The Rules Keep Moving. Your Sustainability Data Shouldn't.
- 5 hours ago
- 2 min read
The public comment window on the SEC's proposal to erase its own climate disclosure rule closed yesterday. That rule was adopted in March 2024 and stayed within weeks, so it never took effect. Europe reversed course as well by lifting the CSRD threshold to companies above 1,000 employees and €450 million in turnover, a change estimated to remove about 90% of expected filers. California pushed its first emissions filing from August 10 to a proposed November 10.
The shifting expectations have a cost, and it’s not the cost of measuring emissions. It is the cost of packaging them. Mario Draghi's competitiveness report priced CSRD compliance at €150,000 for a non-listed company and up to €1 million for a listed one. An analysis of 656 sustainability statements written to European standards showed the average length is 115 pages. The longest ran about 440. Almost none of that spending produced a more accurate GHG number.
BASF built the other kind of asset. In 2020, the company created a digital application to calculate cradle-to-gate product carbon footprints. It now covers nearly 45,000 products, carries certification against ISO 14067 and follows the GHG Protocol Product Standard. And the sustainability statement now sits inside the BASF Report alongside the financials rather than in a separate volume. Their Vice President of Corporate Sustainability took that internal method into the Together for Sustainability guideline which the wider chemical industry now uses.
BASF is no fan of the rulebook. It hosted the European Industry Summit at its Antwerp site in February 2024 where 73 industrial leaders handed the Antwerp Declaration to Ursula von der Leyen with a demand for streamlined legislation. Then-chief executive Martin Brudermüller signed it while serving as president of the European chemical industry council. The current chief executive said this year that the EU regulators ignore business reality on carbon pricing and that industry needs relief rather than more bureaucracy.
Today, Germany still has not written CSRD into national law, so BASF had no obligation to follow the European standards for 2025, but the company applied them anyways. A company that spent years instrumenting its own plants keeps publishing when the mandate evaporates though, because the measurement system runs the business rather than the filing.
Rules will move again, but emissions data built for internal decisions survives every one of those moves. Reporting built for a template survives none of them.
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