Environment

For Sealed Air Corporation, the $1 million annual savings it will realize from its recent investment in an 11-acre solar farm is just a perk that goes along with doing what’s right.

Toward a goal: “We always have sustainability in mind with everything that we do, whether it is a new product or a new facility,” said Sealed Air President of the Americas Tobias Grasso. “We always ask, ‘What is this bringing to us?’ and ‘How is this advancing our mission to leave our world better than we found it?’ Because we have a stated goal to be net-zero carbon neutral in our operations by 2040, we want to make sure that all our investments are in line with that strategy.”

• Earlier this year, a $9 million solar installation at Sealed Air’s Madera, California, manufacturing facility began generating electricity—at a rate capable of fulfilling 98% of the plant’s electricity needs, according to company calculations.
• The solar farm is integrated into the legacy power system so that system has a backup energy source when needed.

The right site: Sealed Air, the maker of the iconic Bubble Wrap® original cushioning and numerous other automation, packaging and digital printing solutions, started making plans for the 8,975-solar-panel farm in 2020. It chose the Madera location as the site for several reasons.

• “We have fairly extensive energy needs for that facility,” Grasso said. “And we had the available land and a good number of hours [of available sunlight] to provide the solar energy.”
• The manufacturer partnered locally with a team from TotalEnergies—a French company that recently acquired SunPower Commercial and Industrial Solutions—on the project.

The impact: Though the company got its solar installation up and running in less than two years, its effect on the environment will be long-lasting and far-reaching.

• The solar panels will prevent 5,000 metric tons of carbon dioxide emissions in just their first year in operation.
• Over the course of 15 years, that’s the greenhouse gas emissions equivalent of driving 15,000 cars for one year, Grasso said.

Solar-power advice: Manufacturers with the right energy needs, land and daily hours of sunlight could benefit from investment in their own solar installations, according to Grasso.

“First, you have to look at the dimensionality of your power needs; you have to look at the economics,” he said. “It’s a good idea to have a partner like TotalEnergies because they can help you through their experience so you model it the right way.”

Washington, D.C. – Following the Supreme Court’s 6–3 decision in West Virginia vs. EPA, National Association of Manufacturers President and CEO Jay Timmons released the following statement:

“Manufacturers share a deep commitment to protecting our planet and our people, and manufacturing innovation holds the key to solving the generational challenge of climate change. The court’s decision affirms the Environmental Protection Agency’s authority to issue appropriate greenhouse gas regulations while providing a reminder that the agency must stay within the guardrails delegated by Congress. As some of the largest electricity consumers and as electricity generators, manufacturers are ready to work with the EPA to deliver innovative and balanced solutions that protect our environment and our competitiveness as it considers next steps.”

Background: Earlier this week, the NAM along with 42 state partners sent President Biden a letter highlighting the importance of affordable, reliable electricity for manufacturers to remain competitive. It signals manufacturers’ eagerness to work with policymakers on the important decisions and planning surrounding the future of the electrical grid and broader energy policy.

-NAM-

The National Association of Manufacturers is the largest manufacturing association in the United States, representing small and large manufacturers in every industrial sector and in all 50 states. Manufacturing employs more than 12.7 million men and women, contributes $2.71 trillion to the U.S. economy annually and accounts for 58% of private-sector research and development. The NAM is the powerful voice of the manufacturing community and the leading advocate for a policy agenda that helps manufacturers compete in the global economy and create jobs across the United States. For more information about the NAM or to follow us on Twitter and Facebook, please visit www.nam.org

As the Securities and Exchange Commission considers a prescriptive rule that imposes significant and burdensome climate-related disclosure obligations on public companies, the NAM is pushing back. It is fighting for critical changes that will support manufacturers’ leadership on climate change.

The background: Manufacturers have long been leaders on climate solutions, working to create the technologies and processes needed to combat climate change while also providing material information about their climate-related efforts to investors.

• But a recent rule proposed by the SEC would mandate that companies, large and small, report reams of complex climate-related information, even when that information may not have any impact on their financial performance or operations.

The rule: The proposed rule, which the SEC released in March, would require qualitative descriptions of companies’ climate-related risks and strategies as well as quantitative reporting of their greenhouse gas emissions and any climate-related impacts on their financial statements.

• The result would be an unworkable framework that does not align with current practices—imposing an enormous burden on manufacturers across the country.
• Additional information can be found about the rule here and about the NAM’s engagement with the SEC on climate disclosures here.

The response: The NAM has laid out a series of necessary changes that the SEC must make to reduce the compliance costs and liability risks associated with the rule’s requirements. Our recommendations will align the rule more closely with current climate reporting practices—decreasing burdens on public companies and increasing information utility for investors. Specifically, the NAM is calling on the SEC to:

• Delay annual GHG emissions reporting, granting manufacturers time to collect and verify data for a midyear report (rather than the proposed February deadline).
• Strike disclosure of Scope 3 emissions, which requires tracking emissions data through the supply chain. While some manufacturers are already working to understand these emissions, the data collection, estimation and reporting methodologies are still evolving. At a minimum, the SEC should provide more flexibility for companies subject to the Scope 3 requirement.
• Rescind accounting changes that would require climate impact analyses of companies’ consolidated financial statements on a line-by-line basis.
• Adjust the climate-related risk disclosures and Scope 1 and Scope 2 emissions reporting requirements to make the provisions less prescriptive and more aligned with existing company practices.
• Fine-tune the guidelines for reporting on climate-related goals to avoid penalizing companies that set ambitious targets.
• Remove requirements that companies disclose competitively sensitive information about the internal tools they use to understand and plan for climate risks, scenarios and activities.

The last word: “The SEC’s climate rule as written would be harmful for both large and small manufacturers and unhelpful for investors,” said NAM Senior Director of Tax and Domestic Economic Policy Charles Crain. “The NAM is committed to supporting our members in their efforts to combat climate change and inform investors about this critical work, and the recommendations we’ve offered present an important step toward that goal.”

Watch: NAM President & CEO Jay Timmons joined CNBC to discuss the impact of the proposed rule.

As the Securities and Exchange Commission considers a prescriptive rule that imposes significant and burdensome climate-related disclosure obligations on public companies, the NAM is pushing back. It is fighting for critical changes that will support manufacturers’ leadership on climate change.

The background: Manufacturers have long been leaders on climate solutions, working to create the technologies and processes needed to combat climate change while also providing material information about their climate-related efforts to investors.

• But a recent rule proposed by the SEC would mandate that companies, large and small, report reams of complex climate-related information, even when that information may not have any impact on their financial performance or operations. 

The rule: The proposed rule, which the SEC released in March, would require qualitative descriptions of companies’ climate-related risks and strategies as well as quantitative reporting of their greenhouse gas emissions and any climate-related impacts on their financial statements.

• The result would be an unworkable framework that does not align with current practices—imposing an enormous burden on manufacturers across the country.
• Additional information can be found about the rule here and about the NAM’s engagement with the SEC on climate disclosures here.

The response: The NAM has laid out a series of necessary changes that the SEC must make to reduce the compliance costs and liability risks associated with the rule’s requirements. Our recommendations will align the rule more closely with current climate reporting practices—decreasing burdens on public companies and increasing information utility for investors. Specifically, the NAM is calling on the SEC to:

• Delay annual GHG emissions reporting, granting manufacturers time to collect and verify data for a midyear report (rather than the proposed February deadline).
• Strike disclosure of Scope 3 emissions, which requires tracking emissions data through the supply chain. While some manufacturers are already working to understand these emissions, the data collection, estimation and reporting methodologies are still evolving. At a minimum, the SEC should provide more flexibility for companies subject to the Scope 3 requirement.
• Rescind accounting changes that would require climate impact analyses of companies’ consolidated financial statements on a line-by-line basis.
• Adjust the climate-related risk disclosures and Scope 1 and Scope 2 emissions reporting requirements to make the provisions less prescriptive and more aligned with existing company practices.
• Fine-tune the guidelines for reporting on climate-related goals to avoid penalizing companies that set ambitious targets.
• Remove requirements that companies disclose competitively sensitive information about the internal tools they use to understand and plan for climate risks, scenarios and activities.

The last word: “The SEC’s climate rule as written would be harmful for both large and small manufacturers and unhelpful for investors,” said NAM Senior Director of Tax and Domestic Economic Policy Charles Crain. “The NAM is committed to supporting our members in their efforts to combat climate change and inform investors about this critical work, and the recommendations we’ve offered present an important step toward that goal.”

Washington, D.C. – Following the introduction of the Environmental Protection Agency’s proposed Water Quality Certification Improvement Rule, National Association of Manufacturers Vice President of Energy and Resources Policy Rachel Jones released the following statement:

“The EPA’s new water permitting proposal falls short of providing the certainty that manufacturers in America desperately need from their local, state and federal regulators, and if the EPA doesn’t get the regulations right here, American families will continue to feel the consequences of rising construction costs and delayed infrastructure investments. While we are pleased that this proposal provides some clarity on the scope of reviews and sets timelines to increase predictability, it just doesn’t go far enough to stop activists from abusing what were intended to be important water protections.

“Manufacturers in America have endured red tape and permitting delays for decades, and manufacturers know what happens when the vaguely worded Section 401 is used as an excuse to block critical infrastructure: We lose out on modern manufacturing jobs. By setting clearer guidelines, the EPA could empower manufacturers to invest in our people and communities with confidence and to work with state leaders to protect our water and environment. The NAM will continue working with policymakers to improve this measure so that it can strengthen environmental stewardship while speeding infrastructure investment and expanding manufacturing here in the United States.”

-NAM-

The National Association of Manufacturers is the largest manufacturing association in the United States, representing small and large manufacturers in every industrial sector and in all 50 states. Manufacturing employs more than 12.7 million men and women, contributes $2.71 trillion to the U.S. economy annually and accounts for 58% of private-sector research and development. The NAM is the powerful voice of the manufacturing community and the leading advocate for a policy agenda that helps manufacturers compete in the global economy and create jobs across the United States. For more information about the NAM or to follow us on Twitter and Facebook, please visit www.nam.org.

As the U.S. Securities and Exchange Commission works to finalize a new rule requiring climate disclosures by public companies, the NAM is mobilizing to defend manufacturers.

The background: Manufacturers have long been leaders on climate solutions, working to create the products and technologies necessary to face the challenge of climate change.

• Manufacturers also regularly provide climate-related information to their investors, including via corporate sustainability reports, third-party reporting frameworks and SEC filings.
• At the beginning of the Biden administration, however, the SEC made clear that it was interested in creating a rule to enhance and standardize these disclosures.
• In the months since, the commission has taken steps toward that goal—and the NAM has stepped up to protect manufacturers.

In March 2021, the SEC issued a request for information on climate disclosures. The NAM responded, urging the SEC to adopt a flexible, principles-based framework that allows companies to provide investors with material information about climate risks in a consistent and comparable manner.

In September, the SEC’s Division of Corporation Finance issued new guidance calling into question companies’ existing climate disclosure practices—including the common practice of supplementing SEC filings with a sustainability or corporate social responsibility report.

• The NAM pushed back against the guidance, cautioning the division against setting new standards without a formal rulemaking process.

In October, the division released guidance drastically limiting the ability of companies to exclude climate-related shareholder proposals from the annual proxy ballot—even if those proposals are unrelated to a business’s operations.

• The NAM pushed back, emphasizing the importance of company-specific decisions for protecting manufacturers and their long-term shareholders.

The new rule: The SEC released a proposed rule in March that would significantly expand public companies’ climate disclosure obligations.

• First, the rule would require qualitative descriptions of companies’ climate-related risks and any efforts to respond to those risks.
• It also would require quantitative reporting of companies’ greenhouse gas emissions and institute a new mandate that companies conduct quantitative climate impact analysis within their consolidated financial statements.
• You can read more about the specifics of the rule here.

NAM in action: The NAM has spent the past several months connecting with manufacturers across the country to understand the real-world impact of the SEC’s proposal.

• Through a range of webinars, listening sessions and roundtables, we have been able to explain the proposed rule, gather vital feedback and map out the way forward.

What’s next: The NAM intends to provide comments to the SEC in June, highlighting provisions within the proposed rule that are impractical, costly, overly prescriptive, confusing for investors or not reflective of current climate disclosure practices.

• The NAM will call on the SEC to make targeted changes to its proposal to increase flexibility, focus on material information for investors and reduce costs, burdens and liability for companies.

What we’re saying: “Manufacturers are the leaders in America’s fight against climate change—and in order to continue that work, we need climate disclosure practices that support sustainability, rather than increasing costs for companies and confusing investors,” said NAM Senior Director of Tax and Domestic Economic Policy Charles Crain.

• “Any SEC climate disclosures rule needs to be less prescriptive, more flexible and solely focused on materiality in order to accurately reflect current practices.”
• “The bottom line is that a climate disclosures rule can’t just sound good; it has to actually work in the real world.”

Washington, D.C. – In response to the Senate Foreign Relations Committee passage of the Kigali Amendment, the National Association of Manufacturers, Air-Conditioning Heating and Refrigeration Institute, American Chemistry Council, The Alliance for Responsible Atmospheric Policy, and the U.S. Chamber of Commerce issued the following statement:

“The business community applauds the Senate Foreign Relations Committee for its bipartisan vote approving the Kigali Amendment for consideration by the full Senate. This is an important step in ensuring the U.S. joins this global effort while accessing international markets that will grow American jobs. It is a win for the economy, the environment, and U.S. leadership.”

-NAM-

The National Association of Manufacturers is the largest manufacturing association in the United States, representing small and large manufacturers in every industrial sector and in all 50 states. Manufacturing employs more than 12.5 million men and women, contributes $2.71 trillion to the U.S. economy annually and accounts for 58% of private-sector research and development. The NAM is the powerful voice of the manufacturing community and the leading advocate for a policy agenda that helps manufacturers compete in the global economy and create jobs across the United States. For more information about the NAM or to follow us on Twitter and Facebook, please visit www.nam.org.

Washington, D.C. – National Association of Manufacturers Chief Legal Officer Linda Kelly issued the following statement in response to California Attorney General Rob Bonta’s announcement of an investigation into fossil fuel and petrochemical industries:

“Not every societal problem demands a state attorney general investigation or adversarial legal process. In fact, anyone who understands the manufacturing sector would know that we are the solution here. Manufacturers are pioneering the technologies, processes and products, including advanced recycling, that are needed to protect our environment, improve sustainability and move toward a circular economy.

“Plastics play a vital role in modern life and improving quality of life. Solutions to waste issues require collaboration with government, consumers and manufacturers. Manufacturers are ready to be collaborative partners with anyone who shares our commitment to a healthier environment.”

-NAM-

The National Association of Manufacturers is the largest manufacturing association in the United States, representing small and large manufacturers in every industrial sector and in all 50 states. Manufacturing employs more than 12.5 million men and women, contributes $2.71 trillion to the U.S. economy annually and accounts for 58% of private-sector research and development. The NAM is the powerful voice of the manufacturing community and the leading advocate for a policy agenda that helps manufacturers compete in the global economy and create jobs across the United States. For more information about the NAM or to follow us on Twitter and Facebook, please visit www.nam.org.

Washington, D.C. – Following the Environmental Protection Agency’s release of its “Good Neighbor” Plan to expand regulation of interstate transport of air emissions that affect downwind states’ ability to attain and maintain National Ambient Air Quality Standards, National Association of Manufacturers Senior Vice President of Policy and Government Relations Aric Newhouse released the following statement:

“Manufacturers are committed to clean air and healthy communities. We have taken the initiative to operate in cleaner, more sustainable ways, and we are proud of our record. Our ‘Promise Ahead’ proposal offers numerous ideas on how we can continue to improve our environment and address climate change.

“While the intent of this proposal is right and one that we share, it could have significant effects on American families if not thoughtfully implemented. At a time when our supply chains are snarled, inflation is skyrocketing and Russia’s war on Ukraine continues, we must be careful with regulations that could further raise prices on all Americans, slow economic growth and threaten jobs.

“We will work with the EPA to ensure these new rules can achieve shared goals in a constructive way that will not have unintended consequences and ripple effects throughout our economy and communities. We look forward to sharing our innovation, technology and supply chain expertise to do so.”

-NAM-

The National Association of Manufacturers is the largest manufacturing association in the United States, representing small and large manufacturers in every industrial sector and in all 50 states. Manufacturing employs more than 12.5 million men and women, contributes $2.57 trillion to the U.S. economy annually and has the largest economic multiplier of any major sector and accounts for 58% of private-sector research and development. The NAM is the powerful voice of the manufacturing community and the leading advocate for a policy agenda that helps manufacturers compete in the global economy and create jobs across the United States. For more information about the NAM or to follow us on Twitter and Facebook, please visit www.nam.org.

Securities and Exchange Commission Chairman Gary Gensler said that the agency will release proposed rules by the end of this year requiring that public companies disclose risks related to climate change, according to MarketWatch.

What they’ll cover: Chairman Gensler indicated that he wants climate disclosures to be “consistent and comparable” and provide decision-useful information to investors. He said staff is considering whether such disclosures would be included in companies’ 10-K filings, whether they would include Scope 1, Scope 2 and/or Scope 3 emissions and whether certain metrics would be required for specific industries.

The challenge: Many manufacturers already voluntarily disclose a significant amount of information about their climate efforts, but an overbroad mandate could impose new cost burdens on companies without providing useful information to shareholders.

What we’re doing: The NAM has consistently stood up for manufacturers, encouraging the SEC to adopt a principles-based approach rather than a uniform mandate. Back in June, the NAM laid out the manufacturing industry’s perspective for the SEC and provided a list of principles that should guide any eventual disclosure framework. As the process moves forward, the NAM will continue to engage with the SEC and advocate for manufacturers.

Learn more: For more information about our principles and the work the NAM has been doing in this area, check out this recent story.