Imagine finding out you've run out of milk immediately after pouring a bowl of cereal. Or maybe realizing you don't have eggs while in the middle of baking a cake. We've all been there, and it's frustrating, to say the least. And this scene has been playing around the globe over the last couple of years for many foods and products. One day it's microchip shortages, and the next, it's baby formula.

Unfortunate as it is, it's one thing for consumers to cope with an empty car lot because of chip shortages. It's another to cope with a hungry infant because store shelves that once contained baby formula are now bare. For those parents and caretakers, their emotions are beyond feeling frustrated. They feel anger and panic, the sort of emotions that they share with their friends and colleagues on social media and forums. The kind of expression that can change the public's sentiment about a company, which in turn can move markets.

This Alternative Data Trends post will examine web data concerning the baby formula shortage. We'll analyze articles, social media, and forum conversations culminating in the U.S. crisis as the news reaches national exposure. We'll also highlight red flags investors could've seen had they monitored the situation with an AI-powered text analysis tool like SESAMm's TextReveal®.

Early warnings: When baby formula supplies began to run dry vs. when it became a national crisis

If we compare absolute and relative volumes—relative being mentions about the topic compared to our entire data lake—the term "formula milk market" yields parallel results. Mentions spike in May when the crisis reaches national coverage (see Figure 1).

However, comparing absolute and relative volumes for the term "formula milk shortage," we find red flags as early as January 2022, four months before the crisis receives national attention (see Figure 2). Relative mentions spike on three occasions before absolute volumes register any significant noise. The fourth instance matches a ripple on the absolute chart.

These articles provide an example of the content published around the times of those rises in mentions:

1. Jan. 12, 2022: "Baby Formula Is Hard to Find. Brands and Stores Are Divided Over Why.," WSJ
2. Feb. 9, 2022: "Baby formula shortage has some families scrambling," WCAX-CBS
3. Mar. 7, 2022: "Baby formula shortage and recalls affecting families," KGUN-ABC
4. Apr. 11, 2022: "A shortage of baby formula is worsening and causing some stores to limit sales," WHYY-PBS

Analyzing the sentiment and polarity of the formula milk market

In short, the e-reputation of the formula milk market has been negative since the beginning of 2022 (see Figure 3). Positive sentiment drops and reflects the opposing negative sentiment almost exactly until May, when the news about the crisis breaks. Likewise, polarity trends downward over the same period.

Note: Polarity represents a company's aggregate of positive and negative sentiment (opinions, reviews), ranging from -1 to 1. A zero score means that there is as much positive as negative sentiment. High e-reputation brands can have polarity scores of more than 0.5.

The web data shows that some articles correlate with sentiment and polarity changes. For instance, in February, AboutLawsuits.com posted, "Similac and Enfamil Baby Formula Shortages Create Infant Feeding Challenges." And in May, HealthDay, a prominent syndicator of health news, posts, "U.S. Baby Formula Shortage Worsens."

Analyzing formula milk brands

In the U.S., four brands produce the bulk of formula milk: Abbott, Mead Johnson, Nestlé, and Perrigo. Abbott and Nestlé hold the largest share of the formula milk market.

When we group these four brands' mentions from January 2021 to June 2022, we can see how their mention volumes compare (Figure 4). For example, at the beginning of the graph, we can see that Abbott and Nestlé have more mention-volume relative to their market share. However, at the end of 2021, Mead Johnson and Abbott experience spikes in mentions due to lawsuits against their formulas. Then, in Q1 2022, Abbott mentions increased drastically after its formulas were recalled due to possible contamination, taking more than 75% of the mention volume.

Analyzing ESG risks by company

Evaluating the top four brands' ESG risks reveals red flags as early as May 2021, when Abbott was fined for including a banned flavoring in its baby formula (see Figure 5). And most red flags were raised before the national shortage crisis was publicized widely.

Besides Abbott, most brands' risks remained low during 2021. However, ESG risks increase during Q1 2022 for all four major formula milk brands. The FDA warned consumers against using specific Abbott formulas during an investigation of infant illnesses possibly caused by Abbott's formulas. Perrigo settles a lawsuit from the State of California over baby formula lead levels. And a panel of federal judges centralizes many baby formula lawsuits into one federal court, including cases against Mead Johnson. Nestlé stays below the 5% threshold throughout, with little to no controversies found.

Three tactics and a summary

The baby formula market in the U.S. has been volatile for many reasons, which we won't get into in this article. However, this volatility could be seen and planned for. In this case, here are some tactics you can take to minimize your investment risks:

1. Employ a tool like SESAMm’s TextReveal to evaluate web data for insights into your investments. With premiere NLP technology, you can uncover sentiment and ESG insights about your industry, portfolio companies, or current investments.
   
   
2. Expand your research term for deeper insights. In this study, the term "formula milk market" had matching absolute and relative volumes. From this view, nothing looks out of place, and there aren't any red flags. However, when we expanded our research with the term "formula milk shortage," we found many controversies before the crisis gained national attention.
   
   
3. Dig into the controversies' causes. It's not enough to acknowledge a red flag. It would be best if you looked into what the potential reason is. Is the controversy caused by external factors or internal ones? Maybe both? Is the issue a one-time occurrence, or is it a pattern? So it's essential to avoid black-box tools. With solutions such as TextReveal that allow you to see beyond, you can access the underlying articles triggering the red flags.

Stay in touch with SESAMm

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The European Union stands at the forefront of global efforts to promote environmental, social, and governance (ESG) accountability. As the world becomes increasingly ESG-aware, the EU has developed a comprehensive regulatory framework designed to ensure transparency and accountability across all sectors.

These regulations represent the EU's commitment to sustainable development and responsible business practices. However, the regulatory landscape is evolving, with the February 2025 EU Omnibus Proposal introducing potential modifications aimed at reducing the regulatory burden on businesses. However, these proposals come at the risk of substantially undercutting the impact of the regulations.

This article recaps the current ESG regulatory framework in the EU, explores the changes proposed by the Omnibus, analyzes the potential impacts of these modifications, and discusses how financial institutions can navigate this evolving landscape while maintaining compliance.

The ESG Regulatory Landscape in the EU

The EU is advancing sustainability through a framework of regulations that enhance corporate accountability and reporting on ESG impacts. These measures aim to promote genuine sustainable practices and address international trade and emissions challenges. Though comprehensive, these regulations are also, at times, confusing in the way they overlap and impact each other.
To get started, let’s examine the EU Taxonomy, SFDR, and CSRD—a triad of interconnected regulations designed to streamline and strengthen sustainable investing practices.

EU Taxonomy

The EU Taxonomy provides a classification system for environmentally sustainable economic activities, offering clear criteria to determine whether an economic activity can be considered "green."

Key Aspects of the EU Taxonomy

• Defines criteria for environmentally sustainable economic activities
• Helps investors identify truly sustainable investments
• Establishes a framework to prevent greenwashing
• Requires companies subject to CSRD to report on Taxonomy alignment
  

The Taxonomy helps channel investment toward genuinely sustainable projects and businesses by creating a common language for sustainable activities.

Status

The EU Taxonomy has been operational since January 2022 with phased implementation. As of March 2025, companies subject to CSRD must disclose their taxonomy alignment percentages.

Sustainable Finance Disclosure Regulation (SFDR)

The SFDR focuses specifically on the financial sector, requiring financial market participants to disclose how they integrate ESG risks into their investment decisions and the sustainability impact of their financial products.

Key Aspects of SFDR

• Requires disclosure of ESG risks in investment processes
• Classifies financial products based on their sustainability characteristics
• Aligns with EU Taxonomy criteria for sustainable investments
• Aims to prevent greenwashing in financial products
  

The SFDR plays a crucial role in bringing transparency to the rapidly growing sustainable investment market.

Status

Fully implemented since March 2021, with enhanced Level 2 requirements since January 2023. All EU financial market participants must classify products under Articles 6, 8, or 9. Current market data shows that 28% of EU funds are compliant with Article 8 and 5% with Article 9, with a significant trend of reclassification from Article 9 to 8 due to stricter interpretations.

Corporate Sustainability Reporting Directive (CSRD)

The CSRD stands as a cornerstone of the EU's ESG regulatory framework, requiring companies to report comprehensively on their environmental, social, and governance impacts. This directive mandates alignment with the EU Taxonomy, ensuring standardized reporting of sustainability metrics.

Key Aspects of CSRD

• Requires detailed reporting on ESG impacts
• Aligns with EU Taxonomy criteria for sustainability
• Currently applies to companies with 250+ employees
• Enhances corporate transparency on sustainability issues
  

The CSRD represents a significant step forward in standardizing sustainability reporting across the EU, providing investors, consumers, and regulators with comparable information on corporate sustainability performance.

Status

The CSRD, adopted in November 2022, replaces the Non-Financial Reporting Directive (NFRD). The transition to CSRD reporting was originally slated to begin in 2025 and would expand the number of companies subject to reporting requirements to 49,000 (vs 11,700 under NFRD). However, as we’ll see later, the Omnibus may push back the timing of CSRD.

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Outside of the EU Taxonomy, SFDR, and CSRD, the Omnibus Proposal highlights two other key ESG regulations: CSDDD and CBAM. These regulations relate to corporate accountability for supply chains and to limiting carbon leakage.

Corporate Sustainability Due Diligence Directive (CSDDD)

The CSDDD focuses on corporate accountability throughout global supply chains, requiring companies to identify, prevent, and mitigate human rights and environmental risks associated with their operations.

Key Aspects of CSDDD

• Requires companies to identify and mitigate human rights and environmental risks
• Applies to full supply chains, ensuring comprehensive oversight
• Applies to EU companies with 1,000+ employees and €450 million+ global turnover and non-EU companies with over €450 million EU turnover
• Mandates regular monitoring and reporting on due diligence efforts
• Strengthens corporate accountability for sustainability across operations
  

This directive acknowledges that a company's sustainability impact extends beyond its direct operations, encompassing its entire value chain.

Status

CSDDD was adopted in April 2024. Its phased implementation is slated to start in June 2026 and be completed by June 2028. The timing and scope of CSDDD is subject to change following the Omnibus Proposal.

Carbon Border Adjustment Mechanism (CBAM)

The CBAM is an innovative approach to preventing carbon leakage. It levies a carbon tax on imports to ensure that the EU's ambitious climate policies do not simply shift carbon-intensive production outside its borders.

Key Aspects of CBAM

• Imposes a carbon tax on imported goods
• Requires importers to report emissions data
• Ensures payment for embedded carbon costs in imported products
• Aims to prevent carbon leakage to regions with weaker climate policies
  

This mechanism aims to create a level playing field for EU producers subject to carbon pricing while encouraging global partners to implement similar carbon pricing mechanisms.

Status

The transitional phase for CBAM began in October 2023, with full implementation scheduled for January 2026. It currently covers cement, iron and steel, aluminum, fertilizers, electricity, and hydrogen. The certificate requirements will phase in gradually from 30% in 2026 to 100% by 2034. It’s expected to apply to 1.8 million EU importers and generate €5-14 billion in annual revenue when fully implemented.

The February 2025 EU Omnibus Proposal

Purpose and Goals

The EU Omnibus Proposal represents a significant recalibration of the EU's regulatory approach, seeking to balance sustainability ambitions with business competitiveness concerns.

The primary objectives of the Omnibus focus on alleviating regulatory burdens faced by businesses, simplifying compliance requirements, and streamlining reporting obligations. These efforts aim to enhance business competitiveness while addressing regulatory complexity concerns. By minimizing these challenges, the goal is to create a more favorable environment for businesses to thrive. However, this push for simplification could come at the expense of transparency and accountability, especially in sectors where regulation plays a protective role.

Impact Analysis: How the Omnibus Changes ESG Compliance

Below, we’ll take a closer look at each regulation and the changes proposed by the Omnibus Proposal.

EU Taxonomy Modifications and Implications

The Omnibus Proposal suggests a Level 2 modification to the application of the EU Taxonomy, reducing the number of companies required to report taxonomy alignment.

Key Changes:

• Taxonomy alignment reporting is limited to companies subject to CSDDD
• Voluntary reporting option for companies not required to comply
  

Possible Implications:

• Reduced availability of standardized sustainability data
• Increased difficulty in verifying "green" business claims
• Higher risk of greenwashing in financial markets
• Less reliable information for sustainable investors
  

These modifications would potentially undermine the Taxonomy's role in creating a common language for sustainable activities.

CSRD Modifications and Implications

The Omnibus Proposal significantly narrows the scope of the CSRD, reducing the number of companies required to report on ESG impacts.

Key Changes:

• Threshold increase from 250+ to 1,000+ employees
• Optional reporting for SMEs
• A two-year delay in reporting obligations for some companies
  

Possible Implications:

• 80% reduction in companies required to report
• Decreased transparency in corporate sustainability performance
• Fewer sustainability data available to investors and regulators
• Potential challenges in tracking sustainability progress

These modifications would substantially reduce the regulatory burden on smaller companies but raise concerns about the availability of comprehensive sustainability data.

CSDDD Modifications and Implications

The Omnibus  includes significant modifications to CSDDD, with a narrowed scope and reduced monitoring requirements.

Key Changes:

• Due diligence is limited to direct suppliers with over 500 employees, not full supply chains
• Monitoring frequency reduced from annual to every 5 years
• Delayed enforcement for one year for the first batch (Companies with 1.5 billion in turnover and 5000 employees)

Possible Implications:

• Weakened corporate accountability for supply chain sustainability
• Increased risk of undetected human rights and environmental violations
• Reduced monitoring of global supply chain impacts
• Extended timeline before full implementation

These changes would significantly reduce companies' compliance burdens but come at the risk of removing the essence of the directive, which is eliminating child labor, forced labor, etc.

SFDR  Modifications and Implications

While not directly modified, changes to other regulations, particularly the EU Taxonomy, indirectly affect the SFDR.

Indirect Impacts:

• Reduced availability of reliable ESG data
• Challenges in differentiating truly sustainable investments
• Potential increase in greenwashing risk
  

These indirect effects could undermine the SFDR's effectiveness in bringing transparency to sustainable investment products.

CBAM Modifications and Implications

The Omnibus Proposal simplifies CBAM compliance, particularly for smaller importers.

Key Changes:

• Small importers (under 50 metric tons/year) are exempted
• Reduced reporting burden for over 182,000 businesses
  

Possible Implications:

• Simplified compliance for small businesses
• Potential loophole risk if companies split shipments to stay under the threshold
• Maintained coverage of 99% of emissions despite exemptions
  

These modifications would maintain the CBAM's effectiveness while reducing the administrative burden on smaller importers.

The Debate: Perspectives on the Omnibus Proposal

Arguments in Favor

Proponents of the Omnibus Proposal emphasize its benefits for business competitiveness and regulatory efficiency. They highlight the reduced administrative burden, especially for small and medium-sized enterprises (SMEs), which often struggle with complex regulations. Additionally, the changes aim to simplify compliance requirements, making it easier for businesses to adhere to regulations. By aligning with global standards, the proposal helps maintain the EU's economic competitiveness while promoting a more efficient allocation of resources across industries. Together, these factors create a more streamlined and supportive environment for businesses to thrive.​

As BusinessEurope Director General Markus J. Beyrer stated:
"Doing better with fewer and clearer norms is what European companies of all sizes are asking for. By reducing unnecessary reporting and regulatory burdens, the first Omnibus will allow companies to contribute more effectively to the EU's sustainability objectives while also preserving the EU economy's competitiveness."

European Commission President Ursula von der Leyen also expressed support for the proposal, stating:​
"EU companies will benefit from streamlined rules. This will make life easier for our businesses while ensuring we stay firmly on course toward our decarbonization goals."

Criticisms and Concerns

Critics raise significant concerns about the potential undermining of the EU's sustainability ambitions. They argue that the Omnibus Proposal may lead to unintended consequences, including reduced transparency in corporate sustainability performance, weakened supply chain accountability, and regulatory uncertainty during transition periods. Additionally, it could undermine sustainability objectives and increase the risk of greenwashing.
As Mariana Ferreira from WWF European Policy Office commented:

"The Commission's sudden urge to destroy laws that are crucial for the achievement of the EU Green Deal is a perilous approach that is forcing Europe into a time of regulatory uncertainty. Under the guise of 'simplification,' the Commission put forward a proposal that will hinder economic and business success."

Similarly, a joint statement from over 360 civil society organizations and trade unions expressed:​

"The Omnibus proposal erodes EU's corporate accountability commitments and slashes human rights and environmental protections."

While the European Parliament debates the Omnibus Proposal, the fact remains that even if the regulations are delayed or loosened, the need for risk management remains unchanged. Investors require transparency, and companies must manage supplier risk effectively.

Navigating ESG Risks with SESAMm

SESAMm’s cutting-edge AI solutions empower investors, financial institutions, and corporations to navigate the complexities of ESG compliance with confidence. Leveraging an industry-leading data lake and state-of-the-art AI, SESAMm uncovers hidden risks in supply chains and target companies, providing real-time insights that drive proactive decision-making. By transforming regulatory challenges into opportunities for responsible and sustainable growth, SESAMm helps businesses stay ahead of evolving ESG requirements while mitigating risk and enhancing transparency.

SESAMm’s AI Technology Reveals ESG Insights

Discover unparalleled insights into ESG controversies, risks, and opportunities across industries. Learn more about how SESAMm can help you analyze millions of private and public companies using AI-powered text analysis tools.

In a historic move, the agreement negotiated at COP 28, after tense negotiations, marks a significant turning point in the fight against climate change. For the first time, an international text explicitly calls for a reduction in the use of fossil fuels, symbolizing notable progress and a significant advance. However, the devil is in the details: the challenge was to reach a consensus among all participating states. The United Arab Emirates, in particular, played a key role, demonstrating its influence on the international stage by adhering to this notion of "transitioning away from fossil fuels."

NGOs and countries of the South, especially island states, would have preferred a firmer commitment towards a complete phase-out of fossil fuels. The current wording leaves room for interpretation and does not specify whether the reduction in fossil fuels should be relative or absolute.

At the heart of this climate battle lies a crucial distinction: it's not just about reducing the relative share of fossil fuels in favor of low-carbon energies but completely eliminating them. Indeed, a state can reduce the proportion of fossil fuels in its energy mix simply by increasing the use of renewables faster while continuing to increase its absolute consumption of fossil fuels, which would not solve the climate problem and could even worsen it.

It is also important to note that natural gas, despite its name, is a fossil fuel. This agreement considers it a "transition energy," part of a "just, orderly, and equitable" transition.

Beyond these semantic debates, the agreement addresses other crucial points, such as tripling renewable energy production capacities by 2030 and improving energy efficiency. It also highlights the development of nuclear energy, which, despite its drawbacks, has the significant advantage of being low-carbon.

Another notable aspect of this agreement is validating the fund for loss and damage, an idea mentioned at COP 27 in Sharm el-Sheikh. This fund, supported by the countries of the North, aims to cover the negative impacts suffered by the countries of the South. Although contributions are voluntary and potentially insufficient, they represent a step forward.

On the sidelines of the main agreement, several major powers, including the European Union, the United States, Indonesia, and Vietnam, committed to accelerating the phase-out of coal, a major source of climate pollution.

A striking fact of COP 28 is the increased presence of fossil fuel lobbyists, with 2,456 accredited representatives, four times more than the previous year. This presence is comparable to that of large national delegations and exceeds that of the countries most vulnerable to climate change.

It has been reported that the COP president, Mr. Sultan Al-Jaber, has made remarks questioning the scientific basis linking the transition away from fossil fuels to the goal of limiting global warming to 1.5°C. These comments appear to disregard the detailed findings of the IPCC reports, which provide an alternative and more alarming scientific perspective.

However, he clarified that his comments were about the challenges of transitioning away from fossil fuels while ensuring sustainable development. His stance, while acknowledging the complexities, does not directly oppose the IPCC reports' findings on the necessity of reducing fossil fuel use to mitigate climate change.

In conclusion, COP 28 stands as a landmark event in the global effort against climate change, balancing the urgency of action with the complexities of international consensus. While it pioneers in explicitly calling for fossil fuel reduction, the agreement also acknowledges the challenges of a full transition, especially from coal, particularly in the context of sustainable development. This nuanced approach, coupled with commitments to strengthen renewable energies and the loss and damage fund, reflects a pragmatic yet hopeful stride towards a more sustainable future. The presence of varied interests, including fossil fuel lobbyists, underscores the ongoing dialogue and debate that will shape our collective response to the climate crisis.