Sustainability claims for international markets

14 Bath Street
Battery Point TAS 7004
ABN: 39 609 055 594

25 February 2025

Dear Sir/Madam,

Please see below my feedback on “Assuring agricultural sustainability claims: discussion paper”.

Key points are:
1. Developing an effective, appropriate response to sustainability claims must be part of an
integrated approach to managing Australian agricultural sustainability. This discussion paper
suggests current thinking on sustainability claims is being done at least partly in a silo, which
will at least partly lead to more duplication, inconsistency and confusion
2. This can be avoided by a well-designed system that urgently harmonises sustainability data
and delivers genuine coordination and collaboration across industries and jurisdictions.
Accurate, verifiable data to support claims will simply be an efficient output of this well-
designed holistic approach, and the same data will be used for multiple other purposes to add
value to Australian agriculture
3. The Sync concept developed by the Australian cotton industry and Sustenance Asia to
harmonise natural capital data and coordinate action provides a model on which to base this
4. Sustainability claims need to be verifiable, not verified. The assumption that data needs to be
assured is propagated largely be the assurance industry, and ignores the facts that third party
assurance is not effective; is expensive; is a potential trade barrier; is a barrier to on-farm
action; will soon be obsolete, and; is not needed
5. Accurate and verifiable data will be an efficient output of the well-designed system described
in point 2. Because data to support claims will largely be derived from technology and be
sufficiently accurate for farmers to make farm business decisions, it should not need to be
assured unless a specific entity wants to pay for it
6. If decision-makers still decide a blanket assurance requirement is needed, they need to
deliver a national system that minimises the cost to farmers and society, and maximises public
good. This would most likely be via CSIRO or some other independent, trusted body.
Developing a system that allows private companies to enrich themselves from expensive,
ineffective and deeply flawed verification processes would be a singularly bad outcome for
farmers, nature and society.

Consultation question 5: Who (e.g. which organisations/agencies) should play a role in assuring sustainability claims for Australian agriculture?

This question highlights that sustainability claims, like everything else in sustainability, can’t be effectively addressed in a silo. Assurance needs to be looked at as one small integrated piece of a pragmatic and effective whole.

My comments are based on discussion paper assertions such as “Verification methods, whether through standards or innovative approaches beyond typical audit-based certification, are critical for credibility.” and “Verification of sustainability practices are becoming non-negotiable…”

I strongly disagree this as a starting point for engineering guidance that will have major ramifications on Australian agriculture’s competitiveness, and the natural, social and economic capital on which farmers depend.

Verifiability of data behind claims is critical, not verification. The myth of third-party assurance being the unchallenged foundation of sustainability and claims is propagated by customers (who don’t want to pay for verification) and third-party verification firms (who enrich themselves in this process and thus conflict themselves out of any discussion on this topic). To properly answer question 5, the

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Department and Working Group should base their planning on the following context to verification and assurance:
• Third party verification by humans is not effective.
o There are countless examples of auditors and data verifiers making mistakes
(accidental or deliberate) with outcomes ranging from minor inconvenience to global
financial system chaos
• Third party verification is expensive.
o As just one example, NASDAQ companies in 2022 paid an average US$82,000 to
have climate disclosures audited. The cost of paying third parties to verify
exponentially more complex general sustainability data will be exponentially more
expensive. Unless customers are willing to pay or auditors are prepared to do this pro
bono, this massive, annual, ongoing cost for an ineffective and inefficient tick-box
exercise will be borne by farmers and consumers
• Third party verification is a potential trade barrier.
o As noted in the discussion paper, developments in the EU will impact Australian
farmers because they may be subject to the same illogical requirements as EU
farmers, but – unless there is a change in government policy – they will not be
subsidised for this cost as EU farmers may be
o Shaping and advocating to EU and other markets a solution that ensures accuracy of
claims and data without relying on expensive, inaccurate, flawed third party
verification will be a far cheaper and more effective option than reacting to “non-
negotiable” verification. This is particularly important given the compliance
requirements listed in the discussion paper are still evolving and will evolve even
more with the Trump administration’s impact on global trade. Now is the time to focus
on actions that optimise productivity and value, not imposts like verification that erode
resources for no reason
• Third party verification is a barrier to action.
o There is already far too much complexity, inconsistency and duplication in
sustainability creating massive confusion for farmers. This ultimately leads to inaction
in management of environmental, social or economic farm resources. Farmers just
want to know what they need to do, and how to do it simply. Requiring expensive,
time-consuming third party verification of farm data is a barrier to action, unless there
are clear market signals to justify the investment of time and money by the farm
business – ie, premiums or reimbursement of cost
• Third party verification will soon be obsolete.
o Agriculture industries are increasingly looking to source data from farm equipment,
satellites, environmental sensors and other technologies. This gives the promise of
real time data being used by farmers to monitor changes and make decisions. The
same data will be the basis of claims made by farmers and industries. As long as the
technology behind the data collection is sound and properly calibrated for accuracy –
and if farmers are using the data to make business decisions it certainly will be – the
need for human verification is redundant.
• Third party verification is not needed.
o Greenwashing legislation requires companies not to make claims that are
unsubstantiated; this can be done by having sound internal processes, and maximum
transparency of data upon which claims are based
o The EU Deforestation Regulation requires geolocation of plots of land used to
produce commodities and “adequately conclusive and verifiable information that the
relevant products are deforestation-free” – it doesn’t require this data to be verified
o The IFRS S1 General Requirements for Sustainability-Related Financial Information
(the sister Standard to the IFRS S2 climate disclosure standard, on which Australia’s
climate disclosure legislation is based; this means IFRS S1 will logically be the default
for future mandated general sustainability disclosures) requires that information be
verifiable, not verified.

All of this context needs to be understood to arrive at a logical response – as opposed to unquestioning acceptance of a grossly faulty status quo that verification is non-negotiable – to the discussion paper question of “which organisations should play a role in assuring sustainability claims for Australian agriculture.”

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Government resources should support existing agriculture industry efforts to:
• Urgently agree on nationally consistent definitions, indicators, and metrics behind
sustainability data (whether for claims, financial instruments, disclosures, farm business
decision-making, or any other purpose). This work is being done by government-funded
initiatives such as the AASF and the Australian cotton industry’s revamped sustainability data
framework; in future, maintaining this nationally consistent catalogue should be done by an
appropriately qualified independent non-profit body, such as the Natural Capital Measurement
Catalogue or SAI Platform
• Urgently coordinate a nationally consistent approach to the most cost-effective collection of
sustainability data. This is likely to be a combination of:
o Single, properly-resourced, free tools for data to be collected and aggregated at farm,
regional, industry, state and national levels. For example, the GAF tools for GHG
data; a single comparable tool for biodiversity data etc. These tools must be
resourced to provide the level of verifiability and data quality needed by the audiences
listed in the discussion paper
o Whole-of-agriculture approach to government agencies to provide data from their
existing systems. For example, Fair Work Commission or Ombudsman providing
data on legislation breaches related to human rights and labour conditions
o Whole of agriculture approach to coordinating data collection not able to be sourced
from technology or government agencies. A workplace indicators discussion paper
prepared by the cotton industry for AASF describes how a coordinated and
collaborative approach can dramatically reduce costs and farmer survey fatigue, and
increase data quality
• The same indicators and data collection methods must be consistent with or used by
government agencies in all jurisdictions. For example, a biodiversity tool must be used by the
Nature Repair Market, EPBC and EPA; any soil data and tools must support or be part of the
National Soil Strategy; a consistent approach to monitoring water withdrawals and water
quality must be embedded in Water Resource Plans, and so on
• Data collected must be made publicly available in real time to support radical transparency,
and allow monitoring of data by regulators and other agencies to take steps. For example, if
water quality monitoring indicates concentrations of a certain insecticide is approaching a
defined threshold for impact, farmers in that catchment can be alerted to take action before
the threshold is passed with potential negative impacts on environmental and human health,
as well as reputational damage for farmers
• This architecture defines the role different agencies and industries need to take to provide
data that meets verifiability needs, and is used for multiple other purposes as well to benefit
farmers, nature and society.

If the Australian Government still decides to make third party verification of sustainability claims a mandated requirement because “Verification of sustainability practices are becoming non-negotiable”
(which I strongly dispute; unquestioning acceptance of a grossly flawed status quo is not the same as non-negotiable), it needs to take steps to explain why this is needed, how the transfer of resources to the assurance industry is justified, and how the cost will not be borne by farmers and consumers
• If the Australian Government still decides verification is a requirement, it needs to deliver a
national system that minimises the cost to farmers and society, and maximises the public
good. This would most likely be to mandate verification is provided by CSIRO or some other
independent, trusted, non-profit body which keeps costs low and reinvests revenues raised in
public good research and actions. Developing a system that relies on private companies to
profit from what is mainly a public good has been shown by the carbon trading market to be
ineffective; extending the same logic to broader sustainability claims would be
unconscionable.

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?

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Section 3.2 is missing soil health, and economic value generated and distributed.

Economic value generated and distributed is often overlooked, but given the importance of “value to
Australia” in driving community trust and acceptance of agriculture (as consistently identified by
Voconiq research) this is a bad oversight. Even if not explicitly asked by a specific market, it is one of the three sustainability pillars and accurately describing agriculture’s economic contribution (wages, rates and taxes, goods and services procurements, donations etc) and is therefore a critical claim to be able to make.

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.
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?

As described in my answer to question 5, all of these can be addressed by a properly designed system based on harmonised data and genuine coordination and collaboration across industries and jurisdictions. Accurate, verifiable data to support claims will simply be an efficient output of this well- designed holistic approach, and the same data will be used for multiple other purposes to add value to
Australian agriculture. Designing a separate system specifically for sustainability claims will only add to duplication, inconsistency, wasted resources, and confusion.

The Sync concept developed by the Australian cotton industry and Sustenance Asia to harmonise natural capital data and coordinate action provides a model on which to base this. A summary is attached.

Consultation question 9: What existing datasets are you aware of that can be used to support sustainability claims?
Consultation question 10: Are there industry-specific datasets that should be prioritised?
Consultation question 10a: Which industry-specific datasets should be prioritised?
Consultation question 11: In what ways can existing data collection processes be improved to support strong and credible sustainability claims (without adding significant workload to farmers and supply chain actors)?
Consultation question 12: How do international markets assess the credibility and strength of the data provided to support sustainability claims?
Consultation question 12a: What benchmarks or standards are used in this evaluation?
Consultation question 13: What new data collection methods are needed to meet emerging market demands?

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As described in my answer to question 5, all of these can be addressed by a properly designed system that urgently harmonises sustainability data and delivers genuine coordination and collaboration across industries and jurisdictions.

The Sync concept developed by the Australian cotton industry and Sustenance Asia to harmonise natural capital data and coordinate action provides a model on which to base this. A summary is attached.

In addition to work by the Australian cotton industry to revamp its sustainability data framework and source data to deliver the claims described in this discussion paper – being part-funded by DAFF as a proof of concept for the rest of Australian agriculture – there is a significant work being done by AASF on indicators and data already. It’s not clear if work by this working group to identify data gaps etc is building on this existing body of work or doing it all again.

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