August, 2026
True Price Foundation welcomes the opportunity to respond to the European Commission’s consultation on guidelines to accompany the EU Corporate Sustainability Due Diligence Directive (CSDDD).
True Price Foundation is a non-profit organisation based in the Netherlands, working globally to advance the understanding and adoption of true pricing and true cost accounting. Our aim is to support a more inclusive and sustainable economy where all products integrate hidden social and environmental costs. For more than 12 years, True Price has been at the forefront of impact valuation, true cost accounting and living income measurement approaches across value chains, including cocoa, coffee, tea, and other sectors.
True Price Foundation supports ambitious and effective implementation of the CSDDD, and sees robust impact measurement and valuation as essential to credible due diligence. Assessing the true cost of a company’s operations and supply chains allows businesses to identify, prioritise risks and impacts, monitor and take action to remediate and eliminate external costs as much as possible. The True Price Database is an accessible and free resource for non-profits and knowledge institutions, and which businesses can also use as due diligence tool.
The role of true cost accounting and true pricing in due diligence (Article 8 – Identifying and assessing actual and potential adverse impacts)
True cost accounting (TCA)[1] and true pricing[2] are decision-making tools that can support companies in identifying and assessing actual and potential adverse impacts. The True Price Standard includes, principles, methodology and monetisation factors. It is publicly available, versioned, and transparently documented, and is being increasingly used in both in academia and businesses.[3]
We believe the CSDDD guidelines should offer examples of adverse human rights (including labour rights) and environmental impacts, ideally structured as a clear classification. They should build as much as possible on existing classifications, including the field of true cost accounting, and the True Price Standard’s list of social and environmental impacts (see Table 1 below)
We recognise the need and call on the European Commission to support development efforts for a social and environmental accounting standard, in the same way that financial accounting standards have been developed over the past century. Social and environmental accounting standards must be scientifically based, open, auditable, version-tracked, aligned with regulation, and developed in an inclusive manner.
Rights-based approach in true cost accounting (Article 9 – Prioritisation of identified actual and potential adverse impacts)
Once impacts are quantified, True Price uses remediation cost as a monetisation technique, which can be understood as a reasonable operationalisation of severity (which accounts for irremediability). This approach is in line with the CSDDD own framing of severity by reference to scale, scope and irremediable character. The methodology is grounded in a rights-based approach to monetary valuation, rather than a purely economic cost perspective: it draws on human rights and labour rights frameworks, the UN Sustainable Development Goals, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises. This means valuations are anchored in what is needed to prevent, restore, compensate, and provide remedy for harm on human-rights or an ecosystem’s function, not in market prices or a purely economic cost-benefit calculation. As a result, the resulting severity estimates reflect the CSDDD’s underlying objective of protecting people and the environment, rather than treating impacts merely as economic externalities to be minimised.
The CSDDD guidelines should recognise monetised severity estimates, based on published and versioned valuation methods, as an acceptable basis for assessing and comparing severity of actual and potential adverse impacts. The True Price rights-based valuation methodologies are designed to reflect the same underlying concern for human rights and environmental protection that motivates the CSDDD, they are well suited to inform how companies determine and compare severity.
Finally, where data is limited, this should not be a reason to exclude a topic from assessmentd. In line with established practice in true cost accounting, we recommend that the guidelines require a documented screening of all impact topics, even where the underlying evidence is qualitative or limited, before any impact is excluded from further assessment. Impacts that are excluded should only be so on the basis of this documented screening, and any excluded impact that is not expected to be of low severity should be required to be stated in the final results. This ensures that data gaps lead to transparency about uncertainty, rather than to the silent exclusion of impacts that may in fact be significant.
[1] A holistic and systemic approach to measuring and valuing the environmental, social, health and economic costs and benefits generated by agrifood systems to facilitate improved decisions by policymakers, businesses, farmers, investors and consumers.
[3] Full list of scientific literature and businesses using True Price Method is available upon request, recent academic references on Table 2 below. Relevant contributions include 2021 UN Food Systems Summit Scientific Group True Cost and True Price of Food.
Visit: https://www.truepricefoundation.org/ to learn more.
All Methods are available from: True Price Standard – True Price Foundation
Contact: info@trueprice.org