Internal training brief · Global Sustainability Supply Chain & Product · CDP scope decision

Carbon. Water. And the question nobody asked.

A working framework for deciding which CDP themes our supply chain actually needs to disclose — and an honest argument for why “we did carbon and water last year” is not a reason to do only carbon and water again.

AudienceCategory buyers, product stewards, supplier engagement leads
Runs inOne 90-minute session, plus a scoring worksheet
Decision it producesDisclose / Build / Monitor — per theme, on record
THEME 01

Carbon

Disclosed — two cycles

Mature. The risk here is complacency, not absence — a carbon answer that excludes land-use change is an incomplete carbon answer.

THEME 02

Water

Disclosed — two cycles

Material because our sites and our tier-1 suppliers sit in stressed basins. That finding was made once — it should be re-made each cycle.

THEME 03

Forests

Open question

Never tested against the criteria. Not a decision — an omission that has quietly become a habit.

Part one · The evaluation

Five tests. Run them on every theme, every year.

Score each test 0–3 for each theme (carbon, water, forests, plastics, biodiversity). Do it in the room, with procurement data on screen, and write the scores down. A documented “no” is a defensible position. An undocumented “no” is exposure.

TEST 01

Commodity & material exposure

Do we buy, at any tier, a material that sits inside the theme’s definition? For forests, run the bill of materials against CDP’s seven forest-risk commodities — including the hidden routes: pulp cartons, natural rubber, soy in animal feed, palm derivatives in surfactants and emulsifiers, leather.

Ask procurement: “Show me spend by material, not by supplier.”
Score 3 if a listed commodity appears in a top-20 spend line.

TEST 02

Place — basin and landscape

Impact is local. Map top-spend sites against water stress (WRI Aqueduct) and sourcing origins against deforestation frontiers. A theme is material where our volume meets a stressed place, not where our headquarters happens to be.

Ask sourcing: “Which country of origin, which basin, which volume?”
Score 3 if >20% of volume comes from a high-stress or high-risk landscape.

TEST 03

Regulatory pull

Disclosure now trails legislation. EUDR (Reg. (EU) 2023/1115) demands geolocated, legality-verified origin for seven commodities placed on the EU market. CSRD/ESRS asks for E1 climate, E3 water and E4 biodiversity. IFRS S2 sets the climate baseline. California SB 253 / SB 261 add a US thread.

Ask legal: “What are we already required to collect?”
Score 3 if a binding requirement lands within 24 months — this test alone can force disclosure.

TEST 04

Customer and capital demand

In CDP Supply Chain we are the responder. Pull the actual requests: which customers invited us, on which themes, and how heavily is each theme weighted in their supplier scorecard? Then check the investor request separately — the two channels do not always ask the same thing.

Ask account management: “Which of our top ten customers scores forests?”
Score 3 if a strategic customer weights the theme in commercial evaluation.

TEST 05

Footprint materiality — where the tonnes and the litres actually sit

Finally, the quantitative check. If land-related emissions (land-use change plus land management) are a meaningful share of our inventory, forests is not a separate topic — it is the missing half of our carbon number. SBTi’s FLAG guidance requires a separate land-sector target where land-intensive activities exceed 20% of total emissions, and the GHG Protocol Land Sector and Removals Guidance defines how those tonnes are counted. The same logic applies to water intensity per unit of product.

Ask the inventory owner: “What percentage of Scope 3 category 1 comes from agricultural or forest-derived inputs?”
Score 3 if the theme drives >15% of the relevant footprint.

TOTAL 11–15, OR ANY 3 ON TEST 03

Disclose

Submit this cycle. Accept a low first-year score — CDP rewards disclosure and improvement, and a first response establishes the baseline everything later is measured against.

TOTAL 6–10

Build

Complete the questionnaire internally without submitting. You will find the data gaps in a quiet year rather than a deadline year, and the traceability work starts twelve months earlier.

TOTAL 0–5

Monitor

Not material this cycle. Record the scores, name the trigger that would change them, and re-test next year. This is the only defensible form of “no”.

Part two · The challenge
“We did carbon and water, so we’ll do carbon and water.” That is a budget decision wearing a materiality decision’s clothes.

Last year’s scope is a habit. Materiality is a finding — and findings expire.

They say

“Forests isn’t our topic — we’re not a food company.”

Forest-risk commodities almost never arrive labelled. They arrive as corrugated packaging and paper, as leather trim, as natural rubber in tyres and seals, as soy inside animal feed, as palm derivatives inside surfactants, lubricants and cosmetics. Run the bill of materials before answering.

They say

“The data is too hard — we can’t trace to origin.”

CDP scores the quality of disclosure and the maturity of the process, not perfection. A first-year response that states known volumes, admits the traceability gap and publishes a roadmap scores; silence scores nothing and tells a customer we have not looked.

They say

“No customer has asked us for forests.”

The regulator has. EUDR requires geolocation of plots of production for its listed commodities — and customers typically ask their suppliers only six to nine months before their own deadline, while origin-level data collection takes nine to twelve. Waiting for the ask guarantees we are late.

They say

“Adding a theme will drag our score down.”

CDP scores are issued per theme. A first forests score does not dilute a climate A-. What does damage the climate score, over time, is a Scope 3 inventory that leaves land-use change out and cannot survive assurance.

They say

“It’s a whole extra questionnaire and team.”

Less true than it was. Since the 2024 cycle CDP runs a single integrated questionnaire, with themes appearing as modules rather than separate submissions. The marginal cost of adding forests to an existing response is far lower than the cost of standing one up cold.

They say

“Let’s revisit it next year.”

Then put that in writing: the five test scores, the trigger that reopens it, and the named owner. If forests scores into Disclose and we still defer, we have made a real decision with a real record — which is the whole point of the exercise.

Part three · Where the ground moved

A short history of why the answer changed.

Share this timeline before the scoring exercise. It explains why a scope set in 2022 cannot simply be re-used: nearly every reference point behind it has been rewritten.

SBTi publishes the FLAG guidance

The first standard method for setting forest, land and agriculture science-based targets — and the threshold above which a company must set one separately from its energy-and-industry target. Land emissions stop being optional footnote material.

The EU Deforestation Regulation enters into force

Regulation (EU) 2023/1115 replaces the old timber regulation and covers cattle, cocoa, coffee, oil palm, rubber, soya and wood plus derived products — requiring geolocation of the plots of land where commodities were produced. Traceability becomes a market-access condition, not a reporting nicety.

TNFD releases its recommendations

Nature-related dependencies, impacts, risks and opportunities get a disclosure architecture that mirrors climate’s. Water and forests move from separate “topics” toward one nature narrative.

IFRS S1 and S2 become effective

Effective for annual reporting periods beginning on or after 1 January 2024, with jurisdictions adopting on their own timetables. CDP realigned its climate questions to this wording — one reason the questionnaire looked different that year.

CDP consolidates into one integrated questionnaire

Plastics questions arrive in 2023; from the 2024 cycle climate, water security, forests, plastics and biodiversity sit inside a single corporate questionnaire structured around IFRS S2 and mapped to ESRS. The practical consequence for us: adding a theme is now a module decision, not a programme decision.

EUDR application is postponed by twelve months

Regulation (EU) 2024/3234 pushes the application date for large and medium operators to 30 December 2025, with micro and small enterprises following later. Further simplification has been debated since — confirm the current date at EUR-Lex before quoting it to a supplier.

Forests disclosure still trails climate by an order of magnitude

Tens of thousands of companies disclose on climate through CDP each year; the forests responder population remains a small fraction of that, even among companies with obvious commodity exposure. Which is precisely why an early, honest forests response differentiates a supplier instead of merely keeping pace.

Trainer’s note — verify before you publish. Response counts, member numbers and procurement-spend figures change every cycle, and the EUDR timetable has moved more than once. Take every number in this deck back to the primary source in the reference list and date-stamp it in the slide footer. A brief that cites a stale figure loses the room faster than one that cites none.

Part four · “Or anything else?”

Three more modules the same five tests will judge.

The question was never carbon versus water versus forests. It is: which of CDP’s modules does our supply chain trip the threshold on? Run the identical scoring worksheet across these.

Since 2023

Plastics

Durable and single-use polymer in product and packaging, by weight and by fate. Score this high if packaging is a top-five material line or if we sell into an EPR regime.

Since 2024

Biodiversity

Commitments, dependencies and impact assessment at site and sourcing level. The natural bridge between a water answer and a forests answer — and the on-ramp to TNFD and SBTN.

Cross-cutting

Supplier engagement quality

Not a theme but a scored dimension: how many suppliers we ask, what we ask, what we do with the answer. Improves every theme’s score at once — the highest-leverage work in the programme.

Part five · Sources

Every claim above, traceable.

Primary sources only. Open each one when you build the internal deck, confirm the live publication or amendment date, and cite it on the slide — the same evidence standard we ask of our suppliers.

  1. CDP — Supply Chain programme
    CDP · programme overview, member requests and responder guidance
    cdp.net/en/supply-chain
  2. CDP — Forests
    CDP · the seven forest-risk commodities and the forests module
    cdp.net/en/forests
  3. CDP — Water security
    CDP · water module scope and rationale
    cdp.net/en/water
  4. CDP — Guidance, questionnaires and scoring methodology
    CDP · current-cycle questionnaire, integrated structure and scoring criteria
    cdp.net/en/guidance
  5. CDP — Scores
    CDP · how scores are banded per theme
    cdp.net/en/scores
  6. Regulation (EU) 2023/1115 — deforestation-free products (EUDR)
    Official Journal of the European Union · in force 29 June 2023
    eur-lex.europa.eu/eli/reg/2023/1115/oj
  7. Regulation (EU) 2024/3234 — amending the EUDR application dates
    Official Journal of the European Union · December 2024 postponement
    eur-lex.europa.eu/eli/reg/2024/3234/oj
  8. Directive (EU) 2022/2464 — Corporate Sustainability Reporting Directive
    Official Journal of the European Union · adopted December 2022
    eur-lex.europa.eu/eli/dir/2022/2464/oj
  9. European Sustainability Reporting Standards (ESRS E1–E5)
    EFRAG · standards, implementation guidance and datapoint lists
    efrag.org
  10. IFRS S2 — Climate-related Disclosures
    IFRS Foundation / ISSB · effective for periods beginning on or after 1 Jan 2024
    ifrs.org · IFRS S2
  11. GHG Protocol — Land Sector and Removals Guidance
    GHG Protocol · accounting for land use change, land management and removals
    ghgprotocol.org/land-sector-and-removals-guidance
  12. SBTi — Forest, Land and Agriculture (FLAG) guidance
    Science Based Targets initiative · published September 2022
    sciencebasedtargets.org · FLAG
  13. Science Based Targets Network — corporate nature targets
    SBTN · freshwater and land target-setting methods
    sciencebasedtargetsnetwork.org
  14. TNFD — Recommendations of the Taskforce on Nature-related Financial Disclosures
    TNFD · published September 2023, plus sector guidance
    tnfd.global
  15. Accountability Framework initiative
    AFi · common definitions for deforestation-free and conversion-free supply chains
    accountability-framework.org
  16. WRI Aqueduct — water risk atlas
    World Resources Institute · basin-level baseline water stress mapping
    wri.org/aqueduct
  17. Forest 500
    Global Canopy · annual assessment of the most exposed companies and financiers
    forest500.org
  18. Global Forest Resources Assessment
    FAO · global forest area and change statistics
    fao.org/forest-resources-assessment
  19. GRI Standards, including GRI 101: Biodiversity 2024
    Global Reporting Initiative · biodiversity standard effective 1 January 2026
    globalreporting.org