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TAC Public Meeting May 2026 Paper 3: SASB Standards preliminary analysis of Agricultural Products and Meat, Poultry & Dairy SASB Standards

Agenda Paper 3

Executive summary

Header	Data
Date	19 May 2026
Paper reference	2026-TAC-012
Project	Proposed amendments to SASB Standards – Phase 1 Part 2
Topic	Preliminary analysis of Agricultural Products and Meat, Poultry & Dairy SASB Standards

Objective of the paper

This paper sets out the TAC Secretariat's preliminary technical analysis of the proposed amendments to the Agricultural Products and Meat, Poultry & Dairy SASB Standards, as published in the ISSB's Exposure Draft on 26 March 2026. The paper:

presents proposed responses to the ISSB consultation questions and related rationale for the responses;
explains the supporting evidence and technical analysis, grounded in the UK context and the international markets in which UK companies operate; and
invites TAC members' views on whether further analysis is needed and whether the proposed directions are appropriate ahead of drafting the formal comment letter.

This is an internal working paper and does not represent a formal TAC position.

Decisions for the TAC

The TAC is asked to review the considerations set out by the TAC Secretariat and provide any comments.

Appendices

Appendix 1: Supplementary explanatory information on technical matters.

This paper has been prepared by the Secretariat for the UK Sustainability Disclosure Technical Advisory Committee (TAC) to discuss in a public meeting. This paper does not represent the views of the TAC or any individual TAC member.

Context

1The International Sustainability Standards Board (ISSB) published an Exposure Draft SASB/ED/2026/1 on 26 March 2026, proposing amendments to three SASB Standards: Agricultural Products (FB-AG), Meat, Poultry & Dairy (FB-MP), and Electric Utilities & Power Generators (IF-EU). This paper addresses the two Food and Beverage sector standards, FB-AG and FB-MP. The third standard, IF-EU will be covered in next month's instalment of the technical analysis which will incorporate stakeholder views on this standard.

2In making amendments to the SASB Standards, the ISSB's overarching objectives as set out in BC21 of the Basis for Conclusions are to:

improve the international applicability of the standards, which were originally developed primarily for United States market conditions;
enhance interoperability with IFRS S1, IFRS S2, GRI, and TNFD; and
incorporate and field test topics relevant to nature, human capital and supply chain sustainability that have grown in investor relevance since the original SASB Standards were published.

Key proposed changes: Agricultural Products SASB Standard

3The most structurally significant change is the expansion of the scope of the Agricultural Products SASB Standard (FB-AG) to include direct farming operations or ‘own operations'. The expanded scope recognises three types of entities: entities with direct farming operations only, entities that source from farms and integrated entities that do both. This reflects the reality of some UK-listed and UK-investor-backed agricultural businesses, particularly plantation operators in Africa, Latin America, the Pacific and Southeast Asia that grow through own operations, outsource from smallholder farmers and process agricultural commodities. Previously, FB-AG applied predominantly to trading and processing entities.

4Regarding the scope change, BC54 and BC59 explain that the ISSB decided not to create a separate industry standard for direct farming, on the basis that entities, particularly in emerging markets, that undertake direct farming generally do so alongside core processing activities (which are covered in the existing Standard). In addition, other listed entities that carry out direct farming only typically do so in partnership with smallholder farmers, from whom they source crops, and these smallholder farmers do not directly report sustainability-related information. For these reasons, expanding the existing Standard by adding two new own-operations-focused topics, Land Use & Ecological Impacts and Labour Conditions, was considered an optimum option that would allow entities to apply the disclosures most relevant to their specific business models.

5In terms of disclosure topic, three new topics are introduced, two are restructured and one is removed as described below:

Food Loss & Food Waste: Is a new topic reflecting UN Food and Agriculture Organisation's (FAO) food loss definition at farm level.
Land Use & Ecological Impacts: Introduces six new spatial footprint and deforestation-free metrics aligned with TNFD;
Labour Conditions: A new human capital topic for own operations anchored in ILO Conventions 29 and 138.
Environmental and Social Supply Chain Management topics replacing the legacy 'Ingredient Supply Chain' topic with a two-part structure covering deforestation-free sourcing and human rights due diligence (HRDD).
The Genetically Modified Organisms (GMO) Management topic is removed based on initial stakeholder feedback obtained by the ISSB.

6GHG Emissions, Energy Management, Water Management, Food Safety and Workforce Health & Safety were retained with some revision to metrics.

Key proposed changes: Meat, Poultry & Dairy SASB Standard

7The scope has been revised to distinctly recognise own operations and third-party sourcing, consistent with the approach taken in the Agricultural Products SASB Standard. This is reflected in the expansion of metrics within the existing Land Use & Ecological Impacts topic to capture own operations. In addition, the scope has been expanded to include live animal transportation as a business activity, reflecting its relevance to animal welfare, disease transmission and regulatory compliance. The Standard has also been updated to recognise that some entities produce and distribute their own feed.

8Four new disclosure topics are introduced, two are restructured as described below:

Land Use & Ecological Impacts: a new own-operations topic introduces six TNFD aligned metrics.
Nutrient Management, a new topic addressing nutrient pollution risks
Antibiotic Use, a standalone topic, separated from Animal Health & Welfare to reflect its relevance to antimicrobial resistance.
Environmental and Social Supply Chain Management, restructured to replace two legacy supply chain topics.
Animal Health & Welfare is restructured to focus on welfare practices and biosecurity only.

9The most consequential question in the FB-MP proposals is the GHG amendments. The revised GHG emissions topic retains a Scope 1 focus, requiring disclosure of gross Scope 1 emissions disaggregated by greenhouse gas type, with methane identified as a mandatory percentage sub-disclosure of the total. One ISSB Board member, Dr Barker, filed a formal Alternative View (AV1-AV33) dissenting from this approach. Drawing on data from the FAO Global Livestock Environmental Assessment Model (GLEAM), the Alternative View argues that approximately 85–95% of the lifecycle GHG emissions of integrated meat and dairy companies originate upstream primarily from enteric fermentation, manure management and feed production and that restricting GHG disclosure to Scope 1 systematically understates the climate risk profile of entities in this sector. He argues that investors cannot adequately assess climate-related risks without disclosure of upstream Scope 3 Category 1 emissions.

10emissions. Notably, CSRD/ESRS E1 already requires large EU entities to disclose Scope 3 Category 1 emissions. Other changes include: replacement of GFSI audit metrics with internationally applicable food safety certification standards, addition of a water discharge destination and treatment metric; alignment of Workforce Health & Safety metrics with GRI 403-9 and revision of GHG emissions to align with IFRS S2.

Analysis

11The following pages present a tabular analysis of the proposed amendments to the two SASB Standards. The analysis is structured by standard, starting with the Agricultural Products SASB Standard and followed by the Meat, Poultry & Dairy Standard. Within the table, the analysis is organised under thematic headings. These themes cover: the scope of the standard or industry description; the disclosure topics and associated metrics; supply-chain management disclosures (analysed separately given the ED have specific questions to this topic); and considerations relating to international applicability, interoperability and proportionality mechanisms.

12An AI-assisted tool was used, where appropriate, to support research and analysis, with outputs reviewed and validated.

13For the purposes of this analysis, the related Exposure Draft questions have been grouped to avoid duplication and overlap in the analysis.

14For each theme or area analysed, the table sets out:

Nature of the proposed changes;
the ISSB's rationale for those changes, as reflected in the Basis for Conclusions;
our research findings, including reviews of current UK reporting practice, relevant literature and interoperability assessments; and
preliminary points proposed for inclusion in the response letter, for the TAC's review and consideration.

15An appendix has been provided to include further explanatory information on technical matters discussed in the paper.

Questions for the TAC

Does the TAC agree with the proposed positions set out in the technical assessment?
Does the TAC consider that there are areas where the TAC Secretariat should conduct further research before taking a position, and if so, which areas?
Does the TAC wish to express a view on Dr Barker's Alternative View (AV) on Scope 3 upstream emissions for the Meat, Poultry & Dairy SASB Standard, and if so, does it support or not support his AV?

Preliminary response considerations and technical assessment

Agricultural Products SASB Standard (FB-AG) – Questions Q1(a) to Q1(i)

Q1 (a) - Do you agree with the proposed Agricultural Products industry description? Does it accurately describe the business activities of entities in this industry? Why or why not?

Q1 (b) - Do you agree with the proposed inclusion of direct farming operations in the scope of the industry classification? Why or why not?

Q1 (c) - Do you agree that the proposed industry description makes it clear that the intended scope of entities in the industry classification includes entities with direct farming operations, entities that source products from farms (including, for example, outgrowers, contract farmers and co-operatives) and entities that do both? Why or why not?

Preliminary response position: Agree with proposals in all three questions. In relation to Question 1(c), the response letter should also incorporate comments and suggested improvements set out in the 'suggested response letter comments for the TAC's consideration' row of analysis table below.

Rationale for agreeing: The revised industry description is internationally applicable and better reflects the business models of UK entities operating across the agricultural products value chain. Findings from our review of UK entities involved in agricultural commodities in emerging markets, including palm oil, tea, fruit and forestry indicate that these entities predominantly operate owned farming activities (direct farming), complemented by outgrower schemes alongside other forms of third-party sourcing. As a result, their business models are aligned with the proposed new industry scope. In addition, the distinction between direct farming and third-party sourcing provides an appropriate basis for decision-useful information supporting both investors and preparers in the assessment of sustainability-related risks and opportunities.

1.1 Detailed analysis of change in industry scope/description

Nature of proposed amendment

The current industry description narrowly focuses on processing, trading, distributing commodities and direct farming is excluded.

The revised description incorporates direct farming and distinguishes three types of entities (tripartite):

entities engaged in direct crop production;
entities sourcing from farms, including through outgrowers, contract farmers and co-operatives; and
integrated entities undertaking both activities.

'Own-operations' or direct farming metrics (FB-AG-160a.1 to 6) apply to types described as (i) and (iii) above; while supply chain metrics (FB-AG-430c.1 to 3 and 430d.1 to 3) apply to types (ii) and (iii).

'Animal feed' is removed to avoid codification in FB-AG as companies in the Meat, Poultry & Dairy industry may also produce their own feed.

ISSB's rationale for changes (per Basis for Conclusions)

The primary driver for the changes is international applicability. BC51-BC56 explains that the original description was too narrowly drawn reflecting the business models for US and European processing entities only rather than the full range of global agricultural businesses.

BC57-BC60 explain that the tripartite scope structure responds to stakeholder feedback that entities in emerging markets span across the value chain, combining direct farming, third party sourcing and processing (BC52).

BC54 explains that the ISSB considered whether to create a separate industry for direct farming but decided not to (BC59), on the basis that emerging market entities typically conduct direct farming operations alongside core processing activities already covered in the current Standard. In addition, other listed entities engaged in direct farming only, do so through partnerships with smallholder farmers who supply crops but do not directly report sustainability-related information. As a result, the ISSB introduced two new disclosure topics in the existing standard to cover direct farming activities (Land Use & Ecological Impacts and Labour Conditions) and two new supply chain management topics (environment and social) to cover third-party sourcing activities. The third-party sourcing-focused activities characterise the majority of entities by number and market capitalisation (BC60).

BC56 explains that the removal of 'animal feed' from the existing industry description prevents confusion from dual classification, as animal feed is also referenced in the Meat, Poultry & Dairy SASB Standard for entities that produce their own feed.

Findings from UK- & international-related research & interoperability findings

Findings from UK company review

Five UK AIM-listed companies were reviewed. Two operate palm oil plantations in Southeast Asia and the Pacific and report both own-estate production and sourcing from outgrower or smallholder schemes. As a result, these entities fall within the revised scope of the Standard, which captures own operations as well as third-party sourcing.

Of the two, one entity reports that 65% of production is from own estates, 20% from smallholder schemes and 15% from independent sellers. The other reports 73% of production from own estates and the remaining 27% sourced from smallholder schemes.

One UK AIM-listed company operating tea, fruit and forestry estates across Africa, Latin America and South Asia reports direct farming (70–80% of output) alongside smallholder schemes (20–30%).

Two UK AIM-listed companies operating agri-distribution/sourcing businesses exclusively within the UK have no direct farming activities. The scope expansion would have limited impact on them.

Note: None of the companies reviewed apply the SASB Standards in their reporting. The largest palm oil company operating in Southeast Asia and the Pacific instead reports under the GRI Standard covering agriculture. There are many overlaps between GRI 13 (Agriculture, Aquaculture and Fishing) and FB-AG.

Interoperability findings to assess appropriateness of scope change

The proposed scope change aligns with TNFD's LEAP 'Locate' step, which requires identification of direct operations (in this case direct farming) in and near sensitive ecosystems mapping directly to FB-AG-160a.2.

ESRS E4 – Biodiversity & Ecosystems (para 18-19) embeds the concept of 'own operations' versus 'value chain', giving some alignment with the tripartite framing introduced through the Land Use & Ecological Impacts and Environmental Supply Chain Management reporting. It should be noted that the ESRS concept of value chain is broader than that of FB-AG.

GRI 13 covers the full agricultural value chain from crop production through processing, aggregation, storage and trading and notes that vertically integrated entities may own or manage production, processing and distribution within a single entity.

The CDP Agriculture questionnaire (v2024) covers direct farming operations, outgrowers and sourced commodities within the reporting boundary aligned with the proposed changes.

Suggested response letter comments for the TAC's consideration

Investor relevance of new scope

UK institutional investors managing sustainable agriculture funds may require land use and nature data to assess portfolio alignment with deforestation-free commitments and nature risks. The scope expansion would improve the decision-usefulness of information available to such investors.

Guidance for integrated entities on boundaries between direct farming and third-party sourcing

The ISSB has structured the revised standard to distinguish direct farming activities, reported under the Land Use & Ecological Impacts metrics, from third-party sourcing activities, reported under the two Supply Chain Management metrics (see BC59). However, for entities with integrated farming models (as the case with UK listed described above), the distinction between own operations and third-party sourcing (including contract farming and outgrower schemes) may not always be clear in practice depending on outgrower contracts. Appendix items A1.2, A1.4 and A1.5 set out scenario examples that illustrate potential application challenges arising from the proposed structure of the Standard, particularly in the absence of a clear definition of direct farming or illustrative guidance. In addition, how farming activities are classified, as either direct operations or third-party sourcing, determines whether the resulting GHG emissions are reported under Scope 1 or Scope 3.

In this context, the ISSB could consider providing illustrative guidance or examples to support the classification of different farming arrangements, for example by reference to the degree of control exercised by the entity.

In addition, defining direct farming within the technical protocols could help avoid potential misinterpretation, particularly where complex or hybrid arrangements exist. The absence of a definition for this key term is inconsistent with the approach taken elsewhere in the Standard, where key terms such as deforestation, human activity, food loss, forced labour and others are defined. We note that the industry description includes the term 'direct crop production', which is insufficient to determine its meaning in the context of complex farming arrangements. It should be noted that the term 'direct farming' is also used in a number of places in the proposed Meat, Poultry & Dairy SASB Standard, which relates to livestock raising rather than crop production, thereby creating further confusion as to the intended meaning of 'direct farming'.

Thus, a clear definition and illustrative guidance would support the consistent distinction and application of direct farming disclosures under the Land Use & Ecological Impacts metrics FB-AG-160a.1 to 160a.6 and the Labour Conditions metric FB-AG-310a.1, as distinct from third-party sourcing disclosures under the Supply Chain Management metrics FB-AG-430c.1 to 430c.3 and FB-AG-430d.1 to 430d.3.

Appendix items A1.2-A1.5 describe different farming arrangements.

Proportionality mechanism for entities with integrated operations or complex farming arrangements

Considering the unique scope extension made to this Standard (as an alternative to developing a new industry Standard), the ISSB could consider enhancing the technical protocols by drawing more explicit attention to the application of judgement and materiality considerations. This would support entities with integrated operations or complex farming arrangements in determining when direct farming or third-party sourcing activities fall below the materiality threshold and therefore do not require disclosure under the Land Use and Ecological Impacts or Supply Chain Management topics, respectively. For example, where an entity determines that direct farming represents only a small proportion of its overall operations and is not material, it may reasonably conclude that only third-party sourcing information should be reported under the Supply Chain Management metrics.

While it is understood that the ISSB expects entities to apply judgement and materiality considerations in all reporting decisions, the role of the SASB Standards may not be interpreted consistently by all stakeholders. Some may view the inclusion of metrics within the Standard as implying that those metrics are presumed material for all entities within the industry.

Scope clarity regarding commodity trading activities

Agricultural commodities trading is included in both the existing and proposed revised industry descriptions. However, neither the Basis for Conclusions nor the technical protocols clarifies whether this scope overlaps with agricultural commodity derivatives trading undertaken by financial services entities. Consistent with the approach taken in the Electric Utilities & Power Generators SASB Standard where an explicit note directs companies with gas-related activities to apply the Gas Utilities SASB Standard for those activities, the ISSB could provide a similar note. This would help clarify the intended scope of agricultural commodities trading and distinguish physical commodity trading from derivatives trading.

Q1 (d) - Do you agree that the proposed disclosure topics in the Agricultural Products SASB Standard would accurately identify the sustainability-related risks and opportunities that could reasonably be expected to affect the prospects of entities in this industry? If not, what revisions would you suggest and why?

Q1 (e) - Do you agree that the proposed metrics and technical protocols in the Agricultural Products SASB Standard would help an entity provide primary users with decision-useful information about sustainability-related risks and opportunities? If not, what revisions would you suggest and why?

Preliminary response position: Neither agree nor disagree with the proposals in both questions. However, the response letter could include observations on certain issues identified in relation to certain topics and associated metrics, for the ISSB's consideration in improving the proposals.

Rationale for neither agreeing nor disagreeing: The three new plus other restructured and revised disclosure topics, together with their associated disclosure and activity metrics, introduce a number of new data points and reporting requirements. Our review of current corporate reports as set out in the analysis table below indicates that reporting against some of the proposed topics and metrics ranges from limited to highly variable among companies. In light of the limited stakeholder engagement and the limited use of the Agricultural SASB Standard in the UK, the Secretariat has not gathered enough real-world practice evidence to support an explicit position of agreement or disagreement with the proposals. Nevertheless, the analysis has highlighted specific areas that may warrant further consideration by the ISSB in order to improve the proposed amendments.

1.2 Land Use & Ecological Impacts (new disclosure topic)

Nature of proposed amendment

This new disclosure topic introduces the following six metrics: FB-AG-160a.1 (spatial footprint relates to what is owned/controlled), FB-AG-160a.2 (proximity to sensitive areas reflects risk exposure), FB-AG-160a.3 (sustainably managed land reflecting opportunity), FB-AG-160a.4 (deforestation-free status reflecting regulatory and transition risk), FB-AG-160a.5 (at-risk products reflecting scenario identification), FB-AG-160a.6 (strategy narrative).

ISSB's rationale for changes (per Basis for Conclusions)

BC57-BC78 explains that the ISSB undertook a review of all FB-AG disclosure topics. The overarching rationale is threefold: (i) remove US-centric topics and expand to reflect emerging market operational realities consistent with the scope change; (ii) align with the ISSB's nature and human capital research projects; and (iii) restructure supply chain management to reflect human rights due diligence practice.

Findings from UK- & international-related research & interoperability findings

Findings from UK company review

Three UK AIM-listed companies operating in emerging markets report on some land use and ecological aspects, though with widely varying scope and depth. This confirms the topic's current relevance but highlights inconsistent current practice.

For spatial footprint data (FB-AG-160a.1 and 160a.2), one UK integrated palm oil farming company reports partial Geographic Information System (GIS) based spatial data. The remaining reviewed entities don't report this and may need new data infrastructure. Appendix items A1.6 provides explanatory information about how GIS works and supports spatial footprint reporting.

Interoperability findings

ESRS E4 (Biodiversity) covers land use across own operations and upstream value chain indicating some alignment with the new Land Use & Ecological Impacts disclosure topic.

FB-AG-160a six new metrics on Land Use & Ecological impacts have some collective alignment with TNFD's Locate, Evaluate & Assess steps.

GRI 13 covers landrights and small holder farmer rights.

CDP Agriculture covers deforestation, land use and water.

Suggested response letter comments for the TAC's consideration

Clarity on the term 'Ecological Impacts'

The disclosure topic Land Use & Ecological Impacts uses the term 'impacts'. However, the perspective from which the term is intended to be applied is not clearly articulated in both the technical protocols and Basis for Conclusions. This may create confusion as the concept of impact is commonly understood differently in other contexts like double materiality assessments in ESRS and impact reporting in GRI. Explicit clarification of the intended lens would improve consistency of application and comparability among entities.

Clarity on certain Land Use & Ecological Impacts metrics

Basis for Conclusions paragraph BC57(a) explains that the new disclosure topics on Land Use & Ecological Impacts and Labour Conditions are intended to focus on direct farming activities. However, within the Land Use & Ecological Impacts disclosure topic, only the final three of the six metrics (FB-AG-160a.4 to FB-AG-160a.6) explicitly refer to 'direct farming' in their description. A similar explicit reference to direct farming is also rightly included in the single metric (FB-AG-310a.1) under the Labour Conditions topic (topic specifically for direct farming activities). By contrast, the first three Land Use & Ecological Impacts metrics (FB-AG-160a.1 to FB-AG-160a.3), which require disclosure of total farm area, the percentage of area near sensitive locations and the total area sustainably managed, do not explicitly reference 'direct farming' in their description. While we note that the technical protocol includes an explicit note below the topic summary stating that all metrics relate only to direct farming, this note is relatively inconspicuous and may not be readily visible to all users who may focus on the metric descriptions only. Thus, the proposed inconsistent labelling of the metrics descriptions, where some explicitly refer to direct farming and others do not, may lead to differing interpretations and inconsistent application. For example, entities may include both direct farming and third-party sourcing within the first three metrics, which do not explicitly reference 'direct farming'.

Unit of measure for spatial footprint

All three UK-listed companies reviewed disclose spatial footprint data in hectares. However, the proposed metric requires this information to be reported in square kilometres, which appears inconsistent with current reporting practice. There is no explanation as to whether the ISSB considers square kilometres to be a more appropriate internationally comparable unit of measurement than hectares.

'Sustainably managed land' credibility

Metric FB-AG-160a.3 requires disclosure of the spatial footprint of sustainably managed land by product. While the technical protocol defines ‘sustainably managed’, it does not indicate credibility of sustainable management which is key for investors and other users of reports. The ISSB could therefore consider referencing commonly used, product-specific sustainability certification standards (for example, RSPO, RTRS, ProTerra, Rainforest Alliance, Fairtrade or 4C) or compliance with jurisdiction regulatory framework on sustainable land management as areas to enhance credibility will also minimising greenwashing risks. Appendix items A1.7 to A1.8 explain these commonly used certification standards in the industry.

1.3 Labour Conditions (new disclosure topic)

Nature of proposed amendment

The new Labour Conditions disclosure topic is intended for the entity's own operations only (or direct farming) focusing on forced and child labour risks. It introduces a single qualitative, process-based metric (FB-AG-310a.1) addressing policies, controls and procedures to manage these risks.

ISSB's rationale for changes (per Basis for Conclusions)

BC89 explains that the proposed qualitative metric for Labour Conditions disclosure topic is intended to capture processes that 'vary by location and agricultural product' anchored in ILO Forced Labour Convention No. 29 and ILO Minimum Age Convention No. 138.

Findings from UK- & international-related research & interoperability findings

Findings from UK company review

All five UK companies reviewed produce a UK Modern Slavery Act statement, providing a foundation for the new FB-AG-310a.1 metric.

One company with operations in Southeast Asia and the Pacific have additional disclosure of its adherence to ILO Declaration on Fundamental Principles and Rights at Work and ILO core conventions, providing some further foundation of alignment with the proposed metric.

Interoperability findings

ESRS S1 (Own Workforce) also covers labour conditions, thus there is some conceptual alignment with FB-AG-310a.1 although ESRS is more prescriptive.

Suggested response letter comments for the TAC's consideration

Limited decision-usefulness of the current qualitative Labour Conditions metric

The Labour Conditions disclosure metric (FB-AG-310a.1) is currently framed as a qualitative, process-based disclosure. Given that this topic applies explicitly to direct farming operations where the reporting entity has better visibility of workforce, the ISSB could consider introducing a quantitative sub-metric, for example on the percentage of employees covered by fair-wage provisions. Such quantitative information may be more decision-useful to investors than a purely process-based disclosure.

1.4 Food Loss & Food Waste (new disclosure topic)

Nature of proposed amendment

Food Loss & Food Waste was added as a new disclosure topic and introduces the Food Agricultural Organisation (FAO) definition for food loss. It requires reporting of food loss at farm and processing level (i.e. direct operations only). The two metrics are: a quantitative disclosure on total food loss and diversion (FB-AG-150a.1) and a qualitative disclosure on value-chain food-waste strategies (FB-AG-150a.2).

ISSB's rationale for changes (per Basis for Conclusions)

BC73 explains specific financial materiality considerations for food loss that the ISSB have considered: (a) it represents avoidable operating costs and negatively affects yield; (b) reducing it can improve margins and supply reliability; (c) diversion to higher-value uses supports circular economy revenues; and (d) emerging food loss regulations present regulatory risks.

Findings from UK- & international-related research & interoperability findings

Findings from UK company review

Of the five UK companies reviewed, one integrated palm oil operator in Southeast Asia and Pacific) reports under GRI and has a GRI food loss metric. However, it discloses 'data not available' indicating potential challenges for reporting the new quantitative metric FB-AG-150a.1. No food loss disclosure were found among the remaining four companies indicating this topic would represent an entirely new data-collection requirement.

Suggested response letter comments for the TAC's consideration

Omission of supply chain food loss disclosure & lack of measurement methodology

The proposed metrics require the reporting of food loss only from direct farming operations. As a result, entities with third-party sourcing activities only would not report food loss. In addition, integrated entities would report only the direct-operations component of their total food loss. However, food loss is a significant financial issue across all stages of the value chain, with substantial losses occurring during transport, storage and other downstream activities. The exclusion of supply chain food losses appears inconsistent with the significance of food loss described by the ISSB in BC73.

In addition, the Exposure Draft does not provide an indicative methodology for measuring food loss and food waste, nor do the technical protocols (FB-AG-150a.1) require entities to disclose the methodologies they have used. The ISSB could consider referencing established international frameworks for measuring food loss such as The Food Loss and Waste Accounting and Reporting Standard (also cited in GRI footnotes), as illustrative guidance without mandating their adoption. At a minimum, the technical protocols could be expanded to require entities to disclose the measurement methodology applied. This would enhance comparability and, at the very least, the disclosure of a company's methodology would enable users to better assess the robustness and credibility of reported food loss and waste metrics.

1.5 GHG Emissions

Nature of proposed amendment

The GHG Emissions disclosure topic has been retained without modification. The Scope 1 emissions metric (FB-AG-110a.1) has also been retained. In addition, a new sub-metric has been introduced to disclose the percentage of emissions subject to emissions-limiting regulations.

ISSB's rationale for changes (per Basis for Conclusions)

BC63-BC67 clarify that the GHG emissions disclosures focus on risks and opportunities from core agricultural activities, including emissions from soil management and land-use change, which may affect costs and market access due to regulatory and market pressures.

Findings from UK- & international-related research & interoperability findings

Findings from UK company review

UK companies reviewed reports GHG emissions scopes 1, 2 and 3. However the new sub-metric of percentage emissions subject to emissions-limiting regulations is currently not reported by the companies reviewed.

GHG Protocol Land Sector and Removals Standard

The GHG Protocol Land Sector and Removals (LSR) Standard, published on 30 January 2026 and effective from 1 January 2027, was developed to address gaps in corporate greenhouse gas accounting for land-based emissions, particularly those arising from agricultural activities and agricultural supply chains. The Standard is explicitly scoped to agriculture and land management (excluding forestry in its initial version), reflecting the historical under-coverage of emissions from farming systems under existing GHG Protocol standards. The LSR Standard requires accounting and reporting for land-use change (LUC) emissions, net biogenic CO2 emissions from land management and emissions from biogenic products. It also introduces structured rules for defining spatial boundaries, with reporting requirements linked to the level of physical traceability, ranging from regional sourcing areas to farm- or field-level information.

Suggested response letter comments for the TAC's consideration

No reference to GHG Protocol Land Sector and Removals (LSR) Standard

The proposed revisions to the GHG emissions topic do not reference the GHG Protocol LSR Standard in either the technical protocols or the Basis for Conclusions. Given that the LSR Standard provides guidance on accounting specific to agricultural and land-based emissions and removals, it is unclear why its relevance has not been acknowledged in the ISSB's SASB materials accompanying this Exposure Draft. This is particularly relevant for agricultural companies setting science-based targets, which may require alignment with the LSR Standard. We therefore recommend that the ISSB addresses the relevance of the LSR Standard, either in the Basis for Conclusions or the technical protocols, to help minimise potential interoperability and implementation challenges for preparers.

Q1 (f) - Do you agree that the proposed metrics in the Environmental Supply Chain Management and Social Supply Chain Management disclosure topics would support cost-effective disclosure of information that primary users need about sustainability-related risks and opportunities in the supply chain (for example, on soil health and water scarcity)? If not, what revisions would you suggest and why?

Preliminary response position: Neither agree nor disagree with the proposals in this question. However, the response letter could include observations on certain issues identified set out in the analysis table below within the row 'suggested response letter comments for the TAC's consideration'.

Rationale for neither agreeing nor disagreeing: The proposals introduce quantitative supply-chain metrics: FB-AG-430c.1 (percentage of sourced products that are deforestation- or conversion-free), FB-AG-430d.2 (percentage of sourced products certified to recognised traceability standards), and FB-AG-430d.3 percentage of high-risk suppliers subject to independent audit or verification). Given limited stakeholder engagement and insufficient evidence of real-world applicability of these metrics, there is not a sufficient basis to explicitly agree or disagree. However, the analysis below identified certain issues that the ISSB could consider to improve the identified areas.

1.6 Environmental Supply Chain Management disclosure topic (ESCM) - FB-AG-430c series

Nature of proposed amendment

Environmental Supply Management was added as a new disclosure topic. The topic introduces three new metrics that include: FB-AG-430c.1: Quantitative metric disclosing the percentage of agricultural inputs sourced as deforestation- and conversion-free, including associated targets. FB-AG-430c.2: Qualitative disclosure identifying priority sourced products exposed to nature- and climate-related physical risks. FB-AG-430c.3: Qualitative disclosure describing strategies for environmental resource management and sustainable supply chain practices.

ISSB's rationale for changes (per Basis for Conclusions)

BC97 explains the two-part SCM structure: Environmental SCM addresses how entities manage nature- and climate-related impacts in sourcing. BC82 and BC101 explain that Environmental SCM metrics (FB-AG-430c.1–.3) mirror the Land Use metrics (FB-AG-160a.4–.6), with a supply-chain rather than own-operations focus, creating a coherent parallel structure.

Interoperability findings

ESRS E4 (Biodiversity) covers deforestation-free sourcing with some alignment with FB-AG-430c.1.

Findings from UK- & international-related research & interoperability findings

Findings from UK company review

One AIM listed vertically integrated palm oil company reports RSPO-certified sourcing and states deforestation-free commitments in its ESG disclosure. This relates to metrics FB-AG-430c.1 and FB-AG-430c.2.

A UK FTSE 250 company (reporting under the Meat, Poultry & Dairy SASB) with pork, poultry and fish productions reports in its ESG disclosures having transitioned to full mass-balance RTRS-certified soya across its pig and poultry farming businesses. While the company reports under the Meat, Poultry & Dairy SASB Standard there are supply chain similarities to the requirements to metric FB-AG-430c.1 requiring percentage of agricultural inputs sourced as deforestation- and conversion-free, including associated targets. Appendix item A1.14 explains mass-balance certification.

Other international observations

The EU Deforestation Regulation (EUDR), effective 30 December 2026 requires operators to demonstrate, at plot level, that products are deforestation-free, legally produced and that Indigenous Peoples and local communities gave their Free, Prior and Informed Consent (FPIC).

Appendix item A1.10 provides explanatory information to the EUDR.

Suggested response letter comments for the TAC's consideration

Clarity on EUDR alignment

The ISSB could consider clarifying in the Basis for Conclusions or some guidance material whether FB-AG-430c.3 (requiring percentages of sourced agricultural products determined to be deforestation or conversion-free), is intended to complement EUDR due diligence disclosure requirements. The current split between environmental and social due diligence elements in the Agricultural Products SASB Standard may not align with the EUDR's integrated approach potentially creating duplicative reporting obligations yet the intended disclosure objective could be the same.

Nature of proposed amendment

Social Supply Management was added as a new disclosure topic. The topic introduces new metrics that include: FB-AG-430d.1: Qualitative disclosure describing human-rights due-diligence (HRDD) processes on labour conditions and impacts on local communities. FB-AG-430d.2: Quantitative metric disclosing the percentage (by weight) of sourced products certified to recognised traceability standards. FB-AG-430d.3: Quantitative metric disclosing the percentage of high-risk suppliers independently audited within the past three years, including a description of identified non-conformances and corrective actions.

ISSB's rationale for changes (per Basis for Conclusions)

BC99-BC102 explains that the Social Supply Chain Management disclosure topic addresses how entities screen, monitor and engage with suppliers on labour, human rights, ethics, corruption and community impacts, including indigenous peoples. This is consistent with the approach taken in the Processed Foods SASB Standard consulted in the July 2025 Exposure Draft.

Interoperability findings

ESRS S2 (Workers in Value Chain) covers the HRDD hence some level of alignment with the new metric FB-AG-430d.1.

Findings from UK- & international-related research & interoperability findings

Findings from UK company review

UK AIM-listed company operating tea, fruit and forestry estates across Africa, Latin America and South Asia reports Rainforest Alliance certification and supplier audit processes showing some alignment with FB-AG-430c.3.

Appendix A1.8 provides explanatory information on the Rainforest Alliance certification framework.

Of the five UK AIM companies reviewed, we did not find disclosures of a formal HRDD process mapping to the structure required by the HRDD metrics. UK Modern Slavery Act statements exist in the disclosures but do not go far enough to capture all required HRDD in (FB-AG-430d.1-430d.3). This topic introduces significant new data points.

Suggested response letter comments for the TAC's consideration

Community relations and rights of indigenous people

The social supply chain topic proposed by the ISSB does not currently address risks related to Indigenous Peoples, including land rights and community relations. A review of UK-listed entities operating plantations in emerging markets shows extensive collaboration with smallholder farmers through outgrower arrangements, indicating heightened risks. The ISSB could therefore consider improving this area or introducing a dedicated disclosure topic on Community Relations and the Rights of Indigenous Peoples, similar to that included in the extractives sector.

Q1 (g) - Do you agree that the proposals would improve the international applicability of the Agricultural Products SASB Standard and would lead to the disclosure of decision-useful information from entities in the industry regardless of their jurisdiction? Why or why not?

Q1 (h) - Do you agree that the proposed amendments would enhance the Agricultural Products SASB Standard's interoperability and alignment with other sustainability-related standards or frameworks? Why or why not? (Note that the ISSB is focused on providing material information for investors about the effects of sustainability-related risks and opportunities on an entity's prospects)

Q1 (i) - Are there any proposed metrics in the Agricultural Products SASB Standard that would benefit from the inclusion of specific proportionality mechanisms described in paragraphs BC47-BC48 of the Basis for Conclusions? If so, identify which metrics you believe would benefit from the introduction of such mechanisms and explain why?

Preliminary response position:

Agree with proposals in Q1 (g) and Q1 (h).

Rationale for agreeing: As set out in the analysis table below and reflected in the suggested response to Q 1(a), the revised industry description is more internationally applicable, as it better reflects the international status UK entities operating across multiple emerging markets.

Neither agree nor disagree with Q1 (i)

Rationale for neither agreeing nor disagreeing: As outlined in the analysis below, the TAC Secretariat has not obtained sufficient stakeholder evidence to determine whether the current proportionality mechanisms are adequate for entities applying the Standards. In addition, the Secretariat has identified areas where further proportionality mechanisms could be considered by the ISSB. Overall, there is therefore insufficient evidence to either explicitly agree or disagree with the ISSB's proposals. However, certain identified issues could be brought to the ISSB's attention for consideration in making improvements.

1.8 International applicability

Nature of proposed amendment

Global Food Safety Initiative (GFSI) audit metrics are removed as they are US-centric and replaced with internationally applicable food safety certification standards. GMO Management removed, reflecting variable regulatory relevance across jurisdictions.

Scope expanded to direct farming, reflecting emerging market agri-business structures.

ISSB's rationale for changes (per Basis for Conclusions)

Both BC94 and BC120 explain that the removal of the reference to GFSI was intended to align the Standard with the approach adopted in the Processed Food Exposure Draft published in July 2025, where stakeholder feedback had driven this change on the basis that it was US focused.

Findings from UK- & international-related research & interoperability findings

UK-specific international applicability

UK-listed companies operate agricultural products plantations across multiple jurisdictions including Indonesia, Malaysia, Kenya, Bangladesh, India and Latin America countries where land tenure frameworks, labour rights systems and certification infrastructure differ. Expanding the scope of the Agricultural Products to capture the operations of such entities demonstrate international applicability of the revised Standard.

Stakeholder evidence (July 2025 consultation)

A review of some stakeholder feedback to the ISSB (published on its site) on the July 2025 Exposure Draft indicated support for the removal of certain requirements, including references to GFSI and GMO management, as improving international applicability and reflecting jurisdictional variability in regulatory relevance.

Suggested response letter comments for the TAC's consideration

Suggested response position.

The Secretariat recommends that the TAC support the proposed improvements to the Standard aimed at enhancing international applicability, including scope changes and the removal of US-centric metrics.

1.9 Interoperability

Nature of proposed amendment

GHG emissions: cross-referenced to IFRS S2 para.29(a). Water: GRI 303 alignment in FB-AG-140a.1 and 140a.4. WHS: GRI 403-9 alignment in FB-AG-320a.1. Nature: TNFD LEAP alignment in FB-AG-160 series.

Findings from UK- & international-related research & interoperability findings

Stakeholder evidence (July 2025 consultation)

A review of stakeholder feedback to the ISSB (published on its site) on the July 2025 Exposure Draft highlighted the importance of interoperability as an iterative and collaborative process, with suggestions that closer coordination with existing sustainability frameworks could further support usability. Some feedback raised questions about the timing of introducing certain TNFD-aligned spatial metrics, noting potential risks of inconsistency if such requirements are developed in advance of the ISSB nature-related reporting materials.

Suggested response letter comments for the TAC's consideration

Interoperability mapping document

The ISSB could consider publishing a joint interoperability mapping document developed in collaboration with EFRAG covering the specific metrics across the SASB Standards to assist dual reporters applying both this SASB Standard and ESRS.

1.10 Proportionality provisions

Nature of proposed amendment

Targeted proportionality provisions brought in the Standard.

ISSB's rationale for changes (per Basis for Conclusions)

BC47-BC48 explain that the ISSB introduced proportionality mechanisms to allow entities to apply the Standards using all reasonable and supportable information available at the reporting date without undue cost or effort. These mechanisms are intended to make the requirements practicable in areas involving significant judgement or uncertainty, such as value-chain scope and certain measurements.

Suggested response letter comments for the TAC's consideration

Proportionality provisions

We note that, in the Basis for Conclusions, the ISSB explains that entities applying the SASB Standards as guidance for IFRS S1 and IFRS S2 may apply proportionality mechanisms under IFRS S1 in limited circumstances, particularly when making determinations related to the value chain. However, as this guidance is specific to entities applying IFRS S1 and IFRS S2, it is unclear whether entities using the SASB Standards on a standalone basis can rely on any proportionality provisions. In addition, this guidance is contained in the Basis for Conclusions rather than the Standard itself. The ISSB should therefore consider incorporating this concept directly into the Standard.

The Secretariat has also identified areas in Section 1.1 where the ISSB could consider introducing, or more clearly signposting, proportionality provisions to support entities with complex farming arrangements involving third parties.

Use of 'shall' in the technical protocols

The Exposure Draft notes that the SASB Standards may be used as a source of guidance for entities applying IFRS S1 and IFRS S2. However, the technical protocols continue to use mandatory 'shall' language throughout. The ISSB could consider clarifying how the Standards are intended to operate when used as guidance, as opposed to on a standalone basis, and whether the use of 'shall' remains appropriate in that context.

Meat, Poultry & Dairy SASB Standard (FB-MP) – Questions Q2(a) to Q2(g)

Q2 (a) - Do you agree with the proposed Meat, Poultry & Dairy industry description? Does it accurately describe the business activities of entities in this industry? Do you agree with the scope of activities included in the industry classification? Why or why not?

Preliminary response position: Agree with the scope amendments in the proposals and include comments about the narrow definition of meat in the scope and the need to explicitly exclude aquaculture in the Standard itself not just a note in the Basis for Conclusions.

Rationale for agreeing: Consistent with the Agricultural Products SASB Standard, the revised industry description for the Meat, Poultry & Dairy SASB Standard encompasses both primary livestock production and third-party sourcing, thereby reflecting the full value chain.

2.1 Detailed analysis of change in industry scope/description

Nature of proposed amendment

The scope of the Standard is structured in the same manner as the Agricultural Products SASB Standard, clearly distinguishing reporting between primary animal production and third-party sourcing activities. It has also been expanded to include live animal transportation as a distinct activity, in addition to the existing activities (animal raising, slaughtering, processing and packaging). Furthermore, the scope has been revised to reflect that some entities produce and distribute their own animal feed, which aligns with the removal of animal feed from the Agricultural Products SASB Standard.

The term 'meat' has been expanded to specify beef, pork and poultry, thereby indirectly excluding aquaculture and fisheries.

ISSB's rationale for changes (per BC)

BC103 explains that the scope revisions are intended to clarify the range of business activities covered. BC106-107 explains that aquaculture and fishing activities are excluded due to significant variation in underlying risks and opportunities with beef, pork, poultry and dairy.

The BC does not articulate the rationale for expanding the scope to include live animal transportation.

Findings from UK- & international-related research & interoperability findings

Findings from UK company review

A review of a UK-listed FTSE 250 company operating a vertically integrated pork and poultry business that includes pig and poultry breeding, rearing and finishing, supported by in-house feed milling and genetics, as well as downstream manufacturing shows that it currently reports under the Meat, Poultry & Dairy SASB Standard. Under the updated scope the entity would be required to apply both direct livestock production metrics (e.g. FB-MP-160a.series) and supply-chain-related metrics (e.g. FB-MP-430b and c series) as its outsource some of its meats from third-party farmers.

Interoperability findings

Live animal transportation regulations

The EU framework (Council Regulation (EC) 1/2005 on animal transport) and its UK equivalent, the Welfare of Animals (Transport) (England) Order 2006 create regulatory compliance obligations for UK processors operating in the UK and exporting live animals to the EU. Appendix items A1.15 &16 explain the EU and UK equivalent animal welfare regulations.

Suggested response letter comments for the TAC's consideration

Aquaculture and fisheries exclusion

Aquaculture and fisheries are not explicitly excluded in the industry description, although the BC explains their exclusion. While the ISSB has sought to address this indirectly by expanding the term 'meat', to specify beef, pork and poultry, this does not provide sufficient clarity. As noted above, a review of a UK FTSE 250 entity indicates the inclusion of fish production within its broader animal protein portfolio. An explicit note confirming the exclusion of aquaculture and fisheries within the Standard itself would therefore reduce ambiguity and support consistent and comparable application.

Impact of editorial changes on scope

In the industry description, the ISSB has narrowed the term 'meat', by specifying beef, pork and poultry. This creates uncertainty as to whether other meats, such as sheep and goat, are intended to be included or excluded. Such ambiguity could have implications for entities engaged in sheep and goat production. For context, the UK trade body, British Meat Processors Association (BMPA) considers sheep and goat meat as part of the wider category of meat. The ISSB could consider clarifying the intended scope to avoid inconsistent and incomparable application.

Live animal transportation metrics

The ISSB has expanded the industry scope to include live animal transportation but has not introduced corresponding metrics, which limits the decision-usefulness of this scope expansion for investors. This also appears inconsistent with other scope extensions for example, the inclusion of direct farming in FB-AG where supporting metrics are provided. The ISSB could consider introducing metrics such as in-transit mortality rates, journey distances or durations to better capture animal welfare and related regulatory risks.

Inconsistent terminology

The industry description uses the term 'animal raising' to refer to the primary production of livestock. However, several metrics (e.g. Land Use & Ecological Impact metrics, FB-MP-160a.8;FB-MP-160a.9) and the associated technical protocols use the term 'direct farming'. In the Agricultural Products SASB Standard, 'direct farming', though not defined, typically refers to direct crop production. The ISSB should consider harmonising these terms to improve clarity and consistent application.

Q2(b) - Do you agree that the proposed disclosure topics in the Meat, Poultry & Dairy SASB Standard would accurately identify the sustainability-related risks and opportunities that could reasonably be expected to affect the prospects of entities in this industry? If not, what revisions would you suggest and why?

Q2 (c) - Do you agree that the proposed metrics and technical protocols in the Meat, Poultry & Dairy SASB Standard would help an entity provide primary users with decision-useful information about sustainability-related risks and opportunities? If not, what revisions would you suggest and why?

Q2(d)- Do you agree that the proposed metrics in the Environmental Supply Chain Management and Social Supply Chain Management disclosure topics would support cost-effective disclosure of information that primary users need about sustainability-related risks and opportunities in the supply chain (for example, on soil health and water scarcity)? If not, what revisions would you suggest and why?

Preliminary response position: Neither agree nor disagree with the proposals in all three questions above. However, the response letter could include observations on issues identified in relation to certain topics and associated metrics, for the ISSB's consideration in improving the proposals.

Rationale for neither agreeing nor disagreeing: The three new plus other restructured and revised disclosure topics, together with their associated disclosure and activity metrics, introduce a number of new data points and reporting requirements. Our review of current corporate reports as set out in the analysis table below indicates that reporting against some of the proposed topics and metrics ranges from limited to highly variable among companies. In light of the limited stakeholder engagement, the Secretariat has not gathered enough real-world practice evidence to support an explicit position of agreement or disagreement with the proposals. Nevertheless, the analysis has highlighted specific areas that may warrant further consideration by the ISSB in order to improve the proposed amendments.

2.2 GHG Emissions disclosure topic

Nature of proposed amendment

The disclosure topic has been maintained as is. Metric: FB-MP-110a.1 - Scope 1 emissions is maintained and 2 new sub-metrics added to it requiring: percentage methane and percentage subject to emissions-limiting regulations.

ISSB's rationale for changes (per Basis for Conclusions)

BC108 explains that the ISSB's amendments seek to better reflect emissions risks from animal raising activities which produce significant methane and also to align GHG metrics across the SASB Standards and IFRS S2.

Dr Barker's Alternative View (AV) - Key arguments

Dr Barker's AV explains that FAO GLEAM data shows that approximately 85–95% of lifecycle GHG emissions for integrated meat and dairy companies originate upstream (enteric fermentation, manure management, feed production). A Scope 1 only metric as proposed in the Exposure Draft, systematically understates the sector's climate risk. He argues that investors cannot adequately assess climate-related financial risk without disclosure of upstream Scope 3 Category 1 emissions.

Findings from UK- & international-related research & interoperability findings

UK company reports findings

Review of UK-listed FTSE 250 company operating a vertically integrated pork, poultry and fish business shows that it reports Scope 1 emissions under the existing metrics. However, no evidence of specific methane disclosures was found.

Other UK specific findings on livestock GHG Emissions

The UK Climate Change Committee's 2024 Progress Report shows that agriculture accounts for around 10% of UK territorial greenhouse gas emissions, with methane from enteric fermentation and manure management as the dominant sources (CCC, 2024, Ch.1, pp. 33–39). The Committee also finds that policy and delivery in agriculture significantly lag other sectors, implying that without robust upstream (Scope 3) disclosure, investors cannot adequately assess climate-related financial risk in UK agri-food value chains.

Other findings on scope 3

FAIRR Initiative (2023): Analysis underpinning the Coller FAIRR Protein Producer Index shows that absolute emissions from the world's 20 largest listed meat and dairy companies continue to rise year-on-year, while most companies do not disclose Scope 3 supply-chain emissions, where livestock-related methane predominantly arises. FAIRR identifies improved upstream Scope 3 disclosure as a priority investor information need, reflecting the expectations of its investor network managing trillions of USD assets.

Interoperability findings

ESRS E1 requires disclosure of Scope 1, 2 and 3 greenhouse gas emissions from agricultural activities, including methane and nitrous oxide from livestock-related activities across the value chain, where climate change is material irrespective of sector classification. This demonstrates a clear precedent for activity-based scope expansion.

Suggested response letter comments for the TAC's consideration

Dr Barker's Alternative View

The Secretariat's preliminary assessment is that the TAC could consider expressing support for the spirit of Dr Barker's Alternative View, using measured language: 'The TAC invites the ISSB to consider whether guidance on Scope 3 Category 1 emissions disclosure for Meat, Poultry & Dairy entities would better serve investor decision-usefulness, noting that CSRD reporters are already disclosing this information.'

Additionally, in the TAC's letter to the ISSB following the technical assessment of IFRS S2, the TAC suggested that 'Scope 3 emissions are likely to benefit from industry-based guidance that reflects the types of assets or business activities that could determine which Scope 3 categories are material. Therefore, the TAC recommends that the ISSB collaborate with GHG Protocol and other global standard setters to develop further industry-based guidance for Scope 3 emissions reporting, specifically about which of the Scope 3 categories might be relevant to different industries and sectors'. This recommendation aligns with the AV put forward by Dr Barker.

Methane disclosure inconsistency with other Oil & Gas SASB Standards

The July 2025 SASB Exposure Draft (ED) for Oil & Gas Exploration & Production includes a standalone methane reduction target metric (EM-EP-110a.3). By contrast, Meat, Poultry & Dairy ED identifies methane as climate-related risk but includes no equivalent reduction target metric and no explanation is provided in the Basis for Conclusions. We suggest that the ISSB considers introducing a comparable methane reduction target disclosure to ensure consistency across industries where methane is identified as a climate-related risk.

2.3 Land Use & Ecological Impacts disclosure topic

Nature of proposed amendment

The Land Use & Ecological Impact disclosure topic has been maintained as it is in the current version of the Standard.

Five new metrics have been added and they include: FB-MP-160a.5 spatial footprint; FB-MP-160a.6 sensitive locations; FB-MP-160a.7 deforestation-free livestock; FB-MP-160a.8 nature- and climate-risk-sensitive products; FB-MP-160a.9 nutrient management coverage.

ISSB's rationale for changes (per Basis for Conclusions)

BC113-BC117 explains that the ISSB aims to better capture land-use and nature-related risks and opportunities in direct farming operations through activity-based scope expansion and TNFD-aligned metrics.

Findings from UK- & international-related research & interoperability findings

UK company reports findings

A review of a UK-listed FTSE 250 vertically integrated pork, poultry and fisheries business shows it discloses some land-use information but does not currently report spatial footprint data, deforestation-free sourcing or sustainably managed land areas. The proposed FB-MP-160a.5–160a.10 metrics would therefore require new data collection. Given that all the metrics under this topic are for 'own operations' and not third-party sourcing this could be feasible given its UK-based operations.

The company also reports that manure and litter are managed under nutrient management plans aligned with Red Tractor standards and Environment Agency guidance, with 69% of pork RSPCA Assured, 100% Red Tractor certified, and 100% of poultry production compliant with Red Tractor standards. Appendix A1.20 – 21 provides explanatory information on RSPCA and Red Tractor Assurance certification standards.

UK specific finding on nutrient management legislation

Under the UK Farming Rules for Water (SI 2018/151), most UK farmers with livestock above certain thresholds are required to produce a nutrient management plan (NMP). The Nitrate Vulnerable Zones (NVZ) regulations similarly require NMPs in designated zones. UK farmers with more than 10 hectares are generally required to have NMPs. The UK nutrient management rules are intended to prevent water pollution by ensuring fertilisers and manures are applied only where and when crops and soils need them, with records providing evidence of compliance and supporting enforcement. Appendix items A1.19 provides additional information about UK nutrient management regulations.

Suggested response letter comments for the TAC's consideration

Suggested improvement for nutrient management plan disclosures

FB-MP-160b.9 requires entities to disclose the percentage of livestock from direct farming operations that maintain and implement a written NMP. As noted in BC116, the objective of nutrient and manure management is to support soil health. However, the disclosure is limited by the absence of credibility on the NMP which is important to investors. A similar concern is also reflected in Dr Richard Barker's Alternative Views on Land use (AV26), where he notes that reporting the existence of a written NMP does not, in itself, convey decision-useful information about the plan's credibility, ambition or effectiveness.

In some jurisdictions, nutrient management is subject to regulatory requirements, providing a more objective basis for disclosure. For example, in the UK, DEFRA requires farms above 10 hectares to comply with nutrient management regulations. In addition, UK certification schemes such as Red Tractor support the credibility of nutrient management practices. In this context, the technical protocols could be strengthened by requiring disclosure of the percentage of direct farming livestock compliant with applicable nutrient management requirements, or by referencing credible certified management plans. Appendix A1.21 discusses Red Tractor Assurance.

Inconsistent metric land use metrics with Agricultural Products SASB Standard

The Agricultural Products SASB Standard introduces metric FB-AG-160a.3, which requires entities to disclose the total area of land they directly own or control that is sustainably managed. The metric is intended to demonstrate how entities manage land-use impacts and opportunities through practices that sustain productivity, promote plant and animal health, and protect water, air, biodiversity and ecosystems. However, a comparable metric has not been introduced in the Meat, Poultry & Dairy SASB Standard, despite similarities in other spatial footprint metrics between the two Standards. This indicates a potential gap in the coverage of land-use-related opportunities within the Meat, Poultry & Dairy SASB Standard.

The ISSB could consider addressing this gap by introducing a comparable metric in the Meat, Poultry & Dairy SASB Standard.

2.4 Other disclosure topic considerations

Nature of proposed amendment

Product Innovation has been added as a new topic with single qualitative metric (FB-MP-410b.1) requiring disclosure of use of innovation in food products.

Other retained topics: Energy Management; Water Management; Antibiotic Use in Animal Production; Workforce Health & Safety; Animal Health & Welfare (renamed).

ISSB's rationale for changes (per Basis for Conclusions)

The Basis for Conclusions explains that the ISSB has retained and introduced certain topics to reflect evolving sustainability-related risks, while restructuring others to improve clarity and decision-usefulness. In particular, it highlights the growing materiality of market transition risks (such as alternative proteins), distinguishes antibiotic use as a standalone human health and antimicrobial-resistance risk and refocuses animal health and welfare disclosures on qualitative practices and biosecurity to better capture risk management across diverse global livestock farming practices.

Findings from UK- & international-related research & interoperability findings

UK company reports review findings – Product Innovation topic

A review of a UK FTSE 250 vertically integrated pork and poultry company indicates that it already discloses information on product innovation, including plant-based product lines and reduced-fat reformulations. This suggests an existing foundation for reporting, although the information would need to be adapted to align with the proposed new metric.

Other UK specific findings for Labour Conditions topic

Meat and poultry processing activities are at least as labour-intensive as agricultural production and often present heightened labour-related risks as noted by findings from the UK Food Standards Agency, the British Meat Processors Association and DEFRA-commissioned reviews of labour shortages in the food supply chain, which document the sector's structural reliance on large workforces and the operational impacts of persistent labour shortages.

Interoperability

ESRS S1 (Own Workforce) and ESRS S2 (Workers in Value Chain) cover labour topics relevant to Meat, Poultry & Dairy SASB Standard high-labour-intensity processing operations underscoring the gap in the absence of a Labour Conditions topic.

Suggested response letter comments for the TAC's consideration

Absence of Labour Conditions disclosure topic

The ISSB should consider introducing a Labour Conditions disclosure topic for own operations within Meat, Poultry & Dairy SASB Standard, aligned with the Agricultural Products SASB Standard (FB-AG-310a.1). Meat and poultry processing activities are at least as labour-intensive as agricultural production and often present heightened labour-related risks, as evidenced by UK regulatory and industry sources documenting the sector's heavy reliance on large workforces and its exposure to persistent labour shortages affecting operational capacity and food safety. The absence of a corresponding topic creates an inconsistency between the standards and limits the availability of decision-useful information for investors in UK food businesses.

We note that metric FB-MP-430c.1 under the Social Supply Chain Management topic requires disclosure of processes, controls and procedures for managing labour conditions and community impacts within the supply chain. However, this is insufficient, as it does not address labour conditions associated with own operations, such as livestock raising and meat processing.

The absence of a Labour Conditions disclosure topic is also inconsistent with the inclusion of a Workforce Health and Safety disclosure topic and related workforce metrics within the Meat Poultry & Dairy SASB Standard.

Absence of Food Loss & Food Waste disclosure topic

As noted in the Agricultural Products SASB Standard, food loss is a value-chain issue. Meat, poultry and dairy products are highly perishable. However, there is currently no dedicated Food Loss & Food Waste disclosure topic. The ISSB should consider introducing this topic to address this sustainability-related risk in this industry.

Q1 (e) - Do you agree that the proposals would improve the international applicability of the Meat, Poultry & Dairy SASB Standard and would lead to the disclosure of decision-useful information from entities in the industry regardless of their jurisdiction? Why or why not?

Q1 (f) - SASB Standard's interoperability and alignment with other sustainability-related standards or frameworks? Why or why not?

Q1 (g) - Are there any proposed metrics in the Meat, Poultry & Dairy SASB Standard that would benefit from the inclusion of specific proportionality mechanisms described in paragraphs BC47-BC48 of the Basis for Conclusions? If so, identify which metrics you believe would benefit from the introduction of such mechanisms and explain why?

Preliminary response position: Agree with proposals in the three questions.

Rationale for agreeing: As set out in the analysis table below the revised industry description is more internationally applicable.

2.5 International applicability

Nature of proposed amendment

Removal and adaption to local jurisdictions of US centric metrics like GFSI and Concentrated Animal Feeding Operations (CAFO) – Appendix item A1.17 provides explanatory information about CAFO

Findings from UK- & international-related research & interoperability findings

Removal and adaptation of US Centric metric

The removal of the Global Food Safety Initiative (GFSI) food safety audit metric replacing it with internationally applicable food safety certification standards is welcomed. GFSI has been widely regarded as US- and EU-centric in its original formulation.

Under the existing Standard, entities are required to report protein output from Concentrated Animal Feeding Operations (CAFOs) based on the US legal definition. This has now been revised to allow entities to use equivalent jurisdiction-specific definitions of concentrated or confined animal feeding operations

Suggested response letter comments for the TAC's consideration

Support the international applicability improvements based on the removal of US Centric metrics.

Appendix 1: Supplementary explanatory information on technical matters

The table below provides explanatory information on the terms used in the analysis in the paper. It is intended to give contextual clarity on how certain technical terms inform the analysis and the recommendations made.

Item No	Subject	Details
A1.1	Change in scope of Agricultural Products SASB Standard	The scope / industry description substantively amended OLD text (current): 'The Agricultural Products industry is engaged in processing, trading and distributing vegetables, fruits, seeds, tea leaves and producing and milling agricultural commodities such as coffee beans, grains, sugar, consumable oils, maize, rice and soybeans and animal feed. Entities typically purchase agricultural products from third-party growers around the world and perform value-adding activities.' NEW text (proposed): Retains above commodities list but adds that entities 'may engage in direct crop production, act as intermediaries between farmers, processors, retailers and restaurants or operate across multiple stages of the food value chain.' Explicitly broadens scope to include outgrowers, contract farmers, co-operatives.
A1.2	Outgrowers	Outgrowers are independent farmers who grow crops and sell their entire production (or a specified proportion) to a single processing company under a purchase agreement. The processing company typically provides seeds, technical guidance and sometimes financing, but the farmer owns or leases the land and manages day-to-day operations. Outgrower schemes are common in palm oil, tea, coffee, cocoa and other tropical commodity sectors, particularly in Sub-Saharan Africa, Southeast Asia and Latin America. They allow processing companies to increase the volume of raw material they can source without the capital cost of owning more land. Source: Food and Agricultural Organisation (FAO) [https://www.fao.org/4/ac131e/ac131e03.htm] Application challenge scenario: An entity operates a nucleus estate model in which it provides contracted smallholder farmers ('outgrowers') with seed, fertiliser, pesticides and technical advice and buys 100% of their output at a guaranteed price (farmers can only sell to the entity and no other party). The entity specifies what crop variety must be planted, when it must be planted, and what inputs must be used, but does not employ the farmers and does not own or lease the land they farm. Does this arrangement count as ‘direct farming operations' triggering reporting of Land Use and Labour Conditions metrics or is it a supply chain relationship covered by the Environmental and Social Supply Chain Management metrics instead? Two companies with identical
A1.3	Contract farming	outgrower arrangements could reach opposite conclusions, producing disclosures that investors cannot compare. [Outgrower models are commercially common for UK-listed plantation and for tropical commodity companies generally]. Contract farming is similar to outgrowing but the processing company typically has greater involvement in how the crop is grown specifying inputs, farming methods, and quality standards. The farmer grows crops under contract and receives a guaranteed price or profit-sharing arrangement. This structure is common in UK poultry (where processors own the birds and the farmer provides the housing and labour) as well as in grain, vegetables and dairy in developed markets. Source: FAO [https://www.fao.org/in-action/contract-farming/about/what-is-contract-farming/en]
A1.4	Cooperatives	Agricultural co-operatives are farmer-owned organisations where members pool resources to achieve economies of scale in marketing, processing, or purchasing. Co-operatives can operate in two ways that are relevant to the Agricultural Products SASB Standard: (1) as collective farming entities, where the co-op itself manages land and farming operations on behalf of members; and (2) as intermediaries, where the co-op purchases produce from its member farmers and then sells it to processors or retailers. Source: FAO - [https://www.fao.org/4/y5469e/y5469e04.htm ] Application challenge scenario: Farmer-owned co-operative with processing integration A farmer-owned co-operative processes and trades the produce of its farmer members. The co-operative does not own or lease any agricultural land. The farmer members own their farms independently, make their own cultivation decisions, and are not employees of the co-operative. However, the co-operative's rules require members to deliver all production to the co-operative, and members receive a share of the co-operative's net surplus rather than a spot-market price. Under the proposed amendments, is the co-operative itself in scope of FB-AG at all? If it is, do the farmer members' farms constitute 'direct farming operations' of the co-operative (triggering the FB-AG-160 Land Use metric series), or are the members' farms a 'supply chain' (triggering FB-AG-430c and FB-AG-430d)? And if they are supply chain, how does the co-operative satisfy FB-AG-430d.3 (percentage of high-risk suppliers independently audited) when its 'suppliers' are its own member-owners?
A1.5	Management contract operations	Application challenge scenario: A company is paid a fee to run 15 farms on behalf of their owners. The company decides what crops to plant, hires all the workers, and manages every day-to-day decision. But the landowners keep the title to the land and take the profit or loss from the harvest. Are these 15 farms counted as the company's own 'direct farming operations' triggering the Land Use and Labour Conditions metrics even though the company does not own the land and takes no financial risk on the harvest?
A1.6	Geographic Information System (GIS) based spatial data	A UK Palm Oil company operating in South East Asia and the Pacific reports using GIS for spatial footprint reporting. Geographic Information System (GIS) is a technology platform that captures, stores, analyses, and visualises geographically referenced data – in other words, data that is linked to specific locations on the earth's surface using coordinates (latitude and longitude). In the context of the Land Use & Ecological Impacts disclosure topic in the revised Agricultural Products SASB Standard (FB-AG-160 series), GIS-based spatial data means information about where a company's farming operations are physically located, how large they are (total area) and what types of ecosystems, protected areas, or ecologically sensitive locations are near those operations. A company with farming operations in multiple countries can use GIS to map all of its land parcels (owned, leased, or under outgrower contract) onto satellite imagery. The GIS system aggregates all mapped parcels to calculate the total area of land associated with the company's operations - this is the 'spatial footprint'. The system can also identify which of those land parcels overlap with or are close to protected nature areas, forests, or biodiversity hotspots (relevant to FB-AG-160a.2). GIS data is important for the SASB Standard because: (i) it provides a verifiable, remotely-sensible data source that is harder to manipulate than self-reported land area estimates; (ii) it enables detection of deforestation or land conversion events using satellite change-detection algorithms (relevant to FB-AG-160a.4); and (iii) it enables investors to assess whether a company's operations are in locations with high nature-related financial risk. A key challenge for many smaller or emerging-market agricultural entities is that they do not yet have centralised GIS systems that map all their outgrower and contract farming relationships. Sources: ESRI (2024), What is GIS?, [https://www.esri.com/en-us/what-is-gis/overview]; TNFD (2023), LEAP Guidance v1.0 (Locate step), https://tnfd.global]
A1.7	Roundtable on Sustainable Palm Oil (RSPO)	All 2 UK listed companies with palm oil operations in Asia and the Pacific reports on RSPO certifications in their ESG and annual reports. The Roundtable on Sustainable Palm Oil (RSPO) is a not-for-profit membership organisation that sets standards for sustainable palm oil production and sourcing. It brings together palm oil growers, processors, traders, consumer goods manufacturers, retailers, banks, and NGOs. RSPO's sustainability criteria for palm oil production include: no clearance of primary forests, high conservation value (HCV) areas, or high carbon stock (HCS) forests; no development on peatlands; protection of water courses; respect for workers' rights and local community rights (including free, prior and informed consent for indigenous peoples); and transparent traceability through the supply chain.
A1.8	Rainforest Alliance	Source: RSPO (2018), RSPO Principles and Criteria for the Production of Sustainable Palm Oil, [https://rspo.org/certification/principles-criteria;] In the context of the Agricultural Products SASB Standard, RSPO certification provides one accepted method by which an entity can demonstrate that its palm oil operations or sourcing satisfy the 'sustainably managed land' criterion required by metric FB-AG-160a.3, and that its sourced palm oil is 'deforestation-free' as required by FB-AG-430c.1. One UK listed company with forestry (rubber plantations), tea and fruit estates reports some of its plantations as Rain Forest Alliance certified. The Rainforest Alliance is an international non-governmental organisation that certifies farms, forests, and tourism businesses to sustainability standards that cover environmental, social, and economic criteria. For agricultural products, the Rainforest Alliance certification standard (aligned with the Sustainable Agriculture Network) assesses: ecosystem protection; wildlife conservation; water conservation; good agricultural practices; workers' rights and safety; and community relations. Source: [https://www.rainforest-alliance.org/business/certification/farm/.]
A1.9	Global Forest Watch satellite monitoring	Global Forest Watch (GFW) is a free, publicly accessible online platform created by the World Resources Institute (WRI). It uses satellite imagery from NASA and the European Space Agency (Sentinel programme) to detect forest loss anywhere in the world at 30-metre resolution, in near-real-time – typically within a few weeks of a deforestation event occurring. In practice, anyone with GPS coordinates for a specific farm or land parcel can cross-check those coordinates against GFW's deforestation alert layers to confirm whether tree cover has been lost at that location after a defined reference date (for the EU Deforestation Regulation, this is 31 December 2020). GFW data is independent, publicly available, and auditable – making it a credible verification tool that does not require physical field visits. Source: World Resources Institute (2023), Global Forest Watch, [https://www.globalforestwatch.org; Hansen, M.C. et al. (2013), High-Resolution Global Maps of 21st-Century Forest Cover Change, Science, 342(6160), 850-853 (the foundational scientific data underpinning GFW)].
A1.10	The EU Deforestation Regulation (EUDR, effective 30 December 2026)	The EU Deforestation Regulation (Regulation EU 2023/1115) is EU law that will apply from 30 December 2026 for large and medium operators, and 30 June 2027 for small operators. Its purpose is to stop the EU market from being supplied by commodities linked to global deforestation. The Regulation covers seven commodities - cattle, cocoa, coffee, palm oil, soya, wood, and rubber - and their derived products. To place these on the EU market, operators must prove that products are: (1) deforestation-free (no forest cleared after 31 December 2020); (2) produced in compliance with the laws of the country of production; and (3) covered by a formal due diligence statement. Crucially, the Regulation requires plot-level geolocation data — GPS coordinates identifying the specific farm or plantation plot where the commodity was grown. FPIC requirement: For indigenous communities, operators must confirm that free, prior and informed consent (FPIC) was obtained from indigenous peoples whose land rights could be affected. This integrates a social obligation into what is primarily an environmental regulation. Source: [https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en] How it relates to the Agricultural Products SASB Standard: The EUDR and the new Environmental Supply Chain Management topic (FB-AG-430c) are pursuing the same underlying investor objective enabling assessment of supply chain deforestation risk. However, the EUDR requires a higher standard of verification (plot-level geolocation and legality compliance) than FB-AG-430c.1 (which requires only a percentage figure for deforestation-free sourcing). The Social Supply Chain Management topic (FB-AG-430d.1, covering HRDD) partially aligns with the EUDR's FPIC and legality requirements but the SASB Standard treats these as separate from deforestation-free sourcing, whereas the EUDR integrates them.
A1.11	UN Guiding Principles on Business and Human Rights (UNGPS)	The UN Guiding Principles on Business and Human Rights (UNGPs), endorsed unanimously by the UN Human Rights Council in 2011, are the global authoritative framework for corporate responsibility for human rights. They establish that: states have a duty to protect against human rights abuses; companies have a responsibility to respect human rights; and both should provide access to remedy for victims. Human Rights Due Diligence (HRDD) — the operational mechanism the UNGPs require — is a four-step process: (1) identify and assess actual and potential adverse human rights impacts in operations and supply chains; (2) integrate findings and take action to prevent or mitigate harms; (3) track the effectiveness of actions; and (4) communicate how impacts are being addressed. Source: [https://www.ohchr.org/en/publications/reference-publications/guiding-principles-business-and-human-rights;]
A1.12	OECD Due Diligence Guidance for responsible supply chains	The OECD Due Diligence Guidance for Responsible Business Conduct (2018) translates the UNGPs into practical, sector-specific steps. It provides operational definitions of 'high-risk' supply chain contexts including conflict areas, weak governance, and documented human rights risks and sector-specific guidance for agricultural supply chains including palm oil, soy, and cocoa. [https://www.oecd.org/investment/due-diligence-guidance-for-responsible-business-conduct.htm.] The OECD Due Diligence Guidance for Responsible Business Conduct (2018) provides practical, sector-specific guidance on how to carry out HRDD consistent with the UNGPs and OECD Guidelines for Multinational Enterprises. Sector-specific guidance is available for agricultural supply chains, including palm oil, soy, and other commodities. The OECD Guidance defines 'high-risk' supply chain contexts including areas of conflict, weak governance, and documented human rights risks. Relevance to the Agricultural Products SASB Standard: The Social Supply Chain Management disclosure topic (FB-AG-430d.1-430d.3) is structured around HRDD concepts drawn from the UNGPs and OECD Guidance.
A1.13	Acceptable traceability certification standards by commodity. For example: palm oil (RSPO); soy (RTRS/ProTerra); cocoa (Rainforest Alliance/UTZ); coffee (Fairtrade/4C).	Commodity traceability certification standards are independent, third-party-verified schemes that confirm a product has been sourced or produced in a way that meets defined social, environmental, and/or governance criteria, and that the product can be traced through the supply chain back to the verified source. Each major agricultural commodity has its own set of leading certification standards Palm oil - Roundtable on Sustainable Palm Oil (RSPO): Certifies that palm oil is produced without deforestation, peatland development, or exploitation of workers and communities. RSPO certification covers traceability through a supply chain to individual certified palm oil mills and plantations. Soy - Round Table on Responsible Soy (RTRS) and ProTerra: These schemes certify that soy has been produced without conversion of native vegetation, with respect for workers' rights and local communities. Relevant for UK food manufacturers and retailers sourcing soy for animal feed in their supply chains. Cocoa - Rainforest Alliance and UTZ (merged into Rainforest Alliance in 2018): Certifies cocoa farms against environmental (deforestation-free, biodiversity protection), social (worker rights, child labour prevention), and economic criteria. Coffee - Fairtrade International and 4C (Common Code for the Coffee Community): Fairtrade certifies that coffee farmers receive a minimum price and a development premium; 4C provides a baseline sustainability code for mainstream coffee supply chains Why this matters for FB-AG-430d.2: The metric requires disclosure of the percentage of sourced agricultural products certified to recognised traceability standards. Without a reference list of accepted standards, different companies will use different certification schemes, making comparisons across companies meaningless. Sources: RSPO, [https://rspo.org; RTRS, https://responsiblesoy.org; ProTerra Foundation, https://proterrafoundation.org; Rainforest Alliance, https://www.rainforest-alliance.org; Fairtrade International, https://www.fairtrade.net; 4C Association, https://www.4c-association.org.]
A1.14	Mass-balance certification (RSPO, RTRS) provides a practical proxy but does not guarantee farm-level deforestation-free status.	A UK FTSE 250 with pork, poultry and fish productions reports in its ESG report having transitioned to full mass balance RTRS-certified soya across its pig and poultry farming businesses Mass-balance certification is a bookkeeping-based supply chain model used primarily for palm oil (RSPO) and soy (RTRS). Under mass balance, a processor can buy a mixture of certified and non-certified material, blend them together during processing, and then label a corresponding volume of its output as 'certified' – even though the specific oil in any given final product cannot be physically traced to a certified farm. This is fundamentally different from two more rigorous certification models: Segregated certification: certified and non-certified materials are physically kept separate throughout the entire supply chain, from farm to final product. Identity-preserved certification: the certified product maintains its identity and is traceable to a single specific farm or plantation throughout the supply chain. Mass balance is widely used in practice because it is significantly cheaper and easier to administer than segregated or identity-preserved certification – but it provides a weaker sustainability assurance. Source: RSPO (2023), RSPO Supply Chain Certification Standard, [https://rspo.org/certification/supply-chains; WWF (2022), Understanding Sustainable Palm Oil Certification, https://www.worldwildlife.org/industries/palm-oil.]
A1.15	The EU framework (Council Regulation (EC) 1/2005 on animal transport)	Council Regulation (EC) 1/2005 on the protection of animals during transport is the core EU law governing the conditions under which live animals may be transported within, into, or out of the European Union. It sets minimum standards for: journey duration limits (without rest, water, and feed stops); maximum transport times before animals must be offloaded and rested; space allowances per animal type during transport; temperature and ventilation requirements in transport vehicles; and competency requirements for drivers, keepers, and transporters. Source: Council Regulation (EC) No 1/2005 of 22 December 2004 on the protection of animals during transport, OJ L 3, 5.1.2005, [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32005R0001]
A1.16	The Welfare of Animals (Transport) (England) Order 2006)	The UK equivalent, The Welfare of Animals (Transport) (England) Order 2006 (with parallel regulations in Scotland, Wales, and Northern Ireland), implements broadly the same standards for transport within and from the UK following Brexit, with the UK retaining EU-derived animal welfare standards in domestic law. Relevance to the Meat, Poultry & Dairy SASB Standard: The revised FB-MP Standard now includes live animal transportation as a recognised business activity within the industry scope. For UK meat processors and pork and poultry companies that export live animals (for example, to EU member states or to third countries), compliance with these transport regulations is a direct regulatory compliance obligation. Non-compliance can result in fines, suspension of export licences, and reputational damage. Source: The Welfare of Animals (Transport) (England) Order 2006, SI 2006/3260, [https://www.legislation.gov.uk/uksi/2006/3260/contents/made]
A1.17	Concentrated Animal Feeding Operations (CAFO)	A Concentrated Animal Feeding Operation (CAFO) is a US regulatory term defined by the US Environmental Protection Agency (EPA) under the National Pollutant Discharge Elimination System (NPDES) permit programme. A CAFO is a livestock or poultry operation where animals are confined for more than 45 days per year in an area where crops, vegetation, forage growth, or post-harvest residues are not sustained during the normal growing season. CAFOs are classified as Large, Medium, or Small based on the number of animals: for example, a Large CAFO includes operations with 1,000 or more beef cattle, 700 or more dairy cattle, 2,500 or more pigs over 55 lbs, or 100,000 or more chickens (other than laying hens). In practice, CAFOs represent intensive, indoor, industrial-scale livestock production. The term captures the factory-farming model common in US agricultural production. Source: US EPA (2023), Concentrated Animal Feeding Operations (CAFOS) Overview, [https://www.epa.gov/npdes/concentrated-animal-feeding-operations-cafos; DEFRA (2016)]
A1.18	Environmental Permitting (England and Wales) Regulations 2016,	UK analogous frameworks to CAFO include the Environmental Permitting Regulations 2016 (intensive farming installations above certain thresholds require an environmental permit) and the Nitrate Vulnerable Zone regulations (requiring nutrient management plans in sensitive water catchments). However, neither of these directly maps to the CAFO definition. Source: [https://www.legislation.gov.uk/uksi/2016/1154/contents/made]
A1.19	The UK 'Farming Rules for Water' (2018)	A nutrient management plan (NMP) is a written farm-level document that balances how much nitrogen (N) and phosphorus (P) is applied to land – from livestock manure, slurry, and fertilisers – against what crops actually need. The objective is to prevent excess nutrient runoff into rivers and groundwater, which causes eutrophication (algal blooms, oxygen depletion, fish kills). The Farming Rules for Water (Reduction and Prevention of Agricultural Diffuse Pollution (England) Regulations 2018, SI 2018/151) make nutrient management planning a legal obligation for most farmers in England above 10 hectares of agricultural land. The Regulations prohibit spreading organic manure where there is a significant risk of runoff, and require farmers to: hold a nutrient management plan; record all nutrient applications; and demonstrate that applications do not exceed crop needs. Equivalent (though not identical) frameworks apply in Wales, Scotland, and Northern Ireland, and in EU Nitrate Vulnerable Zones under the EU Nitrates Directive.
A1.20	Royal Society for the Prevention of Cruelty to Animals (RSPCA)	Source: The Reduction and Prevention of Agricultural Diffuse Pollution (England) Regulations 2018, SI 2018/151, [https://www.legislation.gov.uk/uksi/2018/151/contents/made; DEFRA (2018), Farming Rules for Water - Guidance for Farmers, https://www.gov.uk/guidance/farming-rules-for-water-in-england.] RSPCA Assured is a UK-based farm assurance and food-labelling scheme operated by the Royal Society for the Prevention of Cruelty to Animals (RSPCA). It certifies livestock farming and food production systems against animal-welfare standards that exceed minimum UK legal requirements. For agricultural production, RSPCA Assured evaluates animal welfare and health outcomes, husbandry and stocking practices, and farm management systems supporting compliance and traceability. [Source: RSPCA Assured: a better choice for farmed animals]
A1.21	Red Tractor Assurance	Red Tractor is a UK-wide, industry-led farm assurance scheme covering food production from farm to fork. It certifies agricultural and livestock operations against standards for food safety, traceability, animal welfare aligned with UK legal requirements, environmental protection and basic worker health and safety, and is commonly used to demonstrate baseline compliance and supply-chain assurance in UK food systems. Source: [https://redtractor.org.uk/assurance/]

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TAC Public Meeting May 2026 Paper 3: SASB Standards preliminary analysis of Agricultural Products and Meat, Poultry & Dairy SASB Standards

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