6.6 Addressing Double Counting of Scope 3 Emissions
Scope 3 Standard, Chapter 9, “Setting a GHG Reduction Target
and Tracking Emissions Over Time,” Page 108
9.6 Addressing Double Counting of Scope 3 Reductions Among
Multiple Entities in a Value Chain . . .
Double counting within scope 3 occurs when two entities in
the same value chain account for the scope 3 emissions from
a single emissions source — for example, if a manufacturer
and a retailer both account for the scope 3 emissions
resulting from the third-party transportation of goods
between them . . . . This type of double counting is an
inherent part of scope 3 accounting. Each entity in the
value chain has some degree of influence over emissions and
reductions. Scope 3 accounting facilitates the simultaneous
action of multiple entities to reduce emissions throughout
society. Because of this type of double counting, scope 3
emissions should not be aggregated across companies to
determine total emissions in a given region. Note that while
a single emission may be accounted for by more than one
company as scope 3, in certain cases the emission is
accounted for by each company in a different scope 3
category.
Companies may find double counting within scope 3 to be
acceptable for purposes of reporting scope 3 emissions to
stakeholders, driving reductions in value chain emissions,
and tracking progress toward a scope 3 reduction target. To
ensure transparency and avoid misinterpretation of data,
companies should acknowledge any potential double counting
of reductions or credits when making claims about scope 3
reductions. For example, a company may claim that it is
working jointly with partners to reduce emissions, rather
than taking exclusive credit for scope 3 reductions.
If GHG reductions take on a monetary value or receive credit
in a GHG reduction program, companies should avoid double
counting of credits from such reductions. To avoid double
crediting, companies should specify exclusive ownership of
reductions through contractual agreements.
Double counting of GHG emissions (also referred to as double
claiming with respect to credits or reductions) occurs when two or more reporting
companies in the same value chain report the same GHG emissions in the same scope.
The inherent risk of double counting emissions is most prevalent for Scope 3
emissions, since the Corporate Standard defines Scope 1 and Scope 2 emissions in
such a way as to ensure that (1) GHG emissions are reported in Scope 1 only by the
company that directly generated them and (2) GHG emissions resulting from the
generation of energy in the form of electricity, heating, cooling, or steam are
reported in Scope 2 only by the company that consumed that energy. In contrast to
Scope 1 and Scope 2 classifications, the classification of a given set of GHG
emissions within Scope 3 is not exclusive to one company in the value chain (i.e.,
the same GHG emissions would necessarily be reported in Scope 3 by multiple
companies in the value chain). GHG emissions classified by one reporting company
within Scope 1 or Scope 2 would be classified within Scope 3 by other reporting
companies in the value chain.
Example 6-10
Company A, a clothing manufacturer, sells its goods to
Company B, a clothing retailer. Company B pays Company C, a
third-party transportation company, to move the clothing
from A’s manufacturing facility to B’s retail facility.
The three companies account for the GHG emissions related to
C’s transportation of the clothing from A’s manufacturing
facility to B’s retail facility as follows:
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Company A accounts for the emissions in Scope 3, Category 9 (downstream transportation and distribution).
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Company B accounts for the emissions in Scope 3, Category 4 (upstream transportation and distribution).
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Company C accounts for the emissions in Scopes 1 and 2.
Double counting of Scope 3 emissions is an inherent part of Scope 3 reporting, since
each company in a given value chain has some degree of influence over the same GHG
emissions. In light of this, it is important for companies to consider the
following:
-
The Scope 3 Standard warns against aggregating Scope 3 emissions across companies to determine total GHG emissions in a given value chain.
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As noted in the Scope 3 Standard, “[c]ompanies may find double counting within scope 3 to be acceptable for purposes of reporting scope 3 emissions to stakeholders, driving reductions in value chain emissions, and tracking progress toward a scope 3 reduction target.” This is because the reporting of Scope 3 emissions in a value chain reflects the belief that companies may be able to influence the decisions made and emissions generated upstream and downstream of their operations through engagement with suppliers, customers, and other stakeholders. However, the Scope 3 Standard advises companies to disclose in their GHG reports any potential double counting when claiming Scope 3 emission reductions “[t]o ensure transparency and avoid misinterpretation of data.” In addition, when such emission reductions have monetary value or are worth credits in a GHG reduction program, the Scope 3 Standard recommends that a single company take exclusive ownership of the reductions by contractual agreement to avoid double counting.