ESRS Standard
ESRS Standard
14 The company shall disclose its Transition plan for climate change mitigation.
15 The purpose of this disclosure requirement is to provide an understanding of the company's past, current and future climate change mitigation efforts to ensure that its strategy and business model are consistent with the transition to a sustainable economy and with limiting global warming to 1.5°C in accordance with the Paris Agreement and the goal of achieving climate neutrality by 2050, as well as with the company's exposure to coal, oil and gas activities, where applicable.
16. the information referred to in paragraph 14 shall include:
(a) An explanation of how the company's Targets are consistent with limiting global warming to 1.5°C in accordance with the Paris Agreement, with reference to the GHG emission reduction targets (as per disclosure requirement E1-4).
b) An explanation of the Decarbonisation levers identified and the main actions planned, including changes to the company's product and service portfolio and the introduction of new technologies, with reference to the GHG emission reduction targets (as per disclosure requirement E1-4) and the Value chain mitigation actions (as per disclosure requirement E1-3).
c) An explanation and quantification of the company's investments and financial resources to support the implementation of its Transition Plan, with reference to the mitigation actions (as per disclosure requirement E1-3) and, where applicable, taxonomy-compliant CapEx plans.
d) A qualitative assessment of the potential Locked-in GHG emissions associated with the company's key assets and products.
e) An explanation of Targets or plans to align economic activities with the criteria of Commission Delegated Regulation (EU) 2021/2139.
f) Information on significant CapEx amounts related to economic activities in the coal, oil and gas sectors
g) Information on whether the company is exempt from the Paris-aligned EU Benchmarks.
h) An explanation of how the Transition plan is embedded in the business strategy and financial planning.
i) Whether the plan has been approved by the Administrative, management and supervisory bodies.
j) An explanation of the company's progress in implementing the Transition plan.
17) If the entity does not have a Transition Plan, an indication of whether and when it will adopt one.
Application Requirement (AR)
Application Requirement (AR)
AR 1 A Transition plan refers to the company's climate protection efforts. When disclosing its transition plan, the company is expected to provide a detailed explanation of how it will adapt its strategy and business model to ensure compatibility with the transition to a sustainable economy and limiting global warming to 1,5°C in line with the Paris Agreement (or an updated international climate change agreement) and the Targets of achieving climate neutrality by 2050 with no or limited overshoot in accordance with Regulation (EU) 2021/1119 (European Climate Law) and, if applicable, how it intends to adjust its exposure to coal, oil and gas activities.
AR 2. sectoral pathways have not yet been defined for all sectors under public policies. Therefore, the disclosure on the consistency of the Transition plan referred to in paragraph 16(a) with the 1.5°C global warming target should be understood as an indication of the company's emission reduction target. The disclosure referred to in paragraph 16(a) shall be compared with the impact of a pathway towards 1.5 °C. This comparison should be based either on a sector-specific decarbonization pathway (if available for the company's sector) or on an economy-wide Scenario, bearing in mind its limitations (i.e., it is a simple transfer of emission reduction targets from the state level to the company level). AR 2 should also be read in conjunction with AR 26 and AR 27 and the sector-specific decarbonization pathways mentioned therein.
AR 26 & AR 27
AR 26 & AR 27
AR 26 When providing the information required under paragraph 34(d) and (e), the company shall provide the information for the target period by reference to a sector-specific, if available, or a cross-sectoral emission pathway consistent with the 1.5°C global warming limit. For this purpose, the company calculates a 1.5°C target-aligned baseline for the Scope 1 and Scope 2 GHG emission categories (and a separate one for Scope 3, if applicable) against which its own GHG emission reduction targets or interim targets within the respective categories can be compared.
AR 27 The reference target value can be calculated by multiplying the greenhouse gas emissions in the base year by either a sector-specific (sectoral decarbonization method) or cross-sectoral (absolute contraction methodology) emission reduction factor. emission reduction factor. These emission reduction factors can be derived from various sources. The company should ensure that the source used is based on an emission reduction pathway that is consistent with limiting global warming to 1.5°C.
AR 3. in providing the information required under paragraph 16(d), the company may take into account the following:
(a) the cumulative Locked-in GHG emissions associated with significant assets from the reporting year to 2030 and 2050 in metric tons of CO2 equivalent. This is assessed as the sum of estimated Scope 1 and Scope 2 emissions over the operational lifetime of the key active and committed assets. Major assets are those that are owned or controlled by the company and consist of existing or planned assets (such as fixed or mobile installations, facilities and equipment) that are sources of significant direct or energy-indirect GHG emissions. Fixed assets are the main assets that the company is most likely to use in the next five years.
b) the cumulative locked-in GHG emissions associated with the direct use-phase GHG emissions of sold products in metric tons of CO2 equivalent, measured as the sales volume of the products in the reporting year multiplied by the sum of the estimated direct use-phase GHG emissions over their expected lifetime. This requirement only applies if the company has identified the Scope 3 category "Use of products sold" as material in accordance with disclosure requirement E1-6 in paragraph 51.
c) An explanation of plans to manage (i.e., redesign, retire or phase out) its GHG- and energy-intensive assets and products.
AR 4. in providing the information required by paragraph 16(e), the company shall explain how the alignment of its economic activities with the provisions of Commission Delegated Regulation (EU) 2021/2139 will evolve over time to support its transition to a sustainable economy. In doing so, the company takes into account the key performance indicators required to be disclosed under Article 8 of Regulation (EU) 2020/852 (in particular taxonomy-compliant revenue and CapEx and, where applicable, CapEx plans).
AR 5. when providing the information required under paragraph 16(g), the company shall declare whether it is exempt from the Paris-aligned EU benchmarks in accordance with the criteria set out in Article 12(1)(d) to (g) and Article 12(2) of Commission Delegated Regulation (EU) 2020/1818 (Climate Transition Benchmarks Regulation).
Examples from previous practice
Examples from previous practice
Examples serve only as an indication of how a disclosure obligation has been stated by other companies to date. Audited ESRS reports are not yet available. There is no guarantee of accuracy and completeness.
E1-1 - Transition plan for climate change mitigation
Our Transition plan: Climate neutrality and 1.5 degree Targets
Our Transition plan is geared towards limiting global warming to 1.5°C and achieving climate neutrality by 2050. These Targets are in line with the Paris Agreement and the EU's climate targets.
Focus on Scope 3 emissions
As a provider of logistics and transportation services, Scope 3 emissions account for around 98% of our emissions. These are primarily generated in the upstream Value chain, for example by carriers in the shipping, aviation, road and rail transport sectors who provide capacity on behalf of our customers. These emissions are also part of our customers' Scope 3 emissions.
Levers for decarbonization
Our Emission Reduction Plan focuses on minimizing the carbon footprint of our customers' supply chains. We use various approaches to achieve this:
Low-emission logistics: selecting partners who actively reduce their emissions, for example by using more sustainable means of transportation.
Value chain collaborations: working with producers of sustainable fuels such as Sustainable Aviation Fuel (SAF).
Science-based Targets: Setting short and long-term emissions targets for Scope 1, 2 and 3.
Internal emission reduction: Actions to reduce emissions from our own business activities.
Science-based Targets
Our emissions targets are science-based. Back in 2020, we were one of the first logistics service providers in our region to commit to the 1.5°C Targets of the Science Based Targets Initiative (SBTi). In 2023, our short-term target was validated and we submitted a long-term target to achieve net-zero emissions in accordance with the SBTi's Corporate Net-Zero Standard.
Integration into the corporate strategy
Our Transition plan is an integral part of our strategy and is funded through the annual business and financial planning process, which is approved by the Executive Board and the Supervisory Board. Responsibility for the implementation of the ESG strategy, including the Transition plan, lies with our CFO. In addition, we incorporate greenhouse gas emission reduction performance metrics into our management incentive systems to ensure that Targets are effectively implemented.
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