Materials Sourcing & Efficiency
Public Comment Analysis
Open for general feedback
The standard-setting project seeks to revise and clarify metrics CG-AA-440a.1 and CG-AA-440a.2 and the associated technical protocols to examine and improve measurability, completeness, comparability, alignment, and cost-effectiveness.
Market input and internal review suggest that the two metrics associated with the Raw Materials Sourcing disclosure topic provide insufficient guidance that may result in inconsistent calculations and noncomparable disclosures. In addition, market input suggests that improvements to the completeness in which the metrics measure performance on the topic, along with further alignment with existing industry approaches should be considered.
- Phase 1 - Initial Research
- Phase 2 - Stakeholder Consultation
- Phase 3 - Post-Consultation Analysis
- Phase 4 - Exposure Draft Development
- Phase 5 - Public Comment Period
- Phase 6 - Public Comment Analysis
- Phase 7 - Completed
The public comment period for the Raw Materials Sourcing in Apparel Project concluded on Thursday, September 2, 2021. All received comment letters are published in the Published Documents & Supplemental Materials section below. The SASB Standards Board is currently reviewing and considering all received comment letters.
The Standards Board may vote to proceed with the proposed changes, re-evaluate the proposed changes, or consider additional alternatives based on review and deliberation of the received comment letters. Subscribe to Project Updates to receive the latest information on this project.
Published Documents & Supplemental Materials
- Briefing Document, April 2020, PDF
- SASB to Improve Apparel, Accessories & Footwear Industry Guidance on Materials Sourcing Measurement, March 2020, online blog
- Public Comment Period Launch Webinar: Raw Materials Sourcing in Apparel, May 2021, Recording
Public Comment Letters
Comment letters are received as part of the public comment period between June 3, 2021 and September 2, 2021. Comment letters are posted in the order of receipt. Please note that it can take up to two weeks for comment letters to be posted.
- Columbia Threadneedle, 06-04-2021
- EMAlpha LLC, 07-15-2021
- Nimet Vural, 07-16-2021
- Ethical Capital Opportunity Advisors, 07-22-2021
- Sustainable Forestry Initiative, 08-12-2021
- Rockefeller Capital Management, 08-22-2021
- GUESS, 09-01-2021
- ISS ESG, 09-02-2021
- Textile Exchange, 09-02-2021
- Kering, 09-02-2021
- Rights CoLab, 09-02-2021
- TÜV Rheinland, 09-02-2021
- UL, 09-02-2021
Board Materials & Decisions
Board Meeting Outcomes
- Staff provided an overview of the market input received during the public comment period (June 2 – Sept 3, 2021) and discussed the two following issues with the Board to gain their perspective on possible next steps:
- To enhance guidance related to sourcing region/country
- To enhance guidance on company identification/selection of credible third-party environmental and/or social certifications/standards
- Next steps in the project will consist of additional research and consultation to understand and guide further revisions on the exposure draft as appropriate.
- Staff presented findings from the consultation phase, proposed next steps, and made recommendations related to maintaining the project’s scope.
- The Board provided feedback on staff’s analysis of consultation findings and proposed next steps. The Board also agreed with staff’s recommendation to maintain project scope and pursue revisions that have a clear path forward, as opposed to broadening the project scope in an attempt to address consultation feedback on related, but separate issues.
- Next steps in the project will consist of the development of an exposure draft for public comment.
- The Board unanimously agreed to add a project on measuring performance on raw materials sourcing in the Apparel, Accessories & Footwear industry to its standard-setting agenda.
For a full list of past and upcoming Standards Board meetings, as well as associated materials, please visit our Board Meetings Calendar & Archive.
The staff has prepared this summary for informational purposes only. Any Standards Board decisions are tentative and do not change current accounting. Official positions of SASB are determined only after extensive due process and deliberations.