Part 12: CSRD Delay: A "Blessing in Disguise" for Frontrunners?

This interview is part of 𝐅𝐨𝐥𝐥𝐨𝐰 𝐭𝐡𝐞 𝐇𝐨𝐧𝐞𝐲, weekly interviews with fresh takes on biodiversity in business.

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‍We’ve heard from the standard-setters and the policymakers. We’ve discussed the theory of change and the political headwinds. But what does this actually look like on Monday morning for the person who has to implement it all?

I spoke with Zsuzsa Kozma, CSR Director at Termeer Group (the parent company of Sacha, Sissy Boy, and Manfield). She gave me a sneak peek into the engine room of a retail company with 7,000 unique products and a global supply chain. Zsuzsa shares why she sometimes feels more like an IT manager than a sustainability leader, the paralyzing effect of regulatory uncertainty, and her pragmatic "materials-first" approach.

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Can you start by telling me a bit about your background and how you ended up in your current role at Termeer Group?

My background is actually in product development and buying. I spent years in the industry, so I know what it takes to make a shoe or a garment. But nearly two years ago, I was hired by Termeer Group with a very specific mission: to guide the company through the incoming tsunami of CSRD regulation. They realized they needed someone dedicated to this full-time to get the organization ready for what was coming.

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Did you feel you had the necessary buy-in from the organization to take that on?

Yes, and that is crucial. It helps that we are a family business. Our CEO has a long-term vision; he wants the company to exist for the next generation. He understands that sustainability is part of that license to operate.

But even with that buy-in, the reality of the job was different than I expected. I previously worked on the Dutch Agreement on Sustainable Garments and Textile. Back then, we spent our time visiting factories, we had endless conversations about living wages, freedom of association, and water usage. We were working on real projects that touched people.

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The sheer amount of legislation coming out of the Green Deal means I barely have time for the "real" work anymore.

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And how does the reality of your current role compare to that?

Now? I sometimes feel like I work in IT.

I spend my days building systems. I’m figuring out how to tie data knots together, how to validate information streams, and how to get everything audit-ready. The sheer amount of legislation coming out of the Green Deal means I barely have time for the "real" work anymore. I’m just building the machine to report on it.

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What is the consequence of that shift for your budget and your impact?

It’s frustrating. I said this to our board recently: "If you had given me this budget and told me to do something nice with it, we could have been paying living wages in India for years."

Instead, that money goes to consultants, IT systems, and validation tools. Don't get me wrong, Europe will become more transparent because of this, and that has value. But the supply chain itself? The people making our shoes? They aren't seeing that money.

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The pressure was so high that we were rushing just to be compliant, knowing we weren't really ready. The delay gives us breathing room.

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So, was it a relief when the news came that the CSRD implementation was going to be softened?

To be honest? Yes. And I think many people in my position felt the same.

It’s not because we don't want to do it. It’s because we want to do it right. The pressure was so high that we were rushing just to be compliant, knowing we weren't really ready. The delay gives us breathing room. It allows me to say, "Okay, I don't have to spend all my budget on an auditor right now. I can spend this year actually organizing my data properly." It felt like a gift of time to focus on quality.

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Is that the case for all the regulations coming your way?

Not at all. While the delay for CSRD gave us breathing room, the uncertainty with the EU Deforestation Regulation (EUDR) created a "limbo effect" that is actually quite dangerous.

Because of the rumors that it might be delayed, suppliers hesitated. They didn't invest in the geolocation systems because they hoped they wouldn't need them yet. Now, they are in panic mode. They realize they have to provide geolocation data for products that are already in production. It’s a scramble. If the regulation had just been clear and steady, we could have prepared. But the uncertainty paralyzed them, and now it’s a crisis.

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I prefer to be pragmatic. I don't need a perfect LCA to know that leather has a higher footprint than canvas. I can act on that information without the expensive consultant.

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How important is data in solving these problems?

Data is important, but there is a trap in thinking that more detail always equals better action. You can pay a consultant a lot of money to calculate the exact environmental footprint of a specific shoe. The data comes back and tells you: "The biggest impact is the electricity mix of the factory in China."

Okay, great. But I cannot change the national energy grid of China. I can't even force that factory to put solar panels on their roof if I'm just one of their fifty clients. So I paid for very expensive, very specific data that points to a solution that is completely out of my sphere of influence.

That is why I prefer to be pragmatic. I don't need a perfect LCA to know that air freight has a high impact, or that leather has a higher footprint than canvas. I can act on that information without the expensive consultant.

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In your opinion, is the data required for reporting also the data you need to steer the business towards being more sustainable?

Yes and no. Measuring impacts and risks is a really valuable exercise that we will be doing also for our own understanding of our business activities. But I realized that for a retail business, working on separate "themes" makes no sense. Whether I’m dealing with water, biodiversity, or CO2, the solution is almost always the same: I need to make my materials more sustainable. If I source better cotton, I fix the water issue and the biodiversity issue and the social issue.

So, when the CSRD was off the table for Termeer, I stopped thinking in "themes" and started thinking in "materials." We focus on our top five: leather, cotton, glass, ceramic, and paper. We set KPIs for those. By making the material sustainable, we automatically hit the targets for all those separate CSRD chapters.

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Is this a common way of going about it at the moment in your industry right now?

No, many companies that fell out of scope for the CSRD stopped their efforts right away. I live in a "green bubble." I see the same 10 to 15 frontrunner companies at every sustainability event. We all know each other.

But outside of that bubble? It’s empty. The frontrunners are running hard, but the rest of the pack hasn't even started. That gap is worrying because it kills collaboration. If the maturity levels are too far apart, you can't work together. It’s like putting a student from the final year of high school in a group project with a second grader. They are both trying to learn, but they speak a completely different language and have completely different needs. It isolates the leaders and paralyzes the beginners.

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What do you think will move the beginners?

It will be the cascade effect. The CSRD applies to the big players first. But those big players (the Zalandos, the De Bijenkorfs) will eventually demand data from their smaller suppliers.

I see it happening already. Suppliers are panicking because a big client demanded a full carbon footprint or a living wage audit to keep a contract. That commercial pressure is what will finally wake up the laggards. It won't be the legislation directly; it will be their biggest customer saying, "No data, no deal."

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What advice would you give to others in similar positions who are just starting out?

Don't do it alone. It sounds like a cliché, but it’s true.

This stuff is incredibly complex. If you sit behind your desk and try to figure out the EUDR or the CSRD by yourself, you will go crazy. You will think, "This is too complicated, I'll park it," and then two years pass and you've done nothing. Find peers. Join a working group. Even if you are competitors, on this topic, you are allies. Nobody knows 100% of the answer, but everyone has figured out 10%. When you put that together, it suddenly becomes doable.