Scope 3 Accounting and Reporting Standard - Comment Template - Asahi Glass Co., Ltd. Public Comment

Sep 12, 2026

This comment template supports stakeholder feedback on the Scope 3 Accounting and Reporting Standard. It defines submission timing (November 11, 2009 to December 21, 2009), instructs submitters to organize remarks by chapter or section with page and line references, and specifies delivery via a single MS Word attachment by email. The Asahi Glass Co., Ltd. feedback addresses boundary-setting, prioritization of relevant emissions, data collection feasibility, allocation of emissions, assurance expectations, and reporting frequency to reduce reporting burden.

LanguageEnglish

CategoryLetters

FormatPDF

Pages3

Reading Time1 min

AccessFree to download

Comment Template

Public comment submission instructions

Asahi Glass Co., Ltd. feedback by section

Introduction

Accounting & Reporting Principles

Business Goals & Inventory Design

Mapping the Value Chain

Setting the Boundary

Prioritizing Relevant Emissions

Collecting Data

Allocating Emissions

Assurance

Reporting and Communication

Purchased Goods and Services (Tier 1)

Purchased Goods and Services (Cradle-to-Gate)

Energy-related activities not included in scope 2

Capital equipment

Transportation & Distribution (upstream)

Business travel

Waste generated in operations

Franchises and leased assets (upstream)

Investments

Downstream categories

Use of sold products

Disposal of sold products at end of life

Employee commuting

Glossary and additional comments

World Business Council for Sustainable Development The Greenhouse Gas Protocol Scope 3 Accounting and Reporting Standard Comment Template We are providing this template to streamline public comment submissions. To use this template, please follow the instructions below: This Scope 3 draft is open for stakeholder comment from November 11, 2009 through December 21, 2009. To provide written comments, please use the comment template provided, instead of sending comments in a separate file or e-mail, in order to streamline the comment process. When using the comment template, please organize comments by chapter/section and reference page numbers and line numbers. If you have questions during the public comment process, please email Holly Lahd at[hlahd@wri.org](hlahd@wri.org). Submit comments as an attached MS Word file by email to Holly Lahd at [hlahd@wri.org](hlahd@wri.org) no later than Monday, December 21st, 2009. We appreciate any effort to submit written comments before the deadline. Feedback from (name): Hiroo TAKAHASHI Organization: Senior Manager, Corporate Planning, Asahi Glass Co., Ltd. | Chapter/Section | Comments | | --- | --- | | The outline and overall structure of the document | | | Part 1 | | | 1. Introduction | | | 2. Accounting & Reporting Principles | | | 3. Business Goals & Inventory Design | | | 4. Mapping the Value Chain | | | 5. Setting the Boundary | In general, we propose that the data requirements for upstream and downstream value chain entities are to be pragmatically considered. In such a sense, segment-by-segment model calculation approach should be | | | considered. The reason is that it is difficult to get data from our customers.
Also, our suppliers should find the data requirements from us troublesome and difficult if too much upstream data is required.
[Page 18 line 11 together with Page 10 lines 7&8] While Section 1.11 says “at least 80% of total anticipated scope 3 emissions”, Section 5. 1, says“Companies shall account for and report all relevant scope 3 emissions of the reporting company”. If 100% coverage is required, it causes too heavy burden, thus, avoidance from using the protocol will be resulted. Accordingly, we propose that GHG protocol gives the allowance of the reporting entity for the reporting boundary. | | --- | --- | | 5.1 Prioritizing Relevant Emissions | | | 5.2 Prioritizing Relevant Emissions Based on Size | | | 5.3 Prioritizing Relevant Emissions Based on Other Criteria | | | 6. Collecting Data | | | 6.1. Prioritizing Activities | | | 6.2. Assessing
Data Sources | | | 6.3. Collecting data | | | 7. Allocating Emissions | | | 12. Assurance | | | 13. Reporting and Communication | [Page 47 line 13 and Page 49 line 2]] While the current draft GHG Protocol does not specify the reporting frequency, Figure 13.1 (Illustrative Reporting Form” assumes annual reporting, which is a heavy burden to the reporting entity. We propose that GHG protocol allow the reporting entities to use the previously reported data if no material change occurs. | | Part 2 | | | 1. Purchased Goods and Services-Direct (Tier 1) Supplier Emissions | | | 2. Purchased Goods and Services – Cradle-toGate Emissions | | | 3. Energy-Related Activities Not Included in scope 2 | | | 4. Capital Equipment | | | 5. Transportation & Distribution (upstream/inbound) | | | 6. Business Travel | | | --- | --- | | 7. Waste Generated in Operations | | | 8. Franchises Not Included in Scope 1 and 2 (Upstream) | | | 9. Leased Assets Not Included in Scope 1 and 2 (Upstream) | | | 10. Investments Not Included in Scope 1 and 2 | | | 11. Franchises (Downstream) | | | 12. Leased Assets (Downstream) | | | 13. Transportation & Distribution (Downstream/ Outbound) | | | 14. Use of Sold Products | [Page 83 line 2 Chart Product Type 4] To avoid ambiguity in the interpretation, we propose that GHG Protocol lists up the target industrial gases.
[Page 85 line 12 Chart Product Type 4] We propose

FAQs

What is the submission deadline for stakeholder comments on the Scope 3 draft?

The template states that the draft is open for comment from November 11, 2009 through December 21, 2009.

How should comments be formatted when using the template?

Comments should be organized by chapter or section and must reference page numbers and line numbers.

Where and how should written comments be submitted?

Submit comments as an attached MS Word file by email to Holly Lahd, no later than Monday, December 21, 2009.

Sep 12, 2026

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