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EU Compliance & Market Access
ESG Evidence
Connecting sourcing decisions to disclosure obligations — Scope 3 data, traceability, and audit-ready evidence chains.
Directive (EU) 2022/2464
CSRD & ESRS Reporting
The Corporate Sustainability Reporting Directive requires large EU companies to disclose sustainability information under European Sustainability Reporting Standards (ESRS).
- Phase-in timeline
- In force 5 January 2023. Reporting begins for FY2024 (large PIEs, 500+ employees), FY2025 (large companies), FY2026 (listed SMEs).
- ESRS 2
- General disclosures — governance, strategy, materiality assessment.
- ESRS E1
- Climate — Scope 1, 2, 3 emissions, transition plan.
- ESRS S2
- Workers in the value chain — covers supplier labour conditions, relevant for Thailand sourcing.
- ESRS G1
- Business conduct — anti-corruption, supplier relationships.
- Double materiality
- Companies must assess both financial materiality (risks/opportunities to the company) and impact materiality (company's impacts on people and environment).
- Assurance
- Limited assurance required from FY2024; reasonable assurance planned from 2028.
GHG Protocol — Scope 3 Standard
Scope 3 & Supplier Emissions Data
Category 1 (purchased goods and services) is typically the largest Scope 3 category for companies sourcing physical products. Supplier data collection is the core challenge.
- GHG Protocol Scope 3
- 15 categories. Category 1 covers upstream emissions from purchased goods and services.
- Calculation methods
- In order of preference: supplier-specific data, hybrid method, average-data method, spend-based method.
- Thailand → Nordics sea freight
- Approximately 0.8–1.2 kg CO₂e per kg cargo (GLEC Framework estimate, deep-sea container).
- Air freight multiplier
- Approximately 50–70× sea freight emissions intensity — relevant for high-value or time-sensitive pet food ingredients.
- ESRS E1 requirement
- Scope 3 disclosure required where material — Category 1 is material for most physical goods companies.
- Data gap reality
- Fewer than 30% of EU companies report supplier-specific Scope 3 data. Spend-based proxies dominate in current practice.
Documentation · Traceability · Assurance
Evidence Architecture
What a defensible evidence chain looks like under CSRD, CSDDD, and external assurance — and where most companies currently fall short.
- Minimum evidence set
- Sustainability policy, supplier code of conduct, signed supplier declarations, audit reports (SMETA/BSCI), corrective action plans, emissions calculation methodology.
- CSRD assurance
- External auditor must be able to trace disclosed data back to source documents. Assertions without underlying evidence will not pass limited assurance.
- Common gaps
- Spend-based Scope 3 with no supplier engagement, audit reports older than 24 months, no documented CAP closure.
- CSDDD expectation
- Documented due diligence process, not just a policy statement. Must show identification, prevention, and remediation steps.
- Digital traceability
- ESRS requires disclosure of traceability systems where relevant — blockchain, QR-code provenance, and digital product passports are emerging approaches.
- Best practice
- Maintain a compliance evidence register — a living document mapping each obligation to its evidence source and review date.
Country risk intelligence
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