Industry-based Guidance on implementing
Climate-related Disclosures
Volume 25—Processed Foods
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).
Disclaimer: To the extent permitted by applicable law, the ISSB and the IFRS Foundation
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© IFRS Foundation 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 25—Processed Foods
Industry Description
Processed Foods industry entities process and package foods such as bread, frozen foods,
snack foods, pet foods and condiments for retail consumer consumption. Typically, these
products are made ready to consume, are marketed for retail consumers and can be
found on food retailers’ shelves. The industry is characterised by large and complex
ingredient supply chains, because many entities source ingredients from around the
world. Large entities operate globally, and international opportunities are driving growth.
Sustainability Disclosure Topics & Metrics
Table 1. Sustainability Disclosure Topics & Metrics
TOPIC
METRIC
CATEGORY
UNIT OF
MEASURE
CODE
Energy
Management
(1) Total energy consumed,
(2) percentage grid electricity and
(3) percentage renewable
Quantitative
Gigajoules
(GJ),
Percentage
(%)
FB-PF-130a.1
Water
Management
(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
(%)
FB-PF-140a.1
Number of incidents of non-compliance
associated with water quality permits,
standards and regulations
Quantitative
Number
FB-PF-140a.2
Description of water management risks
and discussion of strategies and
practices to mitigate those risks
Discussion
and Analysis
n/a
FB-PF-140a.3
Environmental
& Social
Impacts of
Ingredient
Supply Chain
Percentage of food ingredients sourced
that are certified to third-party
environmental or social standards, and
percentages by standard
Quantitative
Percentage
(%) by cost
FB-PF-430a.1
Suppliers’ social and environmental
responsibility audit (1) non-conformance
rate and (2) associated corrective action
rate for (a) major and (b) minor non-
conformances
Quantitative
Rate
FB-PF-430a.2
Ingredient
Sourcing
Percentage of food ingredients sourced
from regions with High or Extremely
High Baseline Water Stress
Quantitative
Percentage
(%) by cost
FB-PF-440a.1
List of priority food ingredients and
discussion of sourcing risks related to
environmental and social considerations
Discussion
and Analysis
n/a
FB-PF-440a.2
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Table 2. Activity Metrics
ACTIVITY METRIC
CATEGORY
UNIT OF
MEASURE
CODE
Weight of products sold
Quantitative
Metric tons (t)
FB-PF-000.A
Number of production facilities
Quantitative
Number
FB-PF-000.B
Energy Management
Topic Summary
The Processed Foods industry is reliant on energy and fuel as primary inputs for value
creation in manufacturing food products. Energy is needed to operate large
manufacturing facilities for cooking, refrigeration and packaging. Energy production and
consumption contributes to significant environmental impacts, including climate change
and pollution, which have the potential indirectly, yet materially, to affect processed
food entity operations. Energy efficiency in production and distribution can mitigate
exposure to volatile energy costs and limit an entity’s contribution to direct and indirect
greenhouse gas (GHG) emissions. Producers may be able to reduce the risk posed by
volatile fossil fuel energy costs—particularly natural gas, which the industry uses heavily
—by diversifying their energy portfolio across a range of sources. Decisions regarding
alternative fuels use, renewable energy and on-site generation of electricity versus
purchasing from the grid, may influence both the costs and reliability of the energy
supply.
Metrics
FB-PF-130a.1. (1) Total energy consumed, (2) percentage grid electricity and
(3) percentage renewable
1
The entity shall disclose (1) the total amount of energy it consumed as an
aggregate figure, in gigajoules (GJ).
1.1
The scope of energy consumption includes energy from all sources,
including energy purchased from external sources and energy produced by
the entity itself (self-generated). For example, direct fuel usage, purchased
electricity, and heating, cooling and steam energy all are included within
the scope of energy consumption.
1.2
The scope of energy consumption includes only energy directly consumed
by the entity during the reporting period.
1.3
In calculating energy consumption from fuels and biofuels, the entity shall
use higher heating values (HHV), also known as gross calorific values
(GCV), which are measured directly or taken from the Intergovernmental
Panel on Climate Change (IPCC).
2
The entity shall disclose (2) the percentage of energy it consumed that was
supplied from grid electricity.
2.1
The percentage shall be calculated as purchased grid electricity
consumption divided by total energy consumption.
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The entity shall disclose (3) the percentage of energy it consumed that was
renewable energy.
3.1
Renewable energy is defined as energy from sources that are replenished
at a rate greater than or equal to their rate of depletion, such as
geothermal, wind, solar, hydro and biomass.
3.2
The percentage shall be calculated as renewable energy consumption
divided by total energy consumption.
3.3
The scope of renewable energy includes renewable fuel the entity
consumed, renewable energy the entity directly produced and renewable
energy the entity purchased, if purchased through a renewable power
purchase agreement (PPA) that explicitly includes renewable energy
certificates (RECs) or Guarantees of Origin (GOs), a Green‐e Energy
Certified utility or supplier programme, or other green power products
that explicitly include RECs or GOs, or for which Green‐e Energy Certified
RECs are paired with grid electricity.
3.3.1
For any renewable electricity generated on-site, any RECs and GOs
shall be retained (not sold) and retired or cancelled on behalf of the
entity for the entity to claim them as renewable energy.
3.3.2
For renewable PPAs and green power products, the agreement shall
explicitly include and convey that RECs and GOs be retained or
replaced and retired or cancelled on behalf of the entity for the
entity to claim them as renewable energy.
3.3.3
The renewable portion of the electricity grid mix outside of the
control or influence of the entity is excluded from the scope of
renewable energy.
3.4
For the purposes of this disclosure, the scope of renewable energy from
biomass sources is limited to materials certified to a third-party standard
(for example, Forest Stewardship Council, Sustainable Forest Initiative,
Programme for the Endorsement of Forest Certification or American Tree
Farm System), materials considered eligible sources of supply according to
the Green-e Framework for Renewable Energy Certification, Version 1.0 (2017) or
Green-e regional standards or materials eligible for an applicable
jurisdictional renewable portfolio standard.
4
The entity shall apply conversion factors consistently for all data reported under
this disclosure, such as the use of HHVs for fuel use (including biofuels) and
conversion of kilowatt hours (kWh) to GJ (for energy data including electricity
from solar or wind energy).
Water Management
Topic Summary
Processed Foods entities rely on a reliable water supply for cooking, processing and
cleaning finished goods. Additionally, entities in the industry generate and must manage
the wastewater discharge from processing activities. As water scarcity becomes an issue
of increasing importance, processed foods entities—operating in water-stressed regions—
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may face increasing operational risks. Entities in the industry may face higher
operational costs as well as water shortages because of the physical availability or more
stringent regulations. Entities can manage water-related risks and opportunities through
capital investments and assessment of facility locations relative to water scarcity risks,
improvements to operational efficiency, and partnerships with regulators and
communities on issues related to water access and effluent.
Metrics
FB-PF-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.
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 entity’s
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 its 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.
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FB-PF-140a.2. 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 or limitations that are generally expressed in
terms of frequency, total mass, maximum rate of discharge and mass or
concentration of specified pollutants.
FB-PF-140a.3. 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
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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
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.
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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;
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.
Environmental & Social Impacts of Ingredient Supply Chain
Topic Summary
Entities in the Processed Foods industry manage global supply chains to source a wide
range of ingredient inputs. How entities screen, monitor and engage with suppliers on
environmental and social topics affects the ability of entities to maintain steady supplies
and manage price fluctuations. Supply chain management issues related to labour and
environmental practices, ethics or corruption also may result in regulatory fines or
increased long-term operational costs for entities. The consumer-facing nature of the
industry increases the reputational risks associated with supplier performance. Entities
can engage with important suppliers to manage environmental and social risks to
improve supply chain resiliency, mitigate reputational risks, potentially increase
consumer demand, or capture new market opportunities.
Metrics
FB-PF-430a.1. Percentage of food ingredients sourced that are certified to third-
party environmental or social standards, and percentages by standard
1
The entity shall disclose the percentage of food ingredients sourced that are
certified to a third-party environmental or social standard.
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1.1
Environmental standards are defined as standards that address
environmental impacts related to the production of food ingredients, such
as protection of primary forests, maintenance of surface water and
groundwater quality, and implementation of integrated pest management
solutions or an Organic System Plan.
1.2
Social standards are defined as standards that address social impacts
related to the production of food ingredients, such as compensation of
workforce, training and continual monitoring of health and safety risks
associated with the application of agrochemicals and child-labour
practices.
1.3
The percentage shall be calculated as the cost of food ingredients
purchased from Tier 1 suppliers certified to a third-party environmental or
social standard divided by the total cost of food ingredients purchased
from Tier 1 suppliers.
1.4
Examples of certifications to third-party environmental and social
standards include:
1.4.1
Bonsucro
1.4.2
Fairtrade International
1.4.3
Fair Trade USA
1.4.4
Roundtable on Sustainable Palm Oil (RSPO)
1.4.5
Roundtable on Responsible Soy (RTRS)
1.4.6
Rainforest Alliance
1.4.7
SA8000
1.4.8
U.S. Department of Agriculture (USDA) Organic
1.4.9
UTZ Certified
2
The entity shall disclose the percentage of food ingredients it sourced that are
certified to a third-party environmental or social standard, by standard.
2.1
The entity shall calculate the percentage as the cost of food ingredients
purchased from Tier 1 suppliers certified to each respective third-party
environmental or social standard divided by the total cost of agricultural
products purchased from Tier 1 suppliers.
2.1.1
For Bonsucro certification, the entity shall disclose whether the
food ingredients are certified to the Bonsucro Production Standard
or the Bonsucro Chain of Custody Standard.
2.1.2
For Fairtrade International and Fair Trade USA, the entity shall
disclose whether the food ingredients are certified to the standards
for
small
producer
organisations,
hired
labour,
contract
production, traders, independent small holders or capture
fisheries.
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2.1.3
For RSPO certification, the entity shall disclose which of the RSPO
supply chain models the food ingredients are certified to: Identity
Preserved (IP); Segregated (SG); Mass Balance (MB); or Book & Claim
(B&C).
2.1.4
For RTRS certification, the entity shall disclose whether the food
ingredients are certified to the RTRS Production standard or the
RTRS Chain of Custody Standard and whether traceability in the
chain of custody standard is kept through segregation or mass
balance.
2.1.5
For other third-party certifications, the entity may specify the type
of certification if there is more than one type.
2.2
The entity may aggregate the percentages of numerous third-party
certifications into one aggregate percentage, if the certifications are for
the same food ingredient and deliver similar environmental or social
criteria.
3
The disclosure scope includes food ingredients purchased from Tier 1 suppliers.
3.1
Tier 1 suppliers are defined as suppliers that transact directly with the
entity for food ingredients.
FB-PF-430a.2. Suppliers’ social and environmental responsibility audit (1) non-
conformance rate and (2) associated corrective action rate for (a) major and (b)
minor non-conformances
1
The entity shall disclose its supplier facilities’ (1) non-conformance rate with
external social and environmental audit standard(s) or internally developed
supplier code(s) of conduct for (a) major non-conformances, and separately, (b)
minor non-conformances.
1.1
A major non-conformance is defined as the highest severity of non-
conformance and requires escalation by auditors. Major non-conformances
confirm the presence of underage child workers (below the legal age for
work or apprenticeship), forced labour, health and safety issues that can
cause immediate danger to life or serious injury, or environmental
practices that can cause serious and immediate harm to the community.
Major non-conformance includes material breach or systemic breaking of
code requirement or law. Major non-conformances may also be referred to
as critical or priority non-conformances.
1.2
A minor non-conformance is defined as a non-conformance that, by itself,
is not indicative of a systemic problem with the management system.
Minor non-conformances are typically isolated or random incidents and
represent a low risk to workers or the environment.
1.3
The entity shall calculate the non-conformance rates as the total number
of non-conformances identified (in each respective category) among its
supplier facilities divided by the number of supplier facilities audited.
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2
The entity shall disclose the (2) corrective action rates associated with its supplier
facilities’ (a) major non-conformances, and separately, (b) minor non-
conformances.
2.1
A corrective action is defined as the completion of an action (generally
identified in a corrective action plan) within 90 days, designed to eliminate
the cause of a detected non-conformance, including the implementation of
practices or systems to eliminate any non-conformance and ensure no
reoccurrence of the non-conformance, as well as verification that the
action has taken place.
2.2
The entity shall calculate the corrective action rates as the number of
corrective actions that address non-conformances (in each respective
category) divided by the total number of non-conformances identified (in
each respective category).
3
The entity shall disclose the standards or code(s) of conduct to which it has
measured social and environmental responsibility audit compliance.
3.1
For internally developed supplier code(s) of conduct, the entity shall
disclose the public location where such code(s) can be viewed.
Ingredient Sourcing
Topic Summary
Entities in the Processed Foods industry source a wide range of ingredients, largely
agricultural inputs, from global suppliers. The industry’s ability to source ingredients,
and at some price points, fluctuates with supply availability, which may be affected by
climate change, water scarcity, land management and other resource scarcity
considerations. This exposure may cause price volatility which may affect entity
profitability. Climate change, water scarcity and land-use restrictions present risks to an
entity’s long-term ability to source essential materials and ingredients. Entities that
source ingredients which are more productive and less resource-intensive, or coordinate
with suppliers to increase their adaptability to climate change and other resource
scarcity risks, may reduce price volatility and supply disruptions.
Metrics
FB-PF-440a.1. Percentage of food ingredients sourced from regions with High or
Extremely High Baseline Water Stress
1
The entity shall disclose the percentage of food ingredients sourced from regions
with High or Extremely High Baseline Water Stress.
2
The percentage shall be calculated as the cost of food ingredients purchased from
Tier 1 suppliers that withdraw and consume water in regions with High or
Extremely High Baseline Water Stress to produce the agricultural products,
divided by the total cost of food ingredients purchased from Tier 1 suppliers.
2.1
Tier 1 suppliers are defined as suppliers that transact directly with the
entity for food ingredients.
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2.2
The entity shall identify Tier 1 suppliers 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.
3
If the entity is unable to identify or collect data pertaining to all Tier 1 suppliers,
the entity shall disclose the percentage of agricultural products for which the
source region and water risks are unknown.
FB-PF-440a.2. List of priority food ingredients and discussion of sourcing risks
related to environmental and social considerations
1
The entity shall identify the highest priority food ingredients to its business.
1.1
Priority food ingredients are defined as ingredients (excluding water) that
constitute the largest food ingredient expense, or those ingredients
identified by the entity as essential to its products or as having significant
environmental or social risks.
1.2
The scope of disclosure includes priority food ingredients sourced by the
entity, which may include those sourced directly from contract growers
and from producer supply agreements.
2
The entity shall discuss its strategic approach to managing the environmental and
social risks that arise from its highest priority food ingredients.
2.1
Environmental risks may include effects of drought and climate change on
ingredient prices, reputational damage because of deforestation and other
risks resulting from the environmental impacts associated with the
entity’s supply chain.
2.2
Social risks may include the effects of workers’ rights on productivity,
reputational damage because of human rights issues and other risks
resulting from the social impacts associated with the entity’s supply chain.
3
The entity may identify which food ingredients present risks to its operations, the
risks represented and the strategies the entity uses to mitigate such risks.
3.1
For environmental risks, relevant strategies to discuss may include the
diversification
of
suppliers,
supplier
training
programmes
on
environmental best management practices, expenditures on research and
development for alternative and substitute crops, and audits or
certifications of suppliers’ environmental practices.
3.2
For social risks, relevant strategies to discuss may include supplier training
programmes on agrochemical application, engagement with suppliers on
labour and human rights issues and maintenance of a supply chain code of
conduct.
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