Tag Archive for: double materiality

BFBI is delighted to host a guest article by Adam Condon, a student of The Business of Nature Positive module at Trinity College Dublin – an exploration of more sustainable options to address the nature-related impacts of waste generation from energy products after marathon events.

A Nature-Positive Roadmap for Sports Nutrition:

Finish Line Fallacy

Three weeks after last October’s Dublin Marathon, I was walking my dog along the road when he nosed something silver out of the hedgerow. A crumpled energy gel wrapper, still sticky with maltodextrin, I grabbed out of his mouth. We hadn’t walked fifty metres before he found another. Then another. The race was long over. The waste was not.

The maths here is grim but worth doing. Around 25,000 runners line up each year, and most marathon fuelling plans call for roughly ten gels across the 42 kilometres. That is potentially up to 250,000 single-use wrappers dropped in a single morning across Dublin’s roads, parks, and canals. And that only counts race day. Factor in the training block, months of weekend long runs through the Phoenix Park, along the city centre, out past UCD, and the real number climbs far higher. Silver sticky wrappers sit in hedgerows, parks, and gardens, from July to October, waiting for the dogs, foxes, and wildlife that smell food and pull them loose.

These wrappers cannot be recycled. They are multi-material laminates, meaning, plastic film fused to aluminium foil, and no recycling site in the country will take them (Ellen MacArthur Foundation, 2016). Because they can’t be recycled, over time they fragment into microplastics that leach into soil and waterways, entering food chains and degrading the Dublin biodiversity we are trying to restore (UNEP, 2021). For a sport built on being outdoors, that is a genuinely sticky irony.

A Product That Depletes Nature Twice

The litter we can see is only half the problem. This product depletes nature twice: once when it is made, and again when it is tossed. Working through the sports nutrition value chain, I was shocked by how deep the upstream damage runs. The fuel inside most gels, maltodextrin, comes from intensive corn or wheat monocultures. These systems strip soil and organic matter, lean on synthetic nitrogen fertiliser, and generate nutrient runoff that leads to algal blooms and aquatic dead zones far from the farm (Tilman et al., 2002). The wrapper is worse. Its aluminium foil lining starts life as bauxite ore, extracted through open-pit mining that tears through tropical forests and leaves behind toxic red mud lagoons in place of thriving ecosystems (Power, Gräfe and Klauber, 2011).

Through a double materiality lens, gel brands carry nature-related risk at both ends of their value chain. Upstream, they depend on degraded ecosystems for raw materials. Downstream, the product waste directly harms local biodiversity. Under the EU’s Corporate Sustainability Reporting Directive (CSRD), companies are increasingly expected to disclose exactly these kinds of impacts and dependencies (EFRAG, 2024). Sports nutrition brands that ignore this two-way exposure are on borrowed time.

The “Design to Fail” Business Model

The current model is to sell-and-forget. Brands take high margins on the fuel and knowingly push the cost of the wrapper onto local councils and nature itself. The packaging design, at best, assumes that an exhausted runner, sticky-handed, oxygen-deprived, and kilometres from the nearest bin, will somehow hold onto multiple torn empty wrappers until they find one. That is not a realistic assumption. It is a product designed to fail.

The EU’s incoming Packaging and Packaging Waste Regulation (PPWR) turns this into a direct financial liability (European Commission, 2022). The PPWR introduces recyclability requirements, minimum recycled content thresholds, and Extended Producer Responsibility (EPR) obligations rooted in the Polluter Pays principle. Brands still selling non-recyclable laminate packaging will face rising EPR levies, potential market restrictions, and inevitable reputational damage across the single market. The only question left is whether companies treat incoming regulation as a grudging cost or as impetus to improve their entire product.

“If You Sell the Fuel, Own the Wrapper”

A Nature Positive Roadmap

Nature Positive is not a slogan. The Nature Positive Initiative (2024) defines it as an ambitious goal referring to measurable outcomes that contribute to halting and reversing nature loss. In terms of sports nutrition, that means moving up the Mitigation Hierarchy. Instead of limiting damage at the end, we avoid the impact entirely through redesign, then actively restore the ecosystems the product touches along the way. The principle I propose is simple: if you sell the fuel, own the wrapper.

On the packaging side, viable alternatives already exist through emerging nature-based enterprises (NBEs). Notpla, a London-based startup, produces seaweed-based packaging that dissolves harmlessly in soil and water, captures and stores carbon in its structure during growth, and requires no arable land or freshwater to produce (Notpla, 2024). By addressing both climate change and biodiversity loss simultaneously, it offers a scalable solution to the polycrisis we face. They have already trialled it at the London Marathon. Picture a gel wrapper that, if dropped by a wrecked runner at mile twenty, breaks down into organic matter within weeks. The downstream biodiversity threat disappears.

On the ingredient side, brands can shift their maltodextrin sourcing towards regenerative agriculture systems that rebuild soil health, increase water retention, and restore microbial diversity (Rodale Institute, 2020). This turns the upstream crisis on its head: a nature-depleting input becomes a nature-restoring one. Major food companies are already investing in regenerative sourcing programmes. The sports nutrition sector has no excuse not to follow.

Runners care about the outdoors. They rely on the cultural ecosystem services, the recreation, amenity, and well-being values, provided by places like the Phoenix Park and the Grand Canal. A brand that delivers  the first genuinely Nature Positive gel, compostable wrapper, regeneratively sourced fuel, does not just avoid a compliance headache. It earns lasting loyalty from a community that can spot greenwashing a mile off. Research consistently shows endurance athletes are willing to pay a premium for sustainably packaged products (Trivium Packaging, 2023). An extra fifty cents per gel to protect the route you love running is not a hard sell.

Fuel the Runner, Not the Route

The sports nutrition industry has a choice ahead of it. One path leads to rising EPR fees, regulatory scrambling, and more silver gel wrappers piling up in Ireland’s hedgerows. The other leads to material innovation, restored supply chains, and brand storytelling that stands out more than any ad campaign.

Event organisers can help force this change. The Dublin Marathon and other mass-participation races should mandate compostable packaging for all sponsored nutrition products by 2028. If your brand wants endorsement, its wrapper should not end up in the Grand Canal.

The finish line is not the end of a product’s lifecycle. It is where accountability starts. If you fuel the runner sustainably, runners will buy the fuel.

References:
EFRAG (2024) EFRAG IG 1: Materiality Assessment Implementation Guidance. Brussels: European Financial Reporting Advisory Group.
Ellen MacArthur Foundation (2016) The New Plastics Economy: Rethinking the Future of Plastics. World Economic Forum.
European Commission (2022) Proposal for a Regulation on Packaging and Packaging Waste, COM(2022) 677 final. Brussels.
Nature Positive Initiative (2024) What does Nature Positive mean? Available at: https://www.naturepositive.org/ (Accessed: March 2026).
Notpla (2024) ‘Our Technology.’ Available at: https://www.notpla.com/technology (Accessed: March 2026).
Power, G., Gräfe, M. and Klauber, C. (2011) ‘Bauxite residue issues: I. Current management, disposal and storage practices.’
Hydrometallurgy, 108(1–2), pp. 33–45.
Rodale Institute (2020) Regenerative Organic Agriculture and Climate Change: A Down-to-Earth Solution. Kutztown, PA: Rodale Institute.
Tilman, D., Cassman, K.G., Matson, P.A., Naylor, R. and Polasky, S. (2002) ‘Agricultural sustainability and intensive production practices.’ Nature, 418(6898), pp. 671–677.
Trivium Packaging (2023) 2023 Buying Green Report. Amsterdam: Trivium Packaging. Available at: https://buyinggreen.triviumpackaging.com (Accessed: March 2026).
UNEP (2021) From Pollution to Solution: A Global Assessment of Marine Litter and Plastic Pollution. Nairobi: United Nations Environment Programme

BFBI Business Programme Lead Dr Catherine Farrell CIEEM, Trinity College Dublin, writes on the process steps around undertaking a Double Materiality Assessment (DMA) to help guide your nature strategy: this article focuses on the ways to understand how businesses interface with nature, highlighting the data needs but also the language of a DMA.

Following from our inspiring and interactive workshop on March 10th (read about it here), alongside colleagues from Deloitte, the Business for Biodiversity Ireland team led the second of our Action Track workshop series on May 20th. While our initial workshop focused on the key elements of what a Double Materiality Assessment (DMA) is (and/or isn’t), especially the value chain, this time we focused on how we can map and track the interface of business with nature.

This involves homing in on ‘the where’ part of the DMA process. In essence, this means gathering your organisation’s location data like maps, and – in tandem – figuring out the other types of data available, what they measure and why. Then its time to focus on how we might use data (which may be freely available as well as company-held) to inform our DMA. Our colleagues from Deloitte shared their DMA journey, highlighting how tools like the TNFD LEAP (Locate, Evaluate, Assess and Prepare), can help bring understanding of our business interfaces with nature to light.

In this article we focus more on data and the language of data and DMA (beware of the acronyms!):

Data: we hear a lot about data these days, but when we’re trying to understand our business impacts and dependencies (how we rely on nature) we really need to focus on data relating to aspects of nature referenced in the nature-related reporting frameworks like CSRD, TNFD, SBTN and GRI.

We can start by breaking these into –

  • Locational data (a map of where we operate – note, start with one part of your value chain and get the hang of it!)
  • What types of habitats or ecosystems are present in those places (the basic type and their extent)
  • What our impact is on these specific areas of ecosystem (how we influence their condition), and
  • How we rely on them (what we need from these ecosystems as inputs, aka ecosystem services to our operations) or impact them.

This helps us Locate, Evaluate and Assess our impacts, dependencies, risks and opportunities, and then Prepare to report (think LEAP). We can do this by using available data on habitats, but -now, a health warning – in Ireland habitat data is quite limited. With some ecological input to help, however, we can gather up what is available, in a useful way.

Language: ecological and nature lingo is nuanced but not beyond our reach. It’s helpful to have someone working with us that can communicate these nuances in a clear, simple way. During our workshop we discovered that acronyms and strange ‘eco’ languages can be off putting initially, but once we get into the flow, we find what we need to know.

Many thanks to Aoife Connaughton and Deloitte for collaborating on this workshop, National Biodiversity Data Centre’s Sarah Kelly, and all our Action Track businesses for participating in our Nature Strategy Accelerator Programme, including CIE and CIE Tours, Cloud Assist, Irish Rail, Irish Trees, Future Energy Ireland, KMK, Scott Cawley Ltd, Shannon Airport, Trinity College Dublin and Watermark Coffee.

BFBI Business Programme Lead Dr Catherine Farrell CIEEM, Trinity College Dublin, writes on the process steps around a Double Materiality Assessment to help guide your nature strategy, the subject of our recent Action Track workshop.

As the birds have started to sing for us every morning again (what a joy!), it’s the right time for our businesses to spring into action. And so, inspired by the stretch in the days, on March 11th the team at Business for Biodiversity Ireland, with help from our friends at Deloitte, launched the first of our three Action Track workshops scheduled for 2025 in Dublin.

Our workshop focused on the key elements of what a Double Materiality Assessment (DMA) is (and isn’t), and why it makes perfect business sense for every organisation to conduct one. Business for Nature has outlined how we can do this through a multi-step, iterative process under the Assess phase of their ACT-D framework

Reporting frameworks and sectoral guidance: With heads spinning after the recent EU Omnibus proposal announcement, we all agreed at the workshop, that even though reporting obligation ‘goal posts and timeframes may change, it’s in everyone’s best interest to understand a) their impacts on nature, and b) nature’s impacts / on our businesses (which in turn, relate to dependencies, but also risks and opportunities). This ‘inward and outward looking’ approach is what puts the ‘double’ in DMA. Thankfully, there is a growing repository of sectoral guidance and case studies, as well as freely available online tools like ENCORE and IBAT that assist businesses to begin the journey of ‘Assess’ with relative ease. In the workshop we talked through CSRD, TNFD, SBTN and GRI, but we reminded ourselves, at the heart of all these frameworks is rolling up the sleeves to understand our business operations, our extended value chains and who we interact with along the way.

Value chains and stakeholders: In a world of global value chains – where does a value chain start and end? We spent a fruitful and insightful couple of hours working through value chains relevant to our businesses present: it was great to see the emerging pictures on flipcharts, and participate in conversations that really helped our collective understanding to grow – particularly in relation to where our greatest impacts and dependencies may lie. This is a critical part of the DMA process.

Our next two Action Track workshops will build on this work, working through tools like the TNFD LEAP (Locate, Evaluate, Assess and Prepare), to help bring our understanding to light.

A big thank you to our supporters and speakers from Deloitte, Arianna Bunello and Sofia Langs, with  support from Aoife Connaughton and Caitlyn Flanagan, BFBI Head of Operations Iseult Sheehy and Head of Research Dr Emer Ní Dhúill, Sarah Kelly, of National Biodiversity Data Centre, Eadaoin Boyle Tobin, Business in The Community Ireland.

Thanks to our Action Track businesses – Emily Riondato, Kate Farrell and Caoimhe Donnelly, of Coras Iompair Éireann; Ken Lyons, CIE Tours; Aine Kirrane, Dublin Airport Authority, Liam O’Neill (and Sean online) of Cloud Assist; Aoife McGovern, Future Energy Ireland; Ailish Duggan, Irish Rail; Bob Hamilton, Irish Trees; David Finane, KMK; Aebhín Cawley, Scott CawleyLtd; Arek Gdulinski, Shannon Airport and David Lawlor, Watermark.

Sign up for Discovery Track or level up to Action Track in the Members Home to gain access to future workshops.

Companies are taking a variety of approaches to conducting materiality assessments for their annual reporting in terms of biodiversity and other #ESG topics – but how to be sure your approach is on the right track?

As we compare and contrast assessment approaches in the course of our research, we have noticed that some reports come across as somewhat lacking in focus and substance, while stakeholder engagement appears to vary from cursory at best, brief surveys targeted at a small cohort, to in-depth discussions over a large cross-section of interested groups and individuals. Some reports seem weighted toward the concerns of shareholders rather than matters that impact society at large, while some obfuscate negative environmental and social impacts via their report’s presentation style, veering dangerously close to greenwashing.  

Fortunately, a number of methods and frameworks have emerged to facilitate Environmental, Social and Governance reporting and, in terms of standardisation, the Global Reporting Initiative (GRI) framework provides a solid, comprehensive approach for businesses reporting on their ESG performance. 

The European Union’s Corporate Sustainability Reporting Directive (CSRD) requires the use of double materiality in sustainability disclosures, which acknowledges that materiality – what matters most to a business – can no longer be viewed from a purely financial perspective. Traditionally, a material issue is one that could significantly influence the financial decisions of investors. However, this approach has expanded in recent years, as stakeholders, including regulators and consumers, have increasingly called for businesses to consider their broader societal and environmental impacts. 

A double materiality assessment takes into account two perspectives: 

  1. Financial Materiality: How ESG issues could impact a company’s financial performance. For example, stricter environmental regulations could lead to increased compliance costs, or climate-related risks could lead to asset devaluation. 
  1. Impact Materiality: The external impacts that a company’s operations, products, or services have on society and the environment. For instance, a company’s carbon emissions, deforestation, or supply chain labour practices might negatively affect local communities or contribute to global environmental challenges. 

Both aspects are interconnected and the double materiality approach offers a holistic understanding of a company’s risks and opportunities, enabling a businesses to better anticipate future trends, such as shifts in consumer preferences toward sustainable products or the financial implications of climate change, and nature degradation, as a result of business impacts. 

In particular, GRI 3: Material Topics provides guidance on how businesses can identify, assess, and prioritise material topics for reporting. The approach is quite stakeholder-focused and involves the following steps: 

Step 1: Understand the organisation’s context  

GRI 3 encourages businesses to think broadly about potential topics, not just those that have an immediate or obvious financial impact, but those that reflect significant external societal or environmental concerns. Consider: 

  • Business activities 
  • Business relationships 
  • Sustainability context 
  • Stakeholders 

Thorough and ongoing stakeholder engagement is key to identifying material topics, alongside a review of the latest industry standards, regulatory developments and examining reports by other organisations. Contact as many of your stakeholders as you can and examine their concerns – employees, customers, local communities, NGOs and regulatory bodies.  

For this exercise to be effective, you must engage at-risk or vulnerable groups and consider impacts that result in collective harm (e.g. GHG emissions), which require consultation with experts in this field. Identify the full range of ESG topics that could be relevant to the business – these go beyond climate change and biodiversity to labour and human rights, community relations and governance.  

Step 2: Identify actual and potential impacts 

Financial materiality: Evaluate how the issues raised by stakeholders might impact the company’s financial performance. Risks related to climate change, such as increased operational costs due to carbon pricing, or physical damage to assets from extreme weather events, could have material financial consequences for a business.  

Impact materiality: how do your company’s operations and activities affect society and the environment? For example, a company’s operations may generate waste or pollution, harming local ecosystems and communities. These impacts may not affect the company’s bottom line in the shortterm but are still relevant to stakeholders and fall under the company’s overall environmental and social responsibility. 

Where data is not immediately available or clear, conduct a scoping exercise to identify areas where negative impacts are likely to happen, considering impacts commonly associated with your sector. Identify also any positive impacts – those that contribute to nature restoration, conservation, protection or regeneration. 

Step 3: Assess the significance of the impacts 

The significance of the impact will be specific to each organisation and influenced by the sectors in which it operates. Consultation with experts is essential here. An actual negative impact’s significance is determined by its severity. Significance of a potential impact is determined by both the severity and likelihood of the impact, a.k.a. risk.  

Severity is determined by: 

  • Scale – how grave the impact is, including from a compliance perspective 
  • Scope – how widespread the impact is 
  • Irremediable character – how difficult it is to fix. 

For positive impacts, also look at scale and scope. How beneficial is the impact? How widespread is it or could it be?

Step 4: Prioritise Material Topics

After assessing both the financial and impact materiality, businesses must prioritise the topics that are most significant. This involves balancing the interests of shareholders (who may be primarily concerned with financial materiality) and stakeholders (who may be more concerned with societal and environmental impacts).

Step 5: Review and Disclose

The results of the double materiality assessment should be reviewed by the senior management before disclosure. Material topics should be shared in the company’s annual report. Under GRI standards, the company must explain how it conducted its materiality assessment and provide clear information on the financial and societal impacts of its operations as well as explaining why some standard topics are not considered material.

In each reporting period, review material topics from previous assessments and account for changes in the impacts, and changes due to organisational activities or business relationships. Document the approach taken for each assessment, including the methods of stakeholder engagement, evaluation, visualisation and reporting methods (and actions taken as a result). These elements should all be monitored, reviewed and updated regularly, as material issues can evolve over time. New regulations, shifting stakeholder expectations or emerging ESG risks will entail updating your materiality assessment considerations and methods in future. 

This idea is known as Dynamic Materiality​: “As companies more rapidly change their business models, what is material to such companies will be changing in stride. ​Just as the new material topics will emerge for companies as the company evolves, some sustainability issues that were previously material financially to companies will no longer be”. (​Kuh et al, 2020). 

By conducting a double materiality assessment now, on a voluntary basis, companies who do not yet fall under regulations can be ready for when regulation expands to encompass businesses of every scale and sector, and help secure a place in the supply and value chains of larger organisations who are currently mandated to report.

Transparent disclosure, as well as taking concrete action on biodiversity impacts and other ESG material topics, will enhance your business reputation with consumers and peers, while mitigating risks, boosting long-term resilience and contributing to a more sustainable future. 

The Business For Biodiversity Ireland platform offers guidance to all Irish businesses to build internal capacity to understand your material topics – sign up today.

Illustration: Figure 1(a), EFRAG IG1 Implementation Guidance on Double Materiality, May 2024. The European Sustainability Reporting Standards has published a materiality assessment document, P10 deals with double materiality, with a section on FAQs via the EFRAG site.

Visit the Global Reporting Initiative site for more information: https://www.globalreporting.org/how-to-use-the-gri-standards/gri-standards-english-language/ 

 

 

Materiality is the quality of being relevant or significant, and in terms of business and finance, materiality applies to all items that must be recorded or reported in detail in a business’s financial statements as reasonably likely to impact investors’ decision-making. 

Double materiality: For corporate sustainability reporting, the concept of double materiality applies – it goes beyond that which affects the company and its investors, extending to information on how the firm is impacting society and the environment. 

The EU Corporate Sustainability Reporting Directive (CSRD) mandates a double materiality assessment for around 50,000 reporting companies from 2024 onwards. 

The European Sustainability Reporting Standards (ESRS) explains that a double materiality assessment takes two perspectives, sometimes referred to as an ‘outside in’ / ‘inside out’ approach: 

              (1) an impact perspective “when it pertains to the [entity’s] material actual or potential, positive or negative impacts on people or the environment over the short-, medium- and long-term”; and 

              (2) a financial perspective “if it triggers or could reasonably be expected to trigger material financial effects on the [entity].” 

A double materiality assessment must cover both a business’ own operations as well as upstream and downstream value chain. It must consider the topics and subtopics covered in the 10 ESRS topical standards. These include climate change, pollution, water, biodiversity, circular economy and topics relating to governance and the workforce. 

Detailed reporting on each is required only if the company decides, following a double materiality assessment involving all stakeholders, that it is ‘material’ or relevant under the reporting rules. Where a company determines a topic to not be material, it must explain its rationale in detail. It is still necessary to have a long-term strategy in place to address your organisation’s future impacts and dependencies on nature (and future risks resulting from) biodiversity loss and climate change. 

Read more: https://www.cisl.cam.ac.uk/news/blog/double-materiality-corporate-sustainability-reporting-encompass-societal-and-environmental-impacts 

https://www.charteredaccountants.ie/Accountancy-Ireland/Articles2/Technical/Latest-News/Article-item/the-corporate-sustainability-reporting-directive-getting-to-grips-with-double-materiality