Climate Policy Engagement Analysis
Climate Policy Engagement Overview: 3M appears to have active engagement with climate policy. The company’s top-line messaging on climate change policy and the energy transition is predominantly positive. However, the company retains memberships to several industry associations which are negatively engaged on climate policy.
Top-line Messaging on Climate Policy: 3M has stated top-line support for emissions reductions in line with a 1.5°C target in its GHG 2023 Global Impact Report, published in March 2023. However, 3M’s 2023 Global Impact Report also appears to promote a market-based response to climate change over government regulation, stating that “3M endorses voluntary approaches to GHG emissions management.”
Engagement with Climate-Related Regulations: 3M appears to have limited, positive engagement with climate-related policy in 2021-23. The Atlantic reported in October 2021 that 3M had endorsed a national clean-electricity standard in the context of Build Back Better negotiations, a position which 3M stated again in its 2023 CDP Disclosure . 3M’s 2023 CDP response also suggested support for minimum energy efficiency requirements in the U.S.
Positioning on Energy Transition: 3M has limited and mixed engagement with energy transition related legislation, taking primarily positive positions in 2021-22 but appearing to take negative positions in 2023. 3M stated general support for the decarbonization of energy systems in the EU and the US, in a joint letter from April 2021. However, in an industry letter from May 2023, the company seemed to advocate for weaker implementation guidelines for the Inflation Reduction Act's hydrogen tax credit, suggesting the proposed additionality criteria would be overly restrictive and risked resulting in “economic and job loss”.
Industry Association Governance: 3M discloses a list of its memberships in industry associations on its corporate website without disclosing their climate policy positions, its role within each association, or any attempts to influence the groups’ positions. In its 2023 CDP response, 3M did not disclose its membership to any industry associations. 3M has not published a review of its alignment with its industry associations. 3M is a direct member of the US Chamber of Commerce and National Association of Manufacturers, which are actively and negatively engaged with US climate policy. 3M’s CEO, Mike Roman, is also a member of the Business Roundtable which engages with a mix of both positive and negative positions on U.S. climate policy.