JBS Stopped Affirming Net Zero by 2040 to the SEC Before Its Report Dropped It

JBS published its 2025 sustainability report on July 8, 2026, and the coverage focused on what the document leaves out: the 2040 net-zero goal, any target for Scope 3 emissions, and the deforestation deadlines the company set in 2021. That reading is correct. It is also fifteen weeks late.

JBS had already stopped affirming the 2040 ambition in the filing that matters more. On March 25, 2025, JBS S.A. told the Securities and Exchange Commission, in its annual report on Form 20-F, that “our climate ambitions are currently steadfast.” The next sentence read: “Our ambition to set near-term science-based targets in line with our Net Zero by 2040 ambition has not changed.” One year later, on March 25, 2026, JBS N.V. filed its own 20-F. The word “steadfast” does not appear anywhere in that document, and neither does the sentence about the 2040 ambition. The section where both used to sit, “Climate Change Reduction Goals,” now describes a framework “built on near-term, verifiable reductions.” The 2040 goal survives only in the past tense, in a risk factor that recalls “In 2021, we shared our ambition,” and in the legal-proceedings disclosures about what two state attorneys general did about it.

A sustainability report is a marketing document with footnotes. A 20-F is signed under federal securities law. By our reading, the order in which the language left each one says something about which audience the company was managing.

Key findings

• JBS announced on March 23, 2021 a “commitment to achieve net-zero greenhouse gas (GHG) emissions by 2040” across its operations and value chain, which it billed as a first for the global meat and poultry sector.
• Its FY2024 Form 20-F, filed March 25, 2025, said its Net Zero by 2040 ambition “has not changed.”
• Its FY2025 Form 20-F, filed March 25, 2026, rewrote that section around a framework “built on near-term, verifiable reductions.” The 2040 goal now appears only as history and in the litigation disclosures.
• The 2025 sustainability report, published July 8, 2026, sets emissions targets for Scope 1 and Scope 2 only: a 30 percent intensity cut by 2030 and 70 percent across processing facilities by 2050, both against 2019.
• No current target covers Scope 3, which the report puts at 185.8 million tonnes of CO2 equivalent for 2025, more than 97 percent of the company’s reported footprint.
• The 2021 deforestation deadlines for the Amazon, other Brazilian biomes and the global supply chain do not appear. The report describes efforts “to mitigate deforestation risks.”
• In a settlement announced November 3, 2025, JBS USA agreed to pay $1.1 million and to describe Net Zero by 2040 to US consumers as a “goal” rather than a “pledge” or a “commitment.”
• The New York attorney general found that in 2021 JBS USA “had not developed a detailed plan” and had not assessed whether the commitment “was economically or technologically feasible by 2040.” JBS USA neither admitted nor denied the findings.

What the 2021 announcement actually promised

The March 2021 press release is still online. It describes a commitment that “spans the company’s global operations, including Pilgrim’s Pride Corporation (Nasdaq: PPC), as well as its diverse value chain of agricultural producer partners, suppliers and customers.” The New York attorney general’s findings later spelled out what the value chain meant: Scope 3 emissions, “including from its direct and indirect suppliers that raise the animals it slaughters.” CEO Gilberto Tomazoni framed it as urgent: “Agriculture can and must be part of the global climate solution.”

It was specific about money and method: more than US$1 billion in incremental capital expenditure over the decade, US$100 million by 2030 for research into regenerative farming and on-farm emission mitigation, and a “time-bound roadmap that provides interim targets” consistent with Science Based Targets initiative criteria for a 1.5 degree trajectory. It also set the facility goal that survives today: Scope 1 and 2 emission intensity down at least 30 percent by 2030 against 2019.

It was specific about forests too. Illegal Amazon deforestation eliminated from the supply chain, “including the suppliers of its suppliers,” by 2025. Illegal deforestation eliminated in other Brazilian biomes by 2030. Zero deforestation across the global supply chain by 2035.

What the current report says instead

JBS announced its 2025 report on July 8, 2026. The targets it names: Scope 1 and 2 emissions intensity down 30 percent by 2030 and 70 percent across processing facilities by 2050, both against a 2019 baseline, and 60 percent renewable electricity globally by 2030. The report says JBS cut its Scope 1 and 2 intensity 18.8 percent from 2019 and Pilgrim’s Pride cut its own 24.4 percent, both ahead of the interim targets in their sustainability-linked bond frameworks. It reports nearly US$200 million invested in Scope 1 and 2 projects since 2020, and renewables supplying 31.3 percent of global energy use in 2025.

That last figure was 38.1 percent in 2024. And the report’s electricity table puts renewable electricity at 5.5 percent of consumption in 2025, down from 11.5 percent the year before. The 2030 target is 60 percent.

The company’s own announcement shows the pattern. Net zero does not appear. Scope 3 does not appear. Deforestation appears as a risk to be mitigated rather than a practice to be eliminated by a date.

Jason Weller, global chief sustainability officer, gave the reasoning in a blog post JBS published alongside the report. “The further we got into execution,” he wrote, “the clearer it became that a Net Zero goal spanning hundreds of thousands of independent agricultural producers across tens of millions of hectares in dozens of countries” was “an immense challenge,” given producers with “different practices, different baselines, and no standardized measurement infrastructure.” He wrote that JBS is now “sharpening its climate goals around the portion of our footprint where we have the clearest responsibility and the strongest ability to drive measurable progress: our operations.”

Both statements are defensible on their face. Measuring enteric methane across a supply chain that size is genuinely hard, and a target that cannot be verified is worth little. The difficulty, by our reading, is that those facts had not changed between 2021 and 2026. The producers were already independent, the hectares already numerous, the measurement infrastructure already missing. JBS’s own 2022 sustainability report, as quoted in the attorney general’s findings, described a company that relies on “hundreds of thousands of farmers worldwide who produce food from hundreds of millions of acres of crop, pasture, and range lands.”

What the New York attorney general found

The attorney general sued in February 2024 under New York’s consumer protection and false advertising statutes. The court dismissed that complaint without prejudice in January 2025. The attorney general then subpoenaed JBS USA, received eight document productions, and resolved the matter with an Assurance of Discontinuance instead of an amended complaint, announcing the settlement on November 3, 2025.

Paragraph 16 is the load-bearing one: “At the time it announced its ‘Net Zero by 2040’ commitment, JBS USA Food had not developed a detailed plan setting forth the steps to be taken between March 2021 and 2040 to achieve net zero emissions by 2040, nor had it assessed whether such a commitment was economically or technologically feasible by 2040.”

Other findings fill in the timeline. In October 2020, months before the announcement, JBS answered a climate disclosure questionnaire by reporting that Scope 3 emissions from the livestock it purchases were “relevant, not yet calculated,” and that “JBS [had] not yet found a consensus about [an] efficient and feasible methodology to calculate.” The Better Business Bureau’s National Advertising Division found in late 2023 that “the evidence did not support the broad message conveyed by the challenged advertising that JBS is on a path towards net zero.” Its appellate body upheld that. In January 2024, after the Science Based Targets initiative refused to extend a January 31 deadline, JBS USA withdrew from the SBTi application process. And the 2023 sustainability report, issued in August 2024, said JBS “may not be able to achieve net zero by 2040.”

JBS USA neither admitted nor denied any of it. The $1.1 million went to Cornell University’s New York Soil Health and Resiliency Program rather than to the state, and Cornell says it received the money on January 16, 2026. The settlement states that the payment “is not a civil penalty or fine.”

The equitable relief has a detail worth sitting with. JBS USA agreed to present Net Zero by 2040 to US consumers “as a ‘goal’ as opposed to a ‘pledge’ or a ‘commitment.’” The word was regulated down first. The goal itself came out of the sustainability report about eight months later.

New York was not the only state asking. The FY2025 20-F discloses that on August 13, 2025, the Vermont attorney general issued a demand to JBS USA “related to the VTAG’s investigation of JBS USA Food Company’s net zero sustainability representations in the amount of US$1.6 million.” According to the filing, JBS USA “has defended its representations in a written response to the demand,” and the company continues to cooperate with the investigation.

The Scope 3 problem, in numbers

The category JBS stopped targeting is the category that matters. The report puts 2025 Scope 3 emissions at 185.8 million tonnes of CO2 equivalent, out of a reported total of 191.1 million. In 2023 the figures were 151.5 million and 156.7 million. That is a rise of about 23 percent in Scope 3 and 22 percent overall, and Scope 3 is more than 97 percent of the whole. One category, purchased goods and services, which covers the animals and feed JBS buys, accounts for 171.1 million tonnes on its own, before any land-use change.

The report does publish the number, and that deserves credit: disclosure without a target beats neither. It is also the weaker half, and the report’s own table shows how intermittent it has been. Scope 3 is marked “n/c,” not calculated, for both 2019 and 2024. By our reading, a published number with no reduction commitment attached to it creates no budget line, no executive incentive and no contractual consequence.

That last point is not hypothetical here. According to the attorney general’s findings, JBS USA and Pilgrim’s Pride issued three $1 billion sustainability-linked bonds in March, June and November 2021, each tying the interest rate to Scope 1 and 2 emissions intensity. The FY2025 20-F spells out the mechanism: miss the target and verification window, and the coupon steps up 25 basis points through maturity. JBS and Pilgrim’s met their 2025 interim targets. The third bond rests on JBS USA cutting its intensity 20.3 percent by December 31, 2026, and the 2025 report lists that one as “In Progress” at 3.369 percent. Scope 1 and 2 survived the retreat. Those are the emissions with money attached to them.

The WokeCorp assessment

The commitment was real in form and thin in substance from the start. JBS put a date, a dollar figure and a validation framework behind it in 2021. The attorney general’s finding that no detailed plan or feasibility assessment existed at the time is one JBS USA neither admitted nor denied.

Withdrawing a voluntary target is lawful, and nothing here says otherwise. No rule required JBS to set a 2040 goal and none requires it to keep one. What is left to judge is the gap between the statement and the follow-through.

The sequencing is the finding. The sentence saying the 2040 ambition “has not changed” left the SEC filing in March 2026. The goal left the sustainability report in July 2026. In our reading, the investor-facing document moved about fifteen weeks before the customer-facing one did.

What remains is the part with a contract behind it. The targets that stayed are the ones bondholders can charge 25 basis points for missing. The Scope 3 goal that went never had a comparable penalty attached. We read that as the clearest guide to which climate numbers JBS treats as binding.

Related reading

• Net Zero Theater, the broader pattern of corporate climate targets set without an implementation path
• SEC Climate Disclosure Rule Abandoned, the reporting requirement that would have made Scope 3 figures mandatory rather than voluntary
• The Cocoa Industry’s Broken Harkin-Engel Promise, a supply chain commitment with a comparable record on deadlines
• Certification Theater: Fairtrade and Rainforest Alliance, what third-party verification does and does not establish
• Greenhushing: The South Pole Survey, on companies that keep the targets and stop talking about them

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Sources

• “JBS Makes Global Commitment to Achieve Net-Zero Greenhouse Gas Emissions by 2040,” JBS press release, March 23, 2021. Verified 2026-10-09.
• JBS S.A., Form 20-F for fiscal year ended December 31, 2024, filed March 25, 2025. Verified 2026-10-09.
• JBS N.V., Form 20-F for fiscal year ended December 31, 2025, filed March 25, 2026. Verified 2026-10-09.
• “JBS Publishes 2025 Sustainability Report,” JBS press release, July 8, 2026. Verified 2026-10-09.
• Jason Weller, “Turning Sustainability Ambition into Operational Progress,” JBS, July 8, 2026. Verified 2026-10-09.
• JBS, Non-Financial Disclosure Report 2025. Verified 2026-10-09.
• People of the State of New York v. JBS USA Food Company, Assurance of Discontinuance No. 25-067, Office of the New York Attorney General. Verified 2026-10-09.
• “Attorney General James Secures $1.1 Million for Climate-Smart Agriculture from World’s Largest Beef Producer,” Office of the New York Attorney General, November 3, 2025. Verified 2026-10-09.
• “$1.1M from NY attorney general to promote climate-smart ag,” Cornell Chronicle, February 2026. Verified 2026-10-09.
• ESG Dive, “JBS axes 2040 net-zero goal, citing ‘immense’ execution challenges.” Press coverage of the report. Verified 2026-10-09.
• Mongabay, “Meat giant JBS silently ditches bolder environmental targets in latest review.” Press coverage of the report. Verified 2026-10-09.