Emperor Sustainability Briefing 23.10.2025

Issue #7

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We shall fight in the fields, and in the trilogues

With an influential nature standard releasing soon, updates to forestry and land targets, and the maintaining of a deforestation regulation, it’s been a week of wins for tree-huggers – which as Briefing readers, I’m sure is all of us. Red Tractor has been at war in particular, with the ASA challenging it on farming claims. 

The EU’s Omnibus plan for reducing sustainability regulations enters negotiations this week, with the three EU bodies already agreed on most of the common ground. Speaking of foregone conclusions, the UK Government has been officially advised for the first time to expect 2°C of warming. For the world of sustainability, the battle continues… 

In this Briefing...

Omnibus negotiations – ISO for nature

Red Tractor challenged – GHG Protocol scope 2

UK at 2C – EU EV targets

South Korean SAF – California delay

EUDR sticks

Regulation and frameworks

Omnibus goes to war, with CSRD reductions at stake

The Omnibus trialogues, which will see discussions between the EU Parliament, Commission and Council, begin this week, with the aim of reaching a final agreement on CSRD and CSDDD by the end of 2025. We already know a lot about the negotiating position of the different entities. As it stands all three parties are likely to reduce CSRD scope to only companies with over 1,000 employees, with some disagreement about the corresponding balance sheet threshold. It is likely that we will shift from mandatory reasonable assurance to limited assurance. Large non-EU parent companies will still be subject to reporting, and climate transition plans will probably be maintained. If you knew which ‘wave’ of CSRD your company was in prior to this, then the ultimate outcome is likely to not change this as these negotiating positions have been public and widely discussed by legal teams and auditors since the middle of this year. 

You can find a good round-up of the various potential changes to both regulations here – alternatively, you’d be wise to just wait until the dust has settled and assess your position then! We’ll be sure to bring you outcomes in a future Briefing, once we know with greater certainty what EU and non-EU companies are going to be subject to. Be in touch if you’d like to unpack this further with us, or for us to provide a view on how you’re likely to be affected. 

ISO’s Biodiversity Standard: the definitive nature standard?

The International Organization for Standardization (ISO) has released ISO 17298, the world’s first biodiversity standard for corporates. With ISO standards historically being strongly influential in defining company approaches to topics, the release could be something of a milestone for the creation of operational controls for nature. ISO itself hopes that the framework will help biodiversity concerns be further integrated into corporate decision making. Aligned with the TNFD framework (and partially developed alongside members of TNFD), we expect larger companies which have meaningful nature impacts to be the first to look at and consider adopting the ISO. With ISO’s own net zero standard set to be released next month at COP30, the organisation is gradually taking its place amongst the forefront of sustainability standard setters. 

SBTi opens urgent consultation on FLAG criteria

The Science Based Targets initiative (SBTi) has launched an ‘urgent’ public consultation to update its Forest, Land and Agriculture (FLAG) criteria. The five proposed changes target timelines, deforestation cutoffs, commodity lists and documentation. It’s FLAG criteria 1 and 4 that are most under review here, both to do with target setting periods – although it’s not entirely clear what the cause of the stated ‘urgency’ is, aside from perhaps the ongoing complexities around the EU Deforestation Regulation (see [above/below]!). With the consultation closing on 6th November and the updated criteria expected to be published no earlier than Q1 2026, we will bring you changes in a later edition. 

Red Tractor pulled over by advertising watchdog

Britain’s biggest farm assurance scheme Red Tractor has been pulled up by the UK’s advertising watchdog for overstating its environmental standards. The Advertising Standards Authority (ASA) judged that Red Tractor’s claims that all foods carrying its logo had been “farmed with care”, along with other phrases, were misleading – based in part on evidence from an Environment Agency report, which found that 62% of the most critical pollution incidents between 2014-2019 occurred on Red Tractor farms. The ASA is known to be particularly stringent on more generalised or qualitative green claims. 

The news might give cause for caution when relying on third-party sustainability labels, as these can be as open to criticism as any other claims. The fundamentals remain true: sustainability claims within marketing can most reliably be made safe by increasing scrutiny and oversight into one’s own operations and supply chain.

GHG Protocol opens consultation on new approach to scope 2

As anticipated, the GHG Protocol, the world’s leading standard for how emissions are reported, has opened its consultation on new scope 2 reporting rules. A core focus is to prepare for 24/7 energy matching, the most cutting edge approach to green electricity claims. In 24/7, emissions reductions claims have to be aligned very closely with the time and place that a unit of electricity is consumed. This will mean moving from procuring green electricity on an e.g. annual basis to cover your years’ worth of use, to procuring it within as little as half an hour of its actual production. The aim of this is to create more accurate market signals to better support clean energy build-out. GHG Protocol has separately confirmed that the location-based and market-based dual reporting structure will be maintained. 

Scope 2 is of course widely reported, with the GHG protocol’s consultation therefore of interest to nearly everyone. In particular, however, the revisions should draw attention from companies relying on virtual power purchase agreements, as these are likely to face greater scrutiny in the new regime. Changes are still a long way off though, with the new standard expected in 2027.

Policy

UK Government told to prepare for 2°C of warming 

After years of warning, the UK government has been explicitly told by its climate advisor the Climate Change Committee (CCC) to prepare for at least 2°C of global warming by 2050. This could be marked by a doubling in droughts, significant flood risk increase, and a booming wildfire risk in southern England. The announcement is stark, and marks a shift from previous alignments to a 1.5°C goal which now appears increasingly unattainable. While organisations such as the SBTi still ask for 1.5°C alignment from companies, external realities are unfortunately making the case for this more difficult.

We note that companies which have prepared external action plans around 1.5°C may eventually have to pivot to discussing 2°C as an acknowledged truth, with the UK government consultation on 1.5°C-aligned transition plans, for instance, now being more likely to produce a less stringent regulation. If you’ve published a transition plan that hinges on this,  if you get in touch we’d be happy to help you out on where to go from here. 

EU automakers deem electrification targets unrealistic 

The European car industry, represented by the European Automobile Manufacturers’ Association (ACEA), has submitted proposals to the European Commission urging to ease upcoming decarbonisation targets. The current EU law requires new car and van CO₂ emissions to be cut by 100% by 2035, with 2030 targets requiring a 55% and 50% reduction for cars and vans respectively against 2021 levels. 

The ACEA argue that these timelines are no longer realistic given the gap in EV demand, lagging charging infrastructure, and competition from China’s low-cost electric models. The Commission is expected to review the current targets for cars, vans, and trucks by the end of 2025, but the push reflects growing tension between climate ambition and industrial feasibility. The UK’s own ban on new petrol and diesel cars from 2030 has had to go through revisions, with shifts in international politics and manufacturing applying pressure to what was already a relatively forceful regulation. 

South Korea sets SAF mandate for international flights

From 2027, South Korea will require the use of Sustainable Aviation Fuel (SAF) on all international flights, becoming one of the first countries in Asia to set a national SAF mandate. The mandate will begin at a 1% blending requirement – i.e. 1% of the aeroplane’s total fuel mix will have to be SAF – and scale up to around 10% by 2035. 

The government has formed an SAF Alliance, bringing together airlines, refiners, and regulatory agencies to accelerate domestic production and streamline certification standards. While SAF may still be relatively expensive and supply-constrained, it’s likely to be top-down regulation which will force actual scale-up – with those working in sustainability in aviation likely hoping that other governments follow suit.  

California makes a small delay to climate rules

The last edition of this Briefing reported on the California Air Resources Board’s (CARB) climate rules, set to come into force later this year and affect over 4,000 companies. To keep you up to date, CARB has since announced that it will push off the initial rulemaking into Q1 2026. 

No deforestation regulation delay as EU U-turns the U-turn

The EU has dropped its plans to delay its flagship deforestation regulation EUDR by a year, as mentioned in the last Briefing, with the regulation now set to come into force at the start of 2026. However, a 6-month grace period on fines has been introduced. 

One Number: 79%

Proportion of Britons who support their pensions being invested into renewable energy, according to a UKSIF-commissioned survey – indicating broad support. Notably, 53% of those identifying as Reform voters supported such investments, higher than many might have expected. 

Shortlist 

LEGO has accelerated efforts to ditch natural gas from its factory operations, by deploying site-specific renewable heating systems such as geothermal heat in Hungary and a waste heat recovery system in China. 

IKEA has launched home solar and heat pump offerings for UK customers, in partnership with Soly and Aira, as more British homes turn to self-generation to combat the spike in utilities bills. 

Schroders has met its RE100 commitment a year early, meaning it now sources 100% of its electricity globally from renewable energy. 

To discuss any of these topics in more detail or speak to one of our Sustainability team about how to better your corporate sustainability efforts, email [email protected] -we'd love to hear from you.