The Greenhouse Gas Protocol - Scope 3 Accounting and Reporting Standard - Comment Template

Sep 11, 2026

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Template and submission instructions for public stakeholder comments on the Greenhouse Gas Protocol Scope 3 Accounting and Reporting Standard draft, covering the comment window and how to submit feedback. Guidance requires organizing comments by chapter or section and referencing page and line numbers. The provided excerpts include detailed critique on inventory approach, value chain mapping, upstream and downstream categorization, boundary and reporting requirements, and the implications of estimating scope 3 emissions for materiality decisions.

LanguageEnglish

CategoryLetters

FormatPDF

Pages6

Reading Time2 min

AccessFree to download

Introduction

Mapping the Value Chain

Setting the Boundary

Collecting Data

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): Corinne Reich-Weiser ([corinne@climateearth.com](corinne@climateearth.com)) Organization: Climate Earth 1. Introduction Page 9, Lines 14-15 “For companies implementing both standards, a product level inventory will inform and support the development of a corporate-wide scope 3 inventory. ( To be developed further)” We believe a top-down approach should be recommended. Starting with a corporate inventory to inform the product inventories is superior from both a technical and business perspective because it rapidly informs and supports a product level inventory using materiality as a guide. Product level analysis “in the blind” should not be recommended. 4. Mapping the Value Chain Page 14, Lines 5-7 “The purpose of mapping of the value chain is to identify the full range of possible scope 3 activities before a company determines which are most relevant and should be included in the scope 3 inventory.” A screening assessment should inform a process map and boundary assessment. One cannot draw a process map with hundreds of inputs without first deciding what is important. Page 14, Line 14 “…All scope 3…” “All scope 3 emissions sources” can be estimated , but are impossible to draw on a process flow diagram – supply chains are infinite and each level has hundreds to thousands of inputs. Additional guidance is needed here. Page 14, Lines 25-26 “The distinction between the two categories is based on the financial transactions of the company.” The use of financial transactions to distinguish upstream and downstream scope 3 is excellent. This is a very clear and clean way to understand the emissions categorization. 5. Setting the Boundary Page 18, Lines 27-28, Lines 46-47 “Companies shall report emissions for each scope 3 category determined to be relevant. Companies may additionally report emissions for other scope 3 categories. “ If all scope 3 emissions should be estimated and rolled up to determine which are most important, then all of these estimates should also be reported. Lines 27-28 should be changed to reflect that all emissions estimates need to be reported. Page 18, Lines 46-47 “Initial estimates should be conducted for each individual scope 3 category and rolled up to obtain an estimate of total anticipated scope 3 emissions.” In line with comment above, we propose “should be” changed to “shall be”: “Initial estimates shall be conducted for each individual scope 3 category and rolled up to obtain an estimate of total anticipated scope 3 emissions”. Page 19, Lines 7-8 “Companies shall account for and report the largest scope 3 sources that collectively account for at least 80% of total anticipated scope 3 emissions.” In order to verify that reported emissions are over 80% of scope 3 emissions, an estimate of all scope 3 emissions is necessary. Requiring 100% will create more consistent reporting across all companies and will discourage “cher

FAQs

What time period was the Scope 3 draft open for public comments?

The draft was open for stakeholder comment from November 11, 2009 through December 21, 2009.

How should comments be structured in the template?

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

Where do reviewers provide feedback on reporting boundaries and emission coverage?

Feedback discusses requirements for reporting emissions by relevant scope 3 categories, rolling up initial category estimates, and the need to report emissions comprehensively to support consistent scope 3 determination.

Sep 11, 2026

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