British Retail Consortium Climate Action Roadmap

The British Retail Consortium (BRC) is the trade association for retail businesses, with representation across the UK’s major brands in fashion, home and DIY, mixed retail, stationery and craft, food and drink, fast food, electronics, sport and other specialists.

The BRC produced a Climate Action Roadmap for the retail sector, committing to a science-led strategy to limit global warming to 1.5C.

Ambitions

Supporters of this Roadmap have committed to collectively bring the UK retail industry’s greenhouse gas emissions to net zero by 2040.

Supporting this headline objective of net zero by 2040 are 3 key milestones, some in advance of 2040:

• 2030 – net zero for Scope 2 – (retailers’ electricity use)
• 2035 – net zero for Scope 1- (retailers’ fuel, gas and refrigerant use)
• 2040 – net zero for all products sold in the UK across all Scopes

Actions

The Roadmap describes how the retail industry can decarbonise, while continuing to deliver an outstanding retail experience, through action in five areas: 

• Putting greenhouse gas data at the core of business decision making;
• Operating efficient sites powered by renewable energy;
• Moving to low carbon logistics;
• Sourcing sustainably; and
• Helping our employees and customers to live low carbon lifestyles.

Details and support can be found on the BRC Climate Action Roadmap website

WRAP – The UK Plastics Pact 2025

Chaired by the Waste and Resources Action Plan (WRAP), the UK Plastics Pact is a voluntary commitment to reduce plastic production and waste by 2025 via committing to four targets:

• Eliminating problematic or unnecessary single-use packaging through redesign, innovation or alternative (reuse) delivery models
• 100% of plastics packaging to be reusable, recyclable or compostable by 2025
• 70% of plastics packaging effectively recycled or composted by 2025
• 30% average recycled content across all plastic packaging by 2025.

Signatories include Tesco, McDonalds and Next.

To achieve The UK Plastics Pact targets it is imperative we address some critical issues and find solutions working in collaboration with the plastics value chain. These include: 

• Flexible plastic packaging: Flexible plastic represents a quarter of all UK consumer plastic packaging, but only 6% is currently recycled. Urgent action is needed.
• Problem plastics: Eliminating problematic plastics and rethinking and redesigning our plastics so they are more easily recycled.
• Designing for recyclability: Use our polymer choice and recyclability guidance to design packaging fit for the future
• Citizen behaviour change: Hard hitting campaigns, world leading citizen research and insight are transforming recycling behaviours in the UK.

SBTi Net Zero Standard

Science-based targets provide a clearly-defined pathway for companies to reduce greenhouse gas (GHG) emissions, helping prevent the worst impacts of climate change and future-proof business growth.

Targets are considered ‘science-based’ if they are in line with what the latest climate science deems necessary to meet the goals of the Paris Agreement – limiting global warming to well-below 2°C above pre-industrial levels and pursuing efforts to limit warming to 1.5°C.

In order to be recognised as a 'net-zero business' acting in line with climate science, businesses must now at least halve their emissions by 2030, and reduce them by 90% by 2050 at the latest, all without the use of carbon offsetting. Companies with land-intensive operations must also set an SBTi Forestry, Land Use and Agriculture (FLAG) Target.

In June 2023 SBTi released a new guidance document to support businesses in addressing supply chain emissions, outlining how larger companies can encourage their suppliers to set their own science-based targets. The guidance includes how to identify and prioritise suppliers for reduction targets, securing buy-in, training and engagement tools and methods, and monitoring progress.

Science Based Targets for Nature (SBTN)

Science Based Targets for Nature is a sister organisation to the Science Based Targets initiative (SBTi). They provide guidance on setting environmental targets aligned with the best practice recommendations from the scientific community to tackle the interconnected challenges of nature depletion and climate change.

Guidance is already available for target setting on climate and emissions reduction through SBTi and the Net Zero Corporate Standard.

In May 2023 SBTN announced the first science-based targets for nature in the form of technical guidance for freshwater and land. These cover the ‘Assess, Prioritise and Set” stages of the process, with updates for the “Act and Track” stages to arrive in 2024.

Targets are in development for Oceans and Biodiversity.

Current legislation

Energy Savings Opportunity Scheme (ESOS)

Requires large UK companies to report on energy efficiency measures and plan for continuous improvement. Read more.

Streamlined Energy and Carbon Reporting (SECR)

Requires large UK companies to publish (at a minimum) their Scope 1 and 2 emissions and report on their measures to reduce emissions. Read more.

Ecodesign for Energy-Related Products and Energy Information Regulations 2021

Requires manufactures of energy-related products to make spare parts for products available to customers, to extend the lifespan of goods. Read more.

Green Claims code

In February 2023 the Committee of Advertising Practice released supplementary guidance to the Green Claims Code regarding the use of carbon neutral and net zero claims in advertising. Read more.

Plastic packaging tax

A tax of £200/tonne applies to plastic packaging manufactured in, or imported into the UK, that does not contain at least 30% recycled plastic. Read more.

In April 2023, the government announced a consultation into moving the plastic packaging tax to a ‘mass balance’ approach to better accommodate chemical recycling.

Mandatory Taskforce on Climate-related Financial Disclosures (TCFD) reporting for large businesses

Listed companies, banks or insurers with more than 500 employees will be required to disclose climate-related financial risks in line with the existing TCFD standards. Read more.

Upcoming legislation

Minimum energy efficiency standards (MEES) countdown

The grading criteria for buildings’ energy performance certificates (EPCS) is undergoing several revisions. Notably for retailers, by 2030, all non-domestic rented buildings must meet EPC grade B, with EPC C by 2027 a proposed interim requirement. Read more.

The Environment Act 2021 introduced measures banning the purchase of commodities that are the product of illegal deforestation. DEFRA is consulting on secondary legislation needed to enforce this law and give businesses guidance on compliance. Read more.

Eliminating single use items

The government has introduced a ban on a range of single-use plastic items including plastic plates, trays, bowls, cutlery, and polystyrene food containers. The ban will apply to retailers, takeaways, food vendors, and the hospitality industry and will kick in from October 2023. Read more.

Green claims review for fashion and FMCG retailers

The UK CMA is conducting sector-level investigations into green claims across FMCG and fashion retail. Read more.

Mandatory publication of Net Zero transition plans for large businesses

From 2023 large businesses will be required to publish a net zero transition plan to 2050. The treasury has established an industry task force to oversee the development of a “gold standard” for climate transition plans, set to be finalised this summer. Read more.

Sustainability Disclosure Requirements (SDRs)

Corporates will be required to disclose a range of sustainability information regarding governance, strategy, risk management, targets and metrics under the emergent Sustainability Disclosure Requirements (SDRs) framework. Consultation regarding this took place in 2022 and the final rules and guidance are expected in the first half of 2023. Read more.

Due diligence provisions to eliminate deforestation in supply chains

The Environment Act 2021 introduced measures banning the purchase of commodities that are the product of illegal deforestation. In 2022 DEFRA consulted on secondary legislation needed to enforce this law and give businesses guidance on compliance. The Government will publish its approach to implementing new legislation in due course. Read more.

Energy Bill

Among developments relating to energy pricing and supply, the Energy Bill will focus on new market standards to accelerate adoption of low carbon technologies such as hydrogen fuel and heat pumps, as well as advancing industrial carbon capture and storage. Read more.

Minimum efficiency standards for lighting

The Government has proposed new energy-efficiency standards for lighting in domestic and non-domestic properties. Performance standards would be higher than current EU legislation and would include only the most efficient LED bulbs being available in shops. If adopted, the proposals would come into force in late 2023. Read more.

EU chemical ban

The European Chemicals Agency (ECHA) has unveiled a proposal that would ban the production, use and sale of around 10,000 per-and polyfluoroalkyl substances (PFAS) in the European Union. PFAS, often referred to as 'forever chemicals', are industrial chemicals that can take over 1000 years to degrade and are widely used in consumer products. The ECHA will invite public comment on the proposals from March 2023. Read more.

Increasing Extended Producer Responsibility for Packaging

The government has published the results of a consultation into the implementation of packaging reforms. From 2024, packaging producers must accept responsibility for the costs of their packaging throughout its life cycle. The reforms, which will see a phased approach across 2024-2025, are designed to encourage innovation and prompt organisations to design packaging that uses less material and is easier to recycle. Read more.

EU Green Claims Directive

The EU shared a draft of the Green Claims Directive, which will strengthen consumer protection against greenwashing. The directive will introduce requirements to substantiate claims with life cycle data, and specifically explore the validation of certification schemes, noting the proliferation of eco-labels in the market was a cause of confusion for the public. Similarly to the UK’s Green Claims Code, organisations will be mandated to ensure claims regarding a product’s positive environmental impact need to give information about negative impacts as well.

Further details on specific criteria and sector-level claims are tabled for coming weeks. Read more.

UK Digital Markets, Competition and Consumer Bill

The forthcoming Digital Markets, Competition and Consumer Bill will give the Competition and Markets Authority (CMA) powers to determine when consumer law is infringed outside of court. Breaches could result in fines of up to 10% of global turnover. The Bill is under development, but lawyers indicated that misleading environmental claims are likely to included, so the law would strengthen protections against greenwashing. Since the introduction of the Green Claims Code in 2021 even sustainable brands continue to fall foul of the regulator, who note that environmental claims are some of the most complex to construct. Read more.

EU Corporate Sustainability Due Diligence Directive (CSDDD)

The EU have tabled mandatory reporting for large organisations to protect the environment and human rights across their own operations and supply chain. If adopted, organisations would need to demonstrate ‘prevention action plans’ and ensure that suppliers comply with the plans. Read more.  

Voluntary disclosures

Task Force on Climate-Related Financial Disclosures (TCFD)

TCFD is a voluntary initiative to improve organisational reporting of climate-related financial risks and opportunities. TCFD reporting will become mandatory for the largest UK businesses (see above), however is increasingly requested by investors across a breadth of organisation types. Read more.

Taskforce on Nature-related Financial Disclosures (TNFD)

The Taskforce for Nature-related Financial Disclosures (TNFD) is a risk management and disclosure framework for organisations to report and act on nature-related risks such as biodiversity loss and other impacts to natural capital.

TNFD has launched its fourth and final beta framework in advance of the planned launch in the autumn. This iteration allows organisations early insight into the proposed approach to disclosure metrics, which will follow a tiered framework of indicators spanning global, sector-specific and additional metrics. Read more.

CDP 

CDP (formerly Carbon Disclosure Project) is the global disclosure system for companies and investors to manage their environmental impacts. CDP is the gold standard for corporate environmental reporting and is fully aligned with the TCFD recommendations. CDP covers disclosures across Climate Change, Forests and Water. 2023 will see organisations asked to disclose on plastics for the first time through CDP’s water questionnaire. Read more.

International Sustainability Standards Board (ISSB)

The International Sustainability Standards Board (ISSB) is a standard-setting body working to develop an international baseline standard for sustainability disclosures. ISSB aims to unite the fragmented reporting standards and quality among different regions and nations. This ISSB has issued its first two finalised frameworks, IFRS S1 and IFRS S2, with an expectation that the first corporate reports aligned with them will be published in 2025. It is anticipated that the ISSB standard will become the dominant framework for sustainability reporting.

IFRS S1 is the “core baseline” of sustainability reporting and is applicable to all large businesses. It covers company impact, including emissions across all scopes and waste management.

IFRS S2 is concerned with climate mitigation and climate adaptation and builds on existing disclosure frameworks in this field, mainly the Taskforce on Climate-Related Financial Disclosures (TCFD). Find out more here.