Industry-based Guidance on implementing
Climate-related Disclosures
Volume 40—Biofuels
June 2023
IFRS S2
IFRS
® Sustainability Disclosure Standard
International Sustainability Standards Board
This Industry-based Guidance accompanies IFRS S2 Climate related Disclosures (published
June 2023; see separate booklet) and is issued by the International Sustainability
Standards Board (ISSB).
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© IFRS Foundation 2023
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IFRS S2 CLIMATE-RELATED DISCLOSURES–JUNE 2023
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Introduction
This volume is part of the Industry-based Guidance on Implementing IFRS S2 Climate-related
Disclosures. This guidance suggests possible ways to apply some of the disclosure requirements in
IFRS S2 but does not create additional requirements.
This volume suggests possible ways to identify, measure and disclose information about
climate-related risks and opportunities that are associated with particular business
models, economic activities and other common features that characterise participation in
this industry.
This industry-based guidance has been derived from Sustainability Accounting Standards
Board (SASB) Standards, which are maintained by the International Sustainability
Standards Board (ISSB). The metric codes used in SASB Standards have been included for
ease of reference. For additional context regarding the industry-based guidance contained
in this volume, including structure and terminology, application and illustrative
examples, refer to Section III of the Accompanying Guidance to IFRS S2.
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Volume 40—Biofuels
Industry Description
Biofuels industry entities produce biofuels and process raw materials for production.
Using organic feedstocks, entities manufacture biofuels that are used primarily in
transportation. Entities typically source feedstocks, which include food, oil crops and
animal products, from agricultural product distributors. Ethanol and biodiesel are the
most widely produced biofuels, while other types include biogas, biohydrogen and
synthetic biofuels, produced from a variety of organic feedstocks. Biofuels entities’
customers are chiefly fuel-blending and fuel-supply entities, including major integrated
oil entities. Government regulations related to the use of renewable fuel are a significant
demand driver in the industry.
Sustainability Disclosure Topics & Metrics
Table 1. Sustainability Disclosure Topics & Metrics
TOPIC
METRIC
CATEGORY
UNIT OF
MEASURE
CODE
Water
Management
in
Manufacturing
(1) Total water withdrawn, (2) total water
consumed; percentage of each in
regions with High or Extremely High
Baseline Water Stress
Quantitative
Thousand
cubic metres
(m³),
Percentage
(%)
RR-BI-140a.1
Description of water management risks
and discussion of strategies and
practices to mitigate those risks
Discussion
and Analysis
n/a
RR-BI-140a.2
Number of incidents of non-compliance
associated with water quality permits,
standards and regulations
Quantitative
Number
RR-BI-140a.3
Lifecycle
Emissions
Balance
Lifecycle greenhouse gas (GHG)
emissions, by biofuel type
Quantitative
Grammes of
CO₂-e per
megajoule
(MJ)
RR-BI-410a.1
Sourcing &
Environmental
Impacts of
Feedstock
Production
Discussion of strategy to manage risks
associated with environmental impacts
of feedstock production
Discussion
and Analysis
n/a
RR-BI-430a.1
Percentage of biofuel production third-
party certified to an environmental
sustainability standard
Quantitative
Percentage
(%) of litres
RR-BI-430a.2
Management
of the Legal &
Regulatory
Environment
Amount of subsidies received through
government programmes
Quantitative
Presentation
currency
RR-BI-530a.1
Discussion of corporate positions
related to government regulations or
policy proposals that address
environmental and social factors
affecting the industry
Discussion
and Analysis
n/a
RR-BI-530a.2
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Table 2. Activity Metrics
ACTIVITY METRIC
CATEGORY
UNIT OF
MEASURE
CODE
Biofuel production capacity
Quantitative
Millions of
litres (ML)
RR-BI-000.A
Production of: (1) renewable fuel, (2) advanced biofuel,
(3) biodiesel, and (4) cellulosic biofuel
Quantitative
Millions of
litres (ML)
RR-BI-000.B
Amount of feedstock consumed in production 66
Quantitative
Metric tons (t)
RR-BI-000.C
Water Management in Manufacturing
Topic Summary
Biofuel refining is water-intensive. Biorefineries require water for feedstock processing,
fermentation, distillation and cooling. Although water use at biorefineries is modest
relative to the quantities consumed during feedstock crop production, it is concentrated,
and thus may affect local water resources. Facilities also may generate wastewater
containing salts, organic compounds, dissolved solids, phosphorus and other substances,
requiring wastewater treatment. Biofuel refineries also may face reduced water
availability, related cost increases or operational disruptions. Water extraction from
particular areas for refining, as well as contamination of water supplies because of
refining operations, also could create regulatory risk and tensions with local
communities. Water efficiency in operations and the proper treatment of effluents are
therefore important for biofuels entities.
Metrics
RR-BI-140a.1. (1) Total water withdrawn, (2) total water consumed; percentage of
each in regions with High or Extremely High Baseline Water Stress
1
The entity shall disclose the amount of water, in thousands of cubic metres,
withdrawn from all sources.
1.1
Water sources include surface water (including water from wetlands,
rivers, lakes and oceans), groundwater, rainwater collected directly and
stored by the entity, and water and wastewater obtained from municipal
water supplies, water utilities or other entities.
2
The entity may disclose portions of its supply by source if, for example, significant
portions of withdrawals are from non-freshwater sources.
2.1
Fresh water may be defined according to the local laws and regulations
where the entity operates. If no legal definition exists, fresh water shall be
considered to be water that has less than 1,000 parts per million of
dissolved solids.
2.2
Water obtained from a water utility in compliance with jurisdictional
drinking water regulations can be assumed to meet the definition of fresh
water.
66
Note to RR-BI-000.C – The amount of feedstock consumed in production is defined as feedstock
purchases adjusted for changes in inventory throughout the reporting period.
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3
The entity shall disclose the amount of water, in thousands of cubic metres,
consumed in its operations.
3.1
Water consumption is defined as:
3.1.1
Water that evaporates during withdrawal, use and discharge
3.1.2
Water that is directly or indirectly incorporated into the product or
service
3.1.3
Water that does not otherwise return to the same catchment area
from which it was withdrawn, such as water returned to another
catchment area or the sea
4
The entity shall analyse all its operations for water risks and identify activities
that withdraw and consume water in locations with High (40–80%) or Extremely
High (>80%) Baseline Water Stress as classified by the World Resources Institute’s
(WRI) Water Risk Atlas tool, Aqueduct.
5
The entity shall disclose water withdrawn in locations with High or Extremely
High Baseline Water Stress as a percentage of the total water withdrawn.
6
The entity shall disclose water consumed in locations with High or Extremely
High Baseline Water Stress as a percentage of the total water consumed.
RR-BI-140a.2. Description of water management risks and discussion of
strategies and practices to mitigate those risks
1
The entity shall describe its water management risks associated with water
withdrawals, water consumption and discharge of water or wastewater.
1.1
Risks associated with water withdrawals and water consumption include
risks to the availability of adequate, clean water resources, which include:
1.1.1
Environmental constraints—such as operating in water-stressed
regions,
drought,
concerns
of
aquatic
impingement
or
entrainment, interannual or seasonal variability, and risks from
the impact of climate change
1.1.2
Regulatory and financial constraints—such as volatility in water
costs, stakeholder perceptions and concerns related to water
withdrawals (for example, those from local communities, non-
governmental organisations and regulatory agencies), direct
competition with and impact from the actions of other users (for
example, commercial and municipal users), restrictions to
withdrawals because of regulations, and constraints on the entity’s
ability to obtain and retain water rights or permits
1.2
Risks associated with the discharge of water or wastewater include the
ability to obtain rights or permits related to discharges, regulatory
compliance related to discharges, restrictions to discharges, the ability to
maintain control over the temperature of water discharges, liabilities,
reputational risks and increased operating costs because of regulation,
stakeholder perceptions and concerns related to water discharges (for
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example, those from local communities, non-governmental organisations
and regulatory agencies).
2
The entity may describe water management risks in the context of:
2.1
How risks may vary by withdrawal source, including surface water
(including water from wetlands, rivers, lakes and oceans), groundwater,
rainwater collected directly and stored by the entity, and water and
wastewater obtained from municipal water supplies, water utilities or
other entities; and
2.2
How risks may vary by discharge destinations, including surface water,
groundwater or wastewater utilities.
3
The entity may discuss the potential effects that water management risks may
have on its operations and the time line over which such risks are expected to
manifest.
3.1
Effects include those associated with costs, revenue, liabilities, continuity
of operations and reputation.
4
The entity shall discuss its short- and long-term strategies or plans to mitigate
water management risks, which include:
4.1
The scope of its strategy, plans, goals or targets, such as how they relate to
various business units, geographies or water-consuming operational
processes.
4.2
Any water management goals or targets it has prioritised, and an analysis
of performance against those goals or targets.
4.2.1
Goals and targets include those associated with reducing water
withdrawals,
reducing
water
consumption,
reducing
water
discharges, reducing aquatic impingements, improving the quality
of water discharges and regulatory compliance.
4.3
The activities and investments required to achieve the plans, goals or
targets, and any risks or limiting factors that might affect achievement of
the plans or targets.
4.4
Disclosure of strategies, plans, goals or targets shall be limited to activities
that were ongoing (active) or reached completion during the reporting
period.
5
For water management targets, the entity shall additionally disclose:
5.1
Whether the target is absolute or intensity-based, and the metric
denominator if it is an intensity-based target.
5.2
The time lines for the water management activities, including the start
year, the target year and the base year.
5.3
The mechanism(s) for achieving the target, including:
5.3.1
Efficiency efforts, such as the use of water recycling or closed-loop
systems;
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5.3.2
Product innovations, such as redesigning products or services to
require less water;
5.3.3
Process and equipment innovations, such as those that enable the
reduction of aquatic impingements or entrainments;
5.3.4
Use of tools and technologies (for example, the World Wildlife
Fund Water Risk Filter, the Global Water Tool and Water Footprint
Network Footprint Assessment Tool) to analyse water use, risks and
opportunities; and
5.3.5
Collaborations or programmes in place with the community or
other organisations
5.4
The percentage reduction or improvement from the base year, in which
the base year is the first year against which water management targets are
evaluated towards the achievement of the target.
6
The entity shall discuss whether its water management practices result in any
additional lifecycle impacts or trade-offs in its organisation, including trade-offs
in land use, energy production and greenhouse gas (GHG) emissions, and why the
entity chose these practices despite lifecycle trade-offs.
RR-BI-140a.3. Number of incidents of non-compliance associated with water
quality permits, standards and regulations
1
The entity shall disclose the total number of incidents of non-compliance,
including violations of a technology-based standard and exceedances of quantity
or quality-based standards.
2
The scope of disclosure includes incidents governed by applicable jurisdictional
statutory permits and regulations, which include the discharge of a hazardous
substance, violation of pre-treatment requirements or total maximum daily load
(TMDL) exceedances.
3
The scope of disclosure shall only include incidents of non-compliance that
resulted in a formal enforcement action(s).
3.1
Formal enforcement actions are defined as governmental recognised
actions that address a violation or threatened violation of water quantity
or quality laws, regulations, policies or orders, and can result in
administrative penalty orders, administrative orders and judicial actions,
among others.
4
Violations shall be disclosed, regardless of their measurement methodology or
frequency. These include violations for:
4.1
Continuous discharges, limitations, standards and prohibitions that are
generally expressed as maximum daily, weekly and monthly averages; and
4.2
Non-continuous discharges, limitations that are generally expressed in
terms of frequency, total mass, maximum rate of discharge and mass or
concentration of specified pollutants.
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Lifecycle Emissions Balance
Topic Summary
The rapid growth in global biofuels production has been encouraged by government
energy policies that seek to reduce net GHG emissions from transportation fuels and
dependence on fossil fuels. Most major renewable-fuel policies worldwide require that
biofuels achieve lifecycle GHG emissions reductions relative to a fossil-fuel baseline to
qualify for renewable fuel-mandate thresholds. The biofuel lifecycle emission calculation
may include indirect and direct emissions from feedstock crop production and land use,
fuel refining, fuel and feedstock transport, and vehicle exhaust emissions. Biofuel
producers may influence net emissions directly during the refining process through
energy management (fuel use), process innovations and by using feedstocks with lower
emissions profiles. Fuel products that achieve a reduction in net emissions may qualify as
advanced biofuels, which could increase future demand. Biofuel entities that cost-
effectively reduce product net carbon emissions may gain a competitive product
advantage, spur revenue growth and increase market share.
Metrics
RR-BI-410a.1. Lifecycle greenhouse gas (GHG) emissions, by biofuel type
1
The entity shall disclose its lifecycle GHG emissions (in grammes of CO2-e per
megajoule) for each biofuel category produced.
1.1
Lifecycle GHG emissions are defined as the aggregate quantity of GHG
emissions (including direct emissions and significant indirect emissions,
such as significant emissions from land-use changes) related to the full
fuel lifecycle, including all stages of fuel and feedstock production and
distribution, from feedstock generation or extraction through the
distribution and delivery of the finished fuel, to the ultimate consumer
and fuel use, in which the mass values for all GHGs are adjusted to
account for their relative global warming potential.
1.2
The entity shall disclose its lifecycle GHG emissions for each of the
following biofuel types produced: (1) renewable fuel, (2) advanced biofuel,
(3) biodiesel and (4) cellulosic biofuel.
1.2.1
Renewable fuel is defined as fuel derived from biomass.
1.2.2
Advanced biofuel is defined as fuel derived from algae, animal
manure, corn cobs, grape marcs and wine lees, nut shells, husk
wastes and residues from forestry and forest-based industries, used
cooking oil, etc.
1.2.3
Biodiesel is defined as fuel derived from oils such as rapeseeds,
sunflowers, soybeans, palm oil and waste cooking oil, and used in
place of diesel fuel.
1.2.4
Cellulosic biofuel is defined as fuel derived from material
composed of lignin, cellulose, hemicellulose such as biomass
sourced from forests, woody energy crops, straw, strove, husks,
grasses and cover crops.
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2
The entity shall disclose the applicable jurisdictional laws or regulations used for
calculation.
Sourcing & Environmental Impacts of Feedstock Production
Topic Summary
The Biofuels industry uses a variety of plant-based feedstocks for production. Most
entities purchase feedstocks from agricultural producers and distributors. A growing
proportion of the world’s arable land now is occupied by biofuel crops. Unsustainable
cultivation practices can have negative environmental externalities, including
deforestation and biodiversity loss, soil degradation, and water pollution. These factors
may affect feedstock crop yields adversely over the short- and long-term. This, in turn,
may influence the price and availability of feedstocks for biofuels producers.
Consequently, vetting the sustainability of supply chains, such as through certifications
or engagement with suppliers, is an important consideration for biofuels producers.
Metrics
RR-BI-430a.1. Discussion of strategy to manage risks associated with
environmental impacts of feedstock production
1
The entity shall discuss its strategy to manage the environmental impacts and
regulatory risks associated with feedstock production, where risks may include:
1.1
Risks to feedstock supply and pricing created by climate change impacts
such as the increased likelihood of extreme weather events, decreased
availability of clean water resources, increased competition for arable
land, and decreased crop yields because of temperature increases.
1.2
Long-term risks to feedstock supply associated with suppliers’ impacts on
environmental health including those on biodiversity and soil health that
may be because of monoculture practices or fertiliser and pesticide use.
1.3
Constraints created by regulation such as compliance with sustainability
criteria in renewable fuel mandates; potential regulatory limits on the
types of land where feedstock can be grown; potential limits on what
qualifies as renewable biomass; potential for reduction or loss of public or
political support for biofuel mandates because of the environmental
impacts of feedstock production; and resistance to the use of genetically
modified organisms (GMOs).
2
The disclosure scope excludes risks associated with the lifecycle GHG emissions,
which are addressed in RR-BI-410a.1, respectively.
3
If the entity identifies the availability of clean water resources as a risk to
feedstock supply or pricing, it shall discuss the vulnerability to feedstock growing
regions with water stress and how it manages price variability risk because of
sourcing feedstock from these regions.
3.1
The entity should identify its known sources of feedstock from growing
regions with High (40–80%) or Extremely High (>80%) Baseline Water
Stress using the World Resources Institute’s (WRI) Water Risk Atlas tool,
Aqueduct.
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4
The entity shall describe how it manages risks or opportunities associated with
feedstock production, including constraints created by regulation, and limits on
availability and price.
4.1
Relevant strategies to discuss include sourcing from feedstock producers
that are third-party certified to environmental sustainability standards,
diversification of suppliers, using feedstock procurement criteria to choose
suppliers for varied feedstocks with fewer environmental impacts or
greater adaptability to the effects of environmental externalities (for
example, drought-tolerant or disease-resistant feedstocks), supplier audits,
sourcing from regions where the entity has greater control over feedstock
sources, and expenditures on research and development (R&D) for
alternative and substitute feedstocks that are less susceptible to
environmental externalities.
4.2
The entity should disclose the sustainability criteria it uses to assess its
feedstock suppliers.
RR-BI-430a.2. Percentage of biofuel production third-party certified to an
environmental sustainability standard
1
The entity shall calculate the percentage as the volume of biofuel produced that is
third-party certified to an environmental sustainability standard divided by the
total volume of biofuel produced.
2
Environmental sustainability standards include Bonsucro, the Council on
Sustainable Biomass Production (CSBP), International Sustainability & Carbon
Certification, Roundtable on Sustainable Biomaterials (RSB), and Roundtable on
Responsible Soy (RTRS), as well as other standards with equivalent criteria.
2.1
At a minimum, standards should include the following environmental
sustainability topics:
2.1.1
GHG and other air emissions, water consumption and quality, soil
health, fertiliser and pesticide use, land-use change, biodiversity
and waste management.
3
The entity should disclose the certification schemes to which its biofuel is
certified and the percentage of production certified to each scheme.
Management of the Legal & Regulatory Environment
Topic Summary
The Biofuels industry is dependent on government policies and regulations that create
market demand and incentivise supply with tax breaks and other support for feedstock
production. The Biofuels industry supports some regulations and policies related to
renewable fuel policy, production tax credits and feedstock production. While regulatory
support can result in positive short-term gains by supporting the biofuels market, the
potential long-term adverse environmental impacts from feedstock and biofuels
production may result in a reversal of beneficial policies, leading to a more uncertain
regulatory environment. Consequently, biofuels entities may benefit from developing
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clear strategies for engaging regulators that are aligned with long-term sustainable
business outcomes and that account for environmental externalities.
Metrics
RR-BI-530a.1. Amount of subsidies received through government programmes
1
The entity shall disclose the amount of subsidies received through government
programmes during the reporting year. Subsidies include tax credits such as
blending and production tax credits, funding for projects such as research and
development, import tariffs, direct payments, capital grants, loans and loan
guarantees and any other monetary support received from government
departments or programmes.
2
Government programmes include those worldwide at all jurisdictional levels.
3
The entity may disclose the type of biofuel subsidies received and the amount of
each. Types of biofuel subsidies may include blending and production tax credits,
capital grants, direct payments, loans and loan guarantees, surcharges or tariffs
on competing products, and funding for projects such as research and
development.
4
The entity shall disclose the amount of subsidies as an aggregate amount that was
recognised during the reporting year, regardless of the accounting method (for
example, deferral method, flow-through method or other GAAP methods for
investment tax credits).
RR-BI-530a.2. Discussion of corporate positions related to government
regulations or policy proposals that address environmental and social factors
affecting the industry
1
The entity shall identify risks and opportunities it faces related to laws,
regulations or rulemaking, (hereafter referred to collectively as ‘legal and
regulatory environment’) related to environmental and social factors that may
have a significant financial impact.
1.1
The scope shall include existing, emerging and known future risks and
opportunities.
1.2
The scope shall include risks and opportunities that may exist
domestically and globally.
1.3
The regulatory environment related to material environmental and social
factors includes those related to non-greenhouse gas air emissions,
greenhouse gas emissions, water withdrawals and effluents, feedstock
sourcing, and process and employee safety.
2
Relevant risks may include increased compliance costs, policy reversal (for
example, changes to existing environmental regulations), loss of financial
incentives (for example, reduction or elimination of tax deductions), reputation
(for example, the entity’s stance and actions related to the legal and regulatory
environment), legal and regulatory environment misalignment with long-term
strategy, and misalignment with the expectations of customers, investors and
other stakeholders.
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3
Relevant opportunities may include improved financial conditions (for example,
through policies that incentivise biofuel manufacturing activities), improved
community relations (for example, the entity’s stance and actions related to the
legal and regulatory environment), and other benefits the entity realises from the
alignment of the legal and regulatory environment with long-term strategy.
4
The entity shall discuss its efforts to manage risks and opportunities associated
with each aspect of the legal and regulatory environment associated with the
topics included in this Standard that are relevant to the entity’s business and may
have a significant financial impact.
5
In addition to efforts to influence the legal and regulatory environment, the
entity shall discuss its overall strategy to manage identified risks and
opportunities associated with each aspect of the legal and regulatory
environment.
5.1
Any changes it has made or plans to make to its business structure or
model
5.2
The development of new technologies or services
5.3
Any changes made or plans to make to operational processes, control or
organisational structures
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