British American Tobacco

BAT wishes to submit views on two aspects of the draft ESRS. First, the requirement in ESRS 1, paragraph 76 for sustainability reporting, including metric calculation, to align with the financial reporting period. In practice, a strict alignment requirement is likely to necessitate the use of proxies and estimations to bridge timing gaps, particularly for companies that publish early in the year (e.g. mid-February).

We support the European Commissions efforts to reduce the environmental impact of certain plastic products, and welcome the Commissions commitment to collect and review evidence to determine whether measures that have so far been implemented by Member States under the SUPD indicate that, once fully implemented, the SUPD will likely achieve its objectives.

We respectfully submit the following observations on behalf of British American Tobacco, a manufacturer and distributor of tobacco and non-tobacco products within the European Union, in response to the ongoing public consultation concerning the implementation and interpretation of the EU Deforestation Regulation (Regulation (EU) 2023/1115) ("EUDR"). 1.

BAT welcomes the opportunity to contribute to the call for evidence request and would like to present several near-term solutions that follow the guiding principles of a collaborative mindset across jurisdictions and organisational siloes, common standards, interoperability between systems, a data-driven culture, and flexibility to learn and adapt.