Critical Raw Materials
Act (CRMA) aims to increase the resilience of EU supply chains for these materials. It
includes mandatory targets for companies sourcing strategic raw materials, according
to a list produced periodically by the Commission that considers the extraction and
mining, processing and refining, recycling and import dependence of these raw
materials. The provisions of the CRMA are particularly relevant for companies
operating in strategic sectors such as renewable energy, electromobility, energy-
intensive industry, digital, and aerospace/defence, as they may benefit from shortened
permit-granting procedures, relaxation of administrative burdens and easier access to
financing.

The EU’s Joint Research Centre has published a study that underpins the CRMA and
provides recommendations for companies on how to increase their supply chain
resilience.

“Meeting the EU’s ambitious policy targets will drive an unprecedented increase in
materials demand in the run up to 2030 and 2050. For example, in order to meet the
REPowerEU targets for 2030, for the permanent magnet needs of wind turbines
alone, EU demand for rare earth metals will increase almost fivefold. Lithium demand
for the batteries in electric vehicles will also increase 11 times. Looking to the 2050
horizon, in the high demand scenario, EU demand in all the explored sectors for raw
materials such as neodymium, dysprosium (the two main rare earths), nickel, lithium
and graphite is projected to increase 6, 7, 16, 21 and 26 times compared with the
9
current values, respectively.” - European Commission

Increased focus on due-diligence policies and

processes
The Deforestation-free Regulation does not include targets but rather goes one step
further and prohibits the sale, import or export of certain commodities unless it can be
proven they are deforestation-free and produced in compliance with the relevant
legislation of the producer country. There may be instances in which producer
countries are found to have poor governance or a lack of respect for human rights. In
such cases inadequate human rights frameworks or breaches of human rights must be
considered in the risk assessment phase of the due diligence and could contribute to a
risk of non-compliance, effectively prohibiting companies from placing the goods
concerned on the EU market.

The regulation will have a wide reach, particularly in the consumer industry, affecting
companies that sell into or export from the EU market products made or fed with
certain commodities, such as cattle, soya, rubber, wood, coffee, palm oil or cocoa. In
2024 the EC may extend the scope of the regulation by adding more commodities to
the list. Further down the line CSDDD will introduce rules requiring EU and non-EU
companies to conduct environmental and human rights due diligence across their
operations, subsidiaries and value chains. Companies will have to take measures to
prevent or mitigate any potential impacts they identify, as well as end or minimise any
real impacts. If companies fail to comply and damage occurs as a result they may be
held liable and face financial penalties.

Enforcement actions
According to CSDDD, civil society as well as trade unions and ombudsmen can
initiate civil proceedings on behalf of a victim, which means that companies may be
found liable for damage caused by their activities. Even though many legislative acts
that make up the EU Green Deal, including CSDDD, have yet to take effect, companies
are already having to contend with litigation risks stemming from comparable pieces
of legislation in France or Germany. The German Supply Chain Due Diligence Act,
applicable from 1 January 2023, has already resulted in a number of cases filed against
major global brands. If litigation materialises it may not only affect companies’ ability
10
to raise capital, but also their reputation and brand.

What companies should do now

Take stock of their supply chain

Prohibitions, limitations or targets embedded in the regulations discussed above will

require all companies in scope to evaluate their supply chains and will oblige some to
find new suppliers because their existing ones do not meet regulatory requirements.
For example, a supplier might be in a country with human rights abuses or poor
governance; or it might itself choose not to produce or sell in the EU because of
increased compliance costs. An understanding of the supply chain through this lens
will enable companies to plan.

Some companies may take a strategic decision to rely more on regional and less on
global supply chains, but the opposite choice might also be taken. A recent Deloitte
study found that global procurement is likely to return to favour in many companies
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in the next one to three years. The results suggest that companies aim to benefit from
the competitive price points and efficiencies a global supply chain can bring.

Notwithstanding their strategic choices, companies will need to ensure compliance

with the upcoming regulations. Changing corporate operations may be time
consuming and costly and companies should consider taking anticipatory steps before
the deadlines prescribed by regulators. This could help to lock in better prices or
secure business relationships with less vulnerable suppliers, reducing the risk of supply
chain disruption.
Develop a joined-up view of relevant regulatory
developments and take advantage of synergies
A thorough understanding of regulations at the EU and national level, as well as
potential divergences between countries, should underpin companies’ strategies.
Across industries we see an insufficient level of transparency between different actors
in the supply chain. Systems and processes to improve communication, and solutions
to gather, process and analyse data will pay off as they have the potential to identify
weak points in supply chains. Internally data needs to reach those who make key
decisions daily, such as procurement or supply chain officers.

Companies should therefore look into increasing collaboration and creating links
between finance, internal risk management and procurement departments to ensure the
adequate flow of information within the firm and along the supply chain. These
investments can lead to positive outcomes for a company’s reputation and translate
into positive stakeholder and shareholder impact. According to MIT’s State of Supply
Chain Sustainability 2022 report, 76% of surveyed business leaders across the globe
have reported moderate to very high pressures from investors to advance on supply
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chain sustainability.

Create a strategic supply chain engagement plan

As an immediate next step, companies could take a closer look at their engagement
with current suppliers to identify and mitigate (reporting) risks in their supply chains.
Establishing targeted partnerships with actors along their supply chains and the
introduction of incentives to reward desired outcomes may encourage behavioural
change more broadly.

Decarbonisation gaps and focus areas

Many companies have set decarbonisation targets and are now implementing
transition plans. They will have to make a sustained effort over a number of years to
meet their targets. In the EU, regulatory developments, changes to operating models
and market expectations within the field of decarbonisation are driving rapid change,
creating both opportunities and challenges. In 2024 the key priority for companies is
to ensure that they identify their Scope 1, 2 and 3 emissions, and have set emissions
targets and a comprehensive strategy, especially for the short term.

The decarbonisation landscape in 2024

In the past year the EU has taken action in key areas within decarbonisation, including
reporting under CSRD, carbon taxes, sustainable fuels, renewable energy, electricity
markets, buildings and green infrastructure, and carbon removals. Figure 8 provides
an overview of the timelines for the related regulatory initiatives.
Focus for decarbonisation in 2024 is CSRD
From all of the regulations driving decarbonisation in the EU, CSRD is likely to have
the most significant impact in 2024 across industry sectors (except government and
public services). Among the activities to address under CSRD are emissions tracking
and reporting on emission-reduction targets, if these have been set. Companies need to
ensure that they are actively reducing their carbon emissions across their entire value
chain to meet their shorter-term targets (2025 and 2030). They will also need to be
confident that their medium-term (2040) and long-term (2050) plans meet the
expected carbon reduction trajectory, aiming to keep within the 1.5 °C global
temperature rise target.

Implications of CSRD for decarbonisation

CSRD creates a requirement for companies to report on the sustainability of their
activities. Some of the key implications of decarbonisation are:

• Companies need a track record of emission reductions. They should ensure they

are actively reducing their carbon emissions across the entire value chain and in line
with their disclosed plans. Given increased transparency, those that do not show
tangible progress are likely to be closely scrutinised by key stakeholders, including
customers, investors and financial institutions.

• Identify what needs to be reported and conduct scenario analysis. Under the

principle of double materiality (impact and financial materiality) companies should

assess which impacts need to be reported, as well as risks and opportunities. As part
of this process it is essential to understand the impact that current and upcoming
decarbonisation regulations may have on the company.

• Track and report Scope 1, 2 and 3 emissions. Starting for financial years beginning

in 2024 (with the first reports due in 2025), companies already reporting under
NFRD need to collect high-quality emissions data across their entire value chain.
(Reports on Scope 3 emissions are not required in the first year for companies with
fewer than 750 employees).

Priority areas for carbon emission reductions

Raw materials and renewable fuels: the EU has adopted regulation in key
harmonisation areas, including taxes and renewable fuels, to tackle industrial
emissions. For example, under the carbon border adjustment mechanism, the EU
started to gather emissions data on imported carbon-intensive products such as
aluminium, steel and cement in order to tax them, starting from 2026, on their carbon
content. The EU Emissions Trading System (ETS) was also expanded to cover
maritime transport from 2025 (for emissions reported in 2024) by reducing free
allowances for the sector from 2026, with a total phase out in 2034. On sustainable
transport fuel the EU has adopted the ReFuelEU aviation and FuelEU maritime
regulations. These two regulations create obligations for aircraft and shipping vessels
to use a minimum of two percent of sustainable fuels from 2025, increasing to 70%
and 80% respectively in 2050.

New energy efficiency standards for buildings: In 2024 the Energy Performance of
Buildings Directive (EPBD) will enter into force. The EPBD seeks to ensure that
buildings across the EU meet minimum energy performance standards, with the aim of
having a fully decarbonised building stock by 2050. This is an important development
as emissions from buildings represent over 36 percent of total energy-related emissions
13
in the EU. A further challenge for companies is that standards for public charging
still need to be developed. The Alternative Fuels Infrastructure Regulation (AFIR) calls
for the rapid development of European standardised procedures for recharging and
refuelling infrastructure to support planning, tendering, and building.
The big challenge in real estate
Decarbonising the real estate sector is essential for the EU to achieve its carbon
reduction ambitions. The implications of the EPBD for building owners will be
significant since the scope of the directive includes commercial, public and residential
buildings. Due50 bn to the EPBD’s reliance on national measures, building owners
operating across the EU will need to navigate local regulations to ensure that any new
or existing buildings comply with the required energy standards. For non-compliant
buildings companies will need to conduct an assessment of the upgrades needed. A
further consideration is the interaction with regulations such as the new Renewable
Energy Directive (RED III) or AFIR which will require the deployment of solar energy
capabilities, pre-cabling and charging points for EVs.

The real estate sector will need to rethink and adjust its investment strategy and
processes to increase value by taking into account not only new regulatory
requirements but also market expectations and the resulting new capital expenditure
needs. Achieving significant emissions reductions from buildings will be essential not
only to support the sector’s own decarbonisation goals, but also to respond to the
expected launch of the European Union Emissions Trading System (EU ETS) for
buildings in 2027.

By starting to act now, capital expenditures could be allocated over a longer period,
reducing the financial impact. This could also reduce potential risks, such as
abandoned assets, or the loss of value if required standards are not met. Three key
questions companies need to ask themselves are: do they fully understand the
requirements imposed by the EPBD at the national level and the capital needed to
retrofit buildings and deploy the required technologies? Are building materials with a
lower carbon footprint being sourced for new buildings and retrofits? What is the
current energy mix used for the building and can it be switched to renewables?

A push towards electrification, driven by renewable

energy and green infrastructure
One of the major initiatives recently adopted by the EU was RED III, which seeks to
raise the share of renewable energy consumption 42.5% by 2030. The EU is currently
well below this target (Figure 10).

Under RED III, EU Member States need to contribute to the 42.5% goal by setting
sector-specific targets:

• For transport, Member States can select between a 14.5% reduction in GHG

intensity or at least 29% of renewables use.

• For industry, renewable energy use should increase at a rate of 1.6% per year.

• Buildings should obtain at least 49% of their energy from renewable sources by

2030.
To increase renewable energy production, RED III seeks to accelerate the granting of
permit processes for fast-track deployment and will consider renewable projects to be
of ‘overriding public interest’. This means that approvals for new renewable energy
plants and the connections to those plants, the grid or storage could be fast-tracked.

At present, the EU needs almost 600 GW of solar PV capacity and over 500 GW of
wind capacity to reach its climate change targets. This implies a need to add 48 GW of
14
solar PV and 36 GW of wind capacity annually between now and 2030.

RED III will interact with the EU Reform of the Electricity Market Design initiative,
which seeks to offer protection to consumers and producers to boost renewable
energy. Consumers will have the right to multiple contracts, including forward
contracts that lock in future prices. Power Purchase Agreements will be promoted to
protect against price volatility and boost investment in renewables. There will be
public support for renewables through two-way Contracts-for-Difference to provide
power producers with price stability and shield industry from price volatility. Member
States will be encouraged to channel excess revenues to consumers.

The EU aims to reduce transport-related GHG emissions by 90% by 2050 compared

with 1990. Zero-emission vehicles, mainly electric vehicles (EV), are central to
achieving this, but the infrastructure for transmission, capacity enhancement and
charging must also be widely available. EU estimates identify a need for three million
15 16
charging points by 2030 – the current number is less than 500,000. The entry into
force of the AFIR seeks to address this by setting binding deployment targets in EU
Member States for recharging stations for cars, vans and heavy-duty vehicles, as well
as for hydrogen refuelling. The requirements also apply to maritime ports and
airports. The timeline to deploy the targets begins in 2025, with fast charging stations
for cars and vans, and the supply of electricity for stationary aircraft at all gates, and
extends until 2030, when all the infrastructure prescribed in the regulation will need to
be deployed. Member States are required to report to the European Commission how
they plan to implement the regulation and report progress by 31 December 2024.
There is therefore likely to be growth in green infrastructure deployment, especially for
charging points. In 2024 companies, property owners, public sector authorities,
maritime ports and airport operators need to monitor how standards are being
implemented by Member States and then begin to consider how they are going to
provide charging infrastructure in their own facilities.

New opportunities in carbon removals

At present carbon emitters in mandatory compliance markets such as the EU ETS have
only been able to purchase carbon credit allowances to count toward the holder’s
GHG emissions. Carbon emitters have also been able to purchase carbon credits in the
Voluntary Carbon Market (VCM) to offset their own emissions, especially those that
are unavoidable. The main distinction between carbon credit allowances from the EU
ETS and carbon credits from the VCM is that the latter have not been legally
recognised by the EU. This is mainly due to the lack of mandatory rules to monitor,
report and verify carbon removals within the EU for voluntary projects.

In 2024 the EU is expected to approve the Carbon Removal Certification framework,

the first EU-wide voluntary initiative to certify high-quality carbon removals. The
framework includes carbon farming (for example, forest and soil restoration and
wetland management), permanent storage (for example, direct air capture and storage)
and carbon storage in long-lasting products and materials (wood-based construction)
but excludes carbon capture and storage or carbon capture utilisation. Based on the
framework, certification methodologies will be developed for each carbon removal
activity. These activities will then be certified by a third party and the removals will be
recorded in a publicly accessible central registry.

This framework is likely to change the voluntary carbon market (VCM) dramatically
in years to come, as it will counter greenwashing and build trust by ensuring that
projects are of high quality and removals are quantified, monitored and verified. This
means that in the medium term companies will be able to use carbon removals as part
of their overall decarbonisation strategy to reach net zero.

Public policy challenges

To support the transition there are still three areas where further work is needed by
regulators, standard setters and the industry: funding gaps, emissions accounting
challenges and mitigating emissions beyond a company’s own value chain.

Funding gaps
The European Commission estimates that €1.25 trillion will need to be spent by 2030
17
to meet the EU’s climate and energy security investment needs. This estimate
represents an increase of over 65% from the past decade and is expected to come from
18
the private sector, including firms and households.

An example is the EU’s Net-Zero Industry Act which seeks to achieve at least 40% of
its annual green technology needs by 2030. These technologies include solar, heat
pumps, onshore and offshore renewable technologies, battery and energy storage
technologies and carbon capture and storage. The EU has €250bn in funding available
for green measures under the Recovery and Resilience Facility (RRF) and can mobilise
19
over €370bn under InvestEU for net-zero investments. But the EU has made it clear
that the greater part of the required investments will need to come from private
20
funding.

Emissions accounting challenges

A significant issue is data accuracy and harmonisation, the lack of which hinders
comparability of targets and emission reductions data for Scopes 1, 2 and 3.

Companies in the technology sector have on average 125 tier one suppliers and more
than 7,000 across the whole value chain. In the auto industry the value chain is even
more complex, as an auto manufacturer can have 250 tier one suppliers but up to
21
18,000 suppliers across the entire value chain.

For Scope 3 in particular, the issue becomes more complex when companies have
global supply chains. Suppliers in some developing countries have limited access to
renewable energy and alternative fuels, preventing them from significantly reducing
their Scope 1 and 2 emissions. There is a need to find ways to account for these
emissions while working with suppliers and stakeholders to reduce them.
Looking beyond value chain mitigation
To be able to reach net zero, companies should look beyond their value chain by
investing in projects or conducting actions that avoid or reduce GHG emissions,
including those that remove GHG from the atmosphere or store them. These
investments or actions could then be reported by companies as part of their overall
decarbonisation strategy. Looking beyond value chain mitigation (BVCM) is relevant
for companies as once they have reached the point at which they cannot reduce
emissions within the value chain any further (due to cost or technological
effectiveness), the only option is to invest in projects that can reduce the remaining
emissions. To make BVCM feasible the Science Based Target Initiative is planning to
publish guidance in 2024 on minimum benchmarks for credibility and best practices.

The implication of BVCM’s guidance is that companies, especially those from hard-to-
abate sectors, can help maximise climate mitigation and support the UN’s Sustainable
Development Goals.

What companies should do now

Plan to make significant carbon emission reductions across the value chain

• Identify emissions, set targets and have a comprehensive reduction strategy in

place, with emission reduction targets for 2030, 2040 and 2050.

• Establish for the medium term (2030) a clear annual CO2 pathway with

milestones, correlated to the projected business growth and emissions trajectory.

Quantify the costs of implementing the strategy and evaluate how it will be financed,
taking into account carbon price uncertainty.

Reduce their carbon footprint in raw materials, fossil fuels and buildings

• Ensure they have carbon footprint data for their key raw materials and identify

lower carbon alternatives to reduce potential carbon taxes and improve the
company’s emissions record.
 • Reduce consumption of fossil fuels in fleets by increasing use of alternative fuels or

switching to zero emission alternatives. Engaging with suppliers of low-carbon

transportation options is another alternative.

• Put in place a plan to quantify and reduce building emissions by conducting

retrofits and deploying green technologies. Companies also need to understand the
energy mix of buildings, fully switching to renewables and ensuring that low carbon
materials are sourced for retrofits or new construction.

Focus on electrification, renewables and green infrastructure

• Companies should assess all feasible electric solutions. These solutions include the

deployment of charging points for EVs, shore-side electric installations for vessels at
ports, electricity supply for aircraft at airports, and the replacement of fuel-power
equipment with fully electric options.

• The switch to electric requires the use of a 100% renewable energy supply to fully

achieve environmental benefits.

• Companies can deploy wind and solar technologies to produce their own

electricity on-site and negotiate long-term contracts for renewable energy supply
with utility providers.

Averting greenwashing risks

Companies are responding to the green transition in different ways, from innovating
their business models and working with new partners in the value chain, to marketing
their environmental credentials and linking variable pay to sustainability goals. At the
same time, investors, customers and wider civil society are increasing their
expectations of companies where the green transition is concerned. To minimise their
exposure to greenwashing risk, companies must ensure there is no mismatch between
what they say they are doing and what they are doing.

Change needed in B2C communications

In 2024 the EU will finalise the Directive for Empowering Consumers for the Green
Transition. The European Commission proposed the Directive in March 2022 to
introduce specific rules to tackle unfair commercial practices that mislead consumers
and may prevent them from consuming sustainably. The Directive amends the EU’s
Consumer Rights Directive and Unfair Commercial Practice Directive. By defining
which B2C communications should be banned or considered misleading, the Directive
will provide greater clarity on how companies can market their environmental
performance. Once the rules enter into force in the first half of the year the EU will
become a global leader in regulating companies’ environmental claims. Every industry
will be directly affected by the Directive unless it has existing or upcoming rules
governing environmental claims made voluntarily to customers. Financial services
firms are excluded from the scope of both Directives.

After the Directive for Empowering Consumers for the Green Transition is finalised
and enters into force, EU Member States will have 24 months to transpose the
requirements into national law. From 2026 companies will need to ensure that any
environmental messages or representations made voluntarily about their products,
brand and organisations that imply a neutral, positive or reduced environmental
impact are clearly and accurately substantiated. Common generic phases, such as
‘green,’ ‘carbon neutral’, ‘biodegradable’ and ‘eco-friendly’ will be banned across
packaging, social media posts and advertisements. Companies providing sustainability
labels will also need to ensure that their schemes meet minimum conditions of
transparency and credibility.

The EU Green Claims Directive combats greenwashing by setting out new

communication, substantiation and verification criteria that companies must meet
when devising and marketing their environmental claims to customers. The European
Commission proposed the Green Claims Directive in March 2023, but lawmakers are
now not expected to progress on the Directive until after the 2024 European elections
We expect the rules to enter into force at the earliest in 2025, and to apply from 2027.
We wrote about the Directive in more detail in our 2023 Sustainability Regulation
Outlook.
Heightened litigation risk and regulatory scrutiny
Companies should not only consider new regulations when assessing the regulatory
environment around greenwashing. Action by advertising or competition authorities,
or litigation by investors and civil society, may also generate greenwashing risk,
possibly sooner than new regulations. Consumer-facing industries, especially those
selling and advertising more frequently purchased and essential items, are more likely
22
to experience these impacts. Advertisers and organisations marketing products,
services and brands online will also be particularly affected.

In recent years there has been an increase in allegations of greenwashing that have
materialised in legal action (Figure 11) and in complaints to supervisory, advertising
and oversight authorities (see case study below). Claims have been based on alleged
misrepresentation and breaches of responsible advertising or fair competition
legislation or standards, as well as accusations of fraud. The financial and reputational
23
consequences of these actions can be severe, including on share prices.

We expect litigation and supervisory sanctions to continue as more stringent

sustainability regulations emerge, clarifying and increasing the obligation on
companies to be transparent and accountable. In response companies may be tempted
to stop making any environmental claims. But remaining silent may increase exposure
to accusations of ‘greenhushing’, inviting further stakeholder scrutiny.
Corporate sustainability reporting
Companies across all industries also need to consider greenwashing risks in relation to
the new corporate sustainability reporting requirements, most immediately CSRD.
Drawing together information on more aspects of their sustainability activities and
strategy, companies are more exposed to poor quality or misleading data, including
data provided by third parties in the supply chain.

Companies can achieve efficiencies in their implementation of CSRD and

greenwashing regulations through use of the combined data requirement, as the box
below explains.
CSRD synergies can be used to achieve cost efficiencies. The CSRD requires companies to
report information that can enable their stakeholders to understand a company’s impact on
sustainability matters, as well as how sustainability matters affect the company’s development,
performance and position. Information must be reported in line with the European
Sustainability Reporting Standards (ESRS). The CSRD intersects with greenwashing risk,
creating scope to realise costs efficiencies. For example:

Responses to CSRD, the Directive for Empowering Consumers and the Green Claims
Directive can be integrated if companies form organisational-wide policies on how to
gather, analyse, use and review data for all sustainability communications. Data
collected, processed and assured for companies’ sustainability reports can then be used
to substantiate companies’ B2C environmental claims. This could range from information
gathered on water consumption under ESRS E3 to the materials used to manufacture
products under ESRS E5, which in turn can help determine a product or organisation’s
environmental impacts and performance.

Double materiality assessments can be used to inform companies of their customers’

sustainability preferences. This information can be fed into brand strategies and help
reveal which target segments companies should market their environmental claims to,
and how to do so.

A joined-up regulatory response can streamline companies’ efforts to implement new

governance. systems and ultimately instil the cultural change needed to ensure all
sustainability messages can stand up to scrutiny.
Balancing short-term compliance costs against longer-
term strategic gains
According to the European Commission’s impact assessment accompanying the
Directive for Empowering Consumers, companies are expected to spend up to
€3.1billion to remove unfounded claims from packaging and online messaging and to
24
adapt their systems and processes to substantiate their environmental claims. The up-
front costs of designing and implementing the processes needed will be high.
Meanwhile, organisations providing sustainability labels are expected to incur costs of
up to €3.5billion to implement changes to their internal processes. Manufacturers and
sellers using sustainability labels will need to ask themselves whether they are ready
when these costs are passed on.

Companies can avoid last-minute disruption and reduce compliance costs by starting
the compliance process now. By acting early they can more fully understand how to
leverage processes and controls, identify internal skills gaps, and roll out tailored
upskilling programmes. They can also conduct peer analysis and determine levers to
differentiate themselves from their competitors and begin to integrate new insights into
strategic decision-making.
The scale and cost of the compliance challenge is likely to be considerable. But the
investment not only reduces the risk of penalties for infringement, but also provides
companies with greater agility to access sustainability-related market opportunities in
the future.

Unlocking wider value

Investing in the changes required to meet the upcoming rules will not only enable
companies to address greenwashing risks but also support their wider sustainability
efforts. This includes the actions companies need to take to gather sustainability data
and reshape their branding and market positioning.

By considering how to leverage their response to CSRD to generate efficiencies and

share costs, companies can also develop a consistent process for devising,
communicating and tracking environmental performance across the organisation –
from their management reports and analyst updates to marketing brochures and social
media posts. Companies’ communication on environmental performance can in this
way be lifted to the same level of rigour and trust as their market sensitive and
financial information. This will put them in a good position to meet future
requirements under the Green Claims Directive.

What companies should do now

• Review the accuracy of sustainability data: Review the sustainability data

underpinning the company’s environmental claims, as well as any associated metrics

or targets. Data limitations (for example, in terms of quality or availability) should
be identified and either rectified or fully disclosed.

• Review and test messaging: Review B2C environmental communications and test

the messaging with customers to check if it is clear and well substantiated. This step
will enable companies to devise or refine messaging guidelines and update supplier
codes of conduct. Companies may also need to brief advertising or PR agencies, and
update any corresponding scopes of work as well as contracts.
• Embed greenwashing risk within governance frameworks: It is vital for companies

to update their governance processes to support a wider organisational commitment

to managing greenwashing risk. Companies can review existing roles and
responsibilities, develop management information, and amend executive
remuneration to create appropriate incentives and accountability, as we have
25
outlined previously.
Glossary

Abbreviation Meaning

AFIR Alternative Fuels Infrastructure Regulation

BVCM Beyond value chain mitigation

CapEx Capital expenditures

CRMA Critical Raw Materials Act

CSDDD Corporate Sustainability Due Diligence Directive

CSRD Corporate Sustainability Reporting Directive

Das Delegated acts

DPP Digital product passport

EFRAG European Financial Reporting Advisory Group

EPBD Energy Performance of Buildings Directive

ESPR Ecodesign for Sustainable Products Regulation

ESRS European Sustainability Reporting Standards

EU ETS European Union Emissions Trading System

GHG Greenhouse gas

ISSB International Sustainability Standards Board

NFRD Non-Financial Reporting Directive

PIE Public interest entities

PPWR Packaging and Packaging Waste

 RED III Renewable Energy Directive

RRF Recovery and Resilience Facility

SME Small to medium-sized enterprise

VCM Voluntary Carbon Market

BY Simon Brennan Ramon Bravo Gonzalez

United Kingdom United Kingdom

Magda Puzniak-Holford Ruth Kilsby

United Kingdom United Kingdom

Adithya Subramoni
United Kingdom
Endnotes

1. Deloitte, “What consumers are doing to adopt a more sustainable lifestyle –

Sustainable Consumer 2023”, 2023.

View in Article

2. Joint Research Centre, “Eco-design for Sustainable Products Regulation (ESPR)

– preliminary study on new product priorities”, European Commission, 2023.

View in Article

3. European Commission, “Rules promoting the repair of goods,” 2023.

View in Article

4. Joint Research Centre, “Eco-design for Sustainable Products Regulation (ESPR)

– preliminary study on new product priorities.”

View in Article

5. European Commission, “Proposal for a revision of EU legislation on packaging

and packaging waste,” 30 November 2022.

View in Article

6. United Nations Environment Programme, “The new plastics economy global

commitment,” accessed 8 February 2024.

View in Article

7. The Ellen MacArthur Foundation, The Global Commitment 2022 report, 25

October 2022.

View in Article

8. Samuel Carrara et al., “Supply chain analysis and material demand forecast in
strategic technologies and sectors in the EU – A foresight study,” European
Commission, 16 March 2023.

View in Article
 9. Ibid.

View in Article

10. European Centre for Constitutional and Human Rights, “Ten years after Rana
Plaza: Workers submit complaint,” 2023.

View in Article

11. Deloitte, Navigating the headwinds – Enhancing agility to regain momentum,

2023

View in Article

12. Council of Supply Chain Management Professionals, State of supply chain

sustainability 2022, MIT Centre for Transportation & Logistics, July 2022.

View in Article

13. European Commission, "Commission welcomes political agreement on new

rules to boost energy performance of buildings across the EU,” press release, 7
December 2023.

View in Article

14. European Commission " Joint statement by the Director-General of the

International Renewable Energy Agency La Camera and EU Commissioner
Simson: ‘The time for speeding up renewables is now’,” 30 March 2023.

View in Article

15. European Commission, “Mobility strategy,” 2021

View in Article

16. Servet Yanatma, "Access to EV charging stations in Europe is 'a significant

concern'. How do countries compare?,” Euronews, 18 September 2023.

View in Article
17. Laurent Abraham, Marguerite O’Connell, and Iñigo Arruga Oleaga, The legal
and institutional feasibility of an EU Climate and Energy Security Fund,
European Central Bank, March 2023.

View in Article

18. Frank Elderson “Closing gaps to bend the trend: embedding the flow of finance
in the transition,” European Central Bank, 5 May 2023.

View in Article

19. European Commission, “REPowerEU,” 2022.

View in Article

20. European Commission, “InvestEU programme adopted by Council,” press

release, 17 March 2021.

View in Article

21. Michael Taylor, “EU endeavours to secure and strengthen its supply chain,”
MRS Bulletin 48, (2023): pp 441–446.

View in Article

22. Deloitte, “What consumers are doing to adopt a more sustainable lifestyle –
Sustainable Consumer 2023.”

View in Article

23. Misato Sato, Glen Gostlow, Catherine Higham, Joana Setzer and Frank
Venmans, Impacts of climate litigation on firm value, The Grantham Research
Institute on Climate Change and the Environment, May 2023.

View in Article

24. European Commission, “Impact assessment report: Accompanying the

document proposal for a Directive of the European Parliament and of the
Council”, European Commission, 30 March 2022.

View in Article
25. Rosalind Fergusson and David Strachan, “Building an effective culture to
support sustainability-related objectives,” Deloitte, 10 February 2023

View in Article

Acknowledgments

The authors would like to thank Ejona Haka and Camille Kessler for their
contributions to this article.

Cover image by: Mark Milward