Published name
Name of the organisation your response is on behalf of (if applicable)
Which of the following best describes your situation?
Which sector do you represent?
You may wish to upload your submission here:
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Submission to:
Sustainability claims for international markets: discussion paper
Department of Agriculture, Fisheries and Forestry
WWF-Australia
For more information, please contact:
Sharelle Polack
Senior Manager, Sustainable Agriculture
WWF-Australia
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Consultation question 1: What other current and emerging regulatory requirements are missing from
Section 2.1? Please include in your response which markets and/or sectors the requirements apply to.
The report/scope of the governance structure needs to go beyond regulatory requirements, there are also supply chain and finance sector requirements which will be significant and need to be integrated within this process.
• Accountability Framework Initiative (AFi) which underpins Science-based Targets Initiative
(SBTi) and Science-based Targets Network (SBTN): SBTi includes a deforestation-free (d-free)
supply chains commitment and SBTN a deforestation and conversion free (DCF) commitment.
AFi focuses on commodities from agricultural and forestry supply chains. Globally 6,000
companies have signed up to SBTi, with Japanese companies (a key export market) one of the
largest subscribers. In Australia, key retailers and companies from the finance sector have either
committed to SBTi or it is under their consideration e.g. Woolworths, Coles, McDonalds, Aldi,
Westpac. On pp12 it refers to deforestation requirements for the EU only, however such
requirements are considered by other countries e.g. UK, USA as well as through science-based
targets.
• The Taskforce on Green Value Chains for China brings together companies operating in China
(Bunge, Cargill, China Mengniu Dairy, L’Oréal, Nestlé) to encourage all global supply chain actors
who enter China’s market to alleviate deforestation caused by soybeans, palm oil, beef, pulp
and paper and other commodities.
• Taskforce on climate-related financial disclosures (TCFD) related requirements for large
companies from 1 January 2025 and Taskforce on nature-related financial disclosures (TNFD)
requirements which are coming are not mentioned.
• Buyers of green finance are referred to as an audience in the paper, but no discussion is
provided of finance sector requirements.
Consultation question 2: Are you aware of other expectations for evidence (form or subject) that are not included in Section 2.2? Please include in your response which markets and/or sectors the other expectations for evidence apply to.
• WWF-A is working closely with key retailers, banks and other initiatives to develop a d-free
verification process to meet market access requirements for the EUDR and AFi. At this stage the
focus is on the beef sector but the d-free verification process at property level (determining the
d-free status of a property) could be applied to any agricultural enterprise. To meet the due
diligence market access requirements for EUDR or AFi requires a more detailed assessment
process than: ‘Analysis of satellite imagery was also identified as a tool to ensure compliance
with the EU’s deforestation regulations by verifying that products are not sourced from
deforested land.’
Consultation question 3: What are the most common forms of evidence being asked for with respect to providing evidence to support sustainability claims? Please include in your response which markets and/or sectors the common forms of evidence apply to.
• Relating to d-free verification of commodities the type of evidence that could be relevant
includes:
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WWF Australia’s submission to Sustainability Claims for international markets
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o remote sensing mapping which verifies against the market requirements (a standard)
that the property is d-free.
o as the mapping has limitations, for the producer to strengthen their d-free claims may
also need further evidence such as vegetation type and condition mapping,
georeferenced photos, stock records or ecological assessments.
o the legality of the clearing and where further information is required to support claims
could be addressed through a statutory declaration/vendor declaration; and
o Lifetime traceability of a commodity is required, and this is being considered for beef
through the AgTrace program.
WWF-A is working with the finance sector to try to align the evidence requirements for a
commodity declaration and green finance requirements so that the information is multi-
purpose, reducing the burden on producers.
Consultation question 4: What are markets expecting in terms of evidence to support compliance with regulations (e.g. demonstrating compliance with work related regulations)? Please include in your response which markets and/or sectors the types of supporting evidence apply to.
The EUDR outlines due-diligence requirements for the importer, which in turn become requirements for
Australian exporters. See here for further information: https://green-business.ec.europa.eu/deforestation-regulation-implementation_en
Companies are also expected to track progress against their SBTs, requiring evidence from their supply chains.
Consultation question 5: Who (e.g. which organisations/agencies) should play a role in assuring sustainability claims for Australian agriculture? Please include in your response what role each organisation/agency you identify should have.
While a process has been developed and is being tested for d-free verification of beef, the governance structure of how it will be managed requires discussion and development to be ready for the end of
2025 deadlines. VISEC in Argentina provides an interesting model that could be adopted in Australia. It includes industry, NGOs, and supply chain actors and incorporates the principles of accountability, transparency, and ensures diverse voices for the multiple use cases.
Consultation question 6: Do you agree that the topics listed in section 3.2 are critical for demonstrating sustainability claims across all markets? Consultation question 6a: What other topics would you consider to be critical for demonstrating sustainability claims? Please include in your response which markets and/or sectors these topics apply to.
As sustainability claims cover environmental and social requirements it would be helpful to group the criteria into the:
1) Do no significant harm (DNSH) environmental objectives (e.g. Climate Change Mitigation,
Climate Adaptation and resilience, Circular economy, Pollution prevention, protection of water
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WWF Australia’s submission to Sustainability Claims for international markets
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resources, protection of soil resources and Biodiversity and ecosystems protection (includes
deforestation and conversion);
2) Minimum social safeguards (MSS) (e.g. First Nations rights and cultural heritage, modern
slavery); and
3) Social license requirements e.g. animal welfare objectives.
While the Guiding Principles consider market access and regulatory compliance, critical also for the agricultural industry are supply chain and finance sector company environmental, social and governance
(ESG) requirements. ESG increasingly includes climate and nature as well as regulatory reporting such as those under TCFD-based regulations and on the horizon, TNFD. Further, initiatives at sector level, such as the Australian Sustainability Finance Taxonomy will drive requirements for green financing with the climate-aligned criteria consultation complete and nature metrics under discussion. Therefore, the scope of this work (and that of the governance process) should consider engagement with supply chain and finance sector requirements.
Consultation question 7: Are you aware of any current or emerging approaches to demonstrating evidence-based sustainability claims that should be considered in the next phase of this project (that are within scope)? Consultation question 7a: Please provide details including a link to further information, or the contact details for the entity responsible so we may reach out to them.
As described in Q2, there is a d-free verification process in the testing phase. Please reach out to the author of this submission for further information.
Consultation question 8: What challenges do Australian agricultural sectors face in providing the necessary evidence to satisfy international market demands? Consultation question 8a: How can these challenges be overcome to ensure market access?
If this process is to follow a high-level approach to address sustainability criteria (as opposed to managing farm-level verification) it should address system-level barriers and challenges which include:
1) As highlighted in Q6, market access and regulatory compliance is only one component of
sustainability credentials, this process must also consider ESG reporting requirements of supply
chains and finance sector requirements and evidence requirements for green finance etc to
provide a holistic approach to streamlining sustainability (including social) credentials for
agriculture. This is also critical in the review of compliance burden under Part 2 of Phase 1,
because the compliance burden is greater than market access and regulatory compliance, and
greater again for multi-commodity producers.
2) To date, the process has been based on extremely limited consultation (n=12), pp4, to develop
the paper. However, to ensure that the ASCWG best serves the needs across the agricultural
sector, including producers, the governance structure will need to include an appropriate
diversity of perspectives. This diversity includes involvement of relevant technical experts and
non-government organisations (e.g. environmental protection and animal welfare)1.
3) The role of government at the State/Territory and Federal level in supporting the development
and implementation of sustainability credentials is unclear.
1
While NGO is mentioned in the Glossary, there is no mention of NGO engagement or inclusion in the governance framework in the body text.
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WWF Australia’s submission to Sustainability Claims for international markets
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Would you like to continue with the survey?
What other current and emerging regulatory requirements are missing from section 2.1?
The report/scope of the governance structure needs to go beyond regulatory requirements, there are also supply chain and finance sector requirements which will be significant and need to be integrated within this process.
• Accountability Framework Initiative (AFi) which underpins Science-based Targets Initiative (SBTi) and Science-based Targets Network (SBTN): SBTi includes a deforestation-free (d-free) supply chains commitment and SBTN a deforestation and conversion free (DCF) commitment. AFi focuses on commodities from agricultural and forestry supply chains. Globally 6,000 companies have signed up to SBTi, with Japanese companies (a key export market) one of the largest subscribers. In Australia, key retailers and companies from the finance sector have either committed to SBTi or it is under their consideration e.g. Woolworths, Coles, McDonalds, Aldi, Westpac. On pp12 it refers to deforestation requirements for the EU only, however such requirements are considered by other countries e.g. UK, USA as well as through science-based targets.
• The Taskforce on Green Value Chains for China brings together companies operating in China (Bunge, Cargill, China Mengniu Dairy, L’Oréal, Nestlé) to encourage all global supply chain actors who enter China’s market to alleviate deforestation caused by soybeans, palm oil, beef, pulp and paper and other commodities.
• Taskforce on climate-related financial disclosures (TCFD) related requirements for large companies from 1 January 2025 and Taskforce on nature-related financial disclosures (TNFD) requirements which are coming are not mentioned.
• Buyers of green finance are referred to as an audience in the paper, but no discussion is provided of finance sector requirements.
Are you aware of other expectations for evidence (form or subject) that are not included in section 2.2?
• WWF-A is working closely with key retailers, banks and other initiatives to develop a d-free verification process to meet market access requirements for the EUDR and AFi. At this stage the focus is on the beef sector but the d-free verification process at property level (determining the d-free status of a property) could be applied to any agricultural enterprise. To meet the due diligence market access requirements for EUDR or AFi requires a more detailed assessment process than: ‘Analysis of satellite imagery was also identified as a tool to ensure compliance with the EU’s deforestation regulations by verifying that products are not sourced from deforested land.’
What are the most common forms of evidence being asked for with respect to providing evidence to support sustainability claims?
• Relating to d-free verification of commodities the type of evidence that could be relevant includes:
o remote sensing mapping which verifies against the market requirements (a standard) that the property is d-free.
o as the mapping has limitations, for the producer to strengthen their d-free claims may also need further evidence such as vegetation type and condition mapping, georeferenced photos, stock records or ecological assessments.
o the legality of the clearing and where further information is required to support claims could be addressed through a statutory declaration/vendor declaration; and
o Lifetime traceability of a commodity is required, and this is being considered for beef through the AgTrace program.
WWF-A is working with the finance sector to try to align the evidence requirements for a commodity declaration and green finance requirements so that the information is multi-purpose, reducing the burden on producers.
What are markets expecting in terms of evidence to support compliance with regulations (e.g. demonstrating compliance with work related regulations)?
The EUDR outlines due-diligence requirements for the importer, which in turn become requirements for Australian exporters. See here for further information:
https://green-business.ec.europa.eu/deforestation-regulation-implementation_en
Companies are also expected to track progress against their SBTs, requiring evidence from their supply chains.
Who (e.g. which organisations/agencies) should play a role in assuring sustainability claims for Australian agriculture?
While a process has been developed and is being tested for d-free verification of beef, the governance structure of how it will be managed requires discussion and development to be ready for the end of 2025 deadlines. VISEC in Argentina provides an interesting model that could be adopted in Australia. It includes industry, NGOs, and supply chain actors and incorporates the principles of accountability, transparency, and ensures diverse voices for the multiple use cases.
Do you agree that the topics listed in section 3.2 are critical for demonstrating sustainability claims across all markets?
What other topics would you consider to be critical for demonstrating sustainability claims?
As sustainability claims cover environmental and social requirements it would be helpful to group the criteria into the:
1) Do no significant harm (DNSH) environmental objectives (e.g. Climate Change Mitigation, Climate Adaptation and resilience, Circular economy, Pollution prevention, protection of water resources, protection of soil resources and Biodiversity and ecosystems protection (includes deforestation and conversion);
2) Minimum social safeguards (MSS) (e.g. First Nations rights and cultural heritage, modern slavery); and
3) Social license requirements e.g. animal welfare objectives.
While the Guiding Principles consider market access and regulatory compliance, critical also for the agricultural industry are supply chain and finance sector company environmental, social and governance (ESG) requirements. ESG increasingly includes climate and nature as well as regulatory reporting such as those under TCFD-based regulations and on the horizon, TNFD. Further, initiatives at sector level, such as the Australian Sustainability Finance Taxonomy will drive requirements for green financing with the climate-aligned criteria consultation complete and nature metrics under discussion. Therefore, the scope of this work (and that of the governance process) should consider engagement with supply chain and finance sector requirements.
Are you aware of any current or emerging approaches to demonstrating evidence-based sustainability claims that should be considered in the next phase of this project (that are within the scope of the project as defined at section 1.3.3)?
Please provide details including a link to further information, or the contact details for the entity responsible so we may reach out to them.
As described in Q2, there is a d-free verification process in the testing phase. Please reach out to the author of this submission for further information.
What challenges do Australian agricultural sectors face in providing the necessary evidence to satisfy international market demands?
If this process is to follow a high-level approach to address sustainability criteria (as opposed to managing farm-level verification) it should address system-level barriers and challenges which include:
1) As highlighted in Q6, market access and regulatory compliance is only one component of sustainability credentials, this process must also consider ESG reporting requirements of supply chains and finance sector requirements and evidence requirements for green finance etc to provide a holistic approach to streamlining sustainability (including social) credentials for agriculture. This is also critical in the review of compliance burden under Part 2 of Phase 1, because the compliance burden is greater than market access and regulatory compliance, and greater again for multi-commodity producers.
2) To date, the process has been based on extremely limited consultation (n=12), pp4, to develop the paper. However, to ensure that the ASCWG best serves the needs across the agricultural sector, including producers, the governance structure will need to include an appropriate diversity of perspectives. This diversity includes involvement of relevant technical experts and non-government organisations (e.g. environmental protection and animal welfare) .
3) The role of government at the State/Territory and Federal level in supporting the development and implementation of sustainability credentials is unclear.