GHG accounting for small and mid-sized suppliers

Many small and mid-sized companies first meet greenhouse gas accounting through a customer questionnaire: a retailer, carmaker or bank asks for emissions figures, reduction targets or product footprints, sometimes as a condition of doing business. The good news is that the core calculation is simple, and new EU rules limit what can be demanded. This guide explains why customers ask, how a small supplier can calculate its scope 1 and 2 emissions, works through a packaging maker's first inventory, and covers the value chain cap, product footprints, scope 3 and the tools available.

By Muhammad Bilal, Chartered Accountant. Reviewed by Awais Jameel, Chartered Accountant. 4 minute read.

Short answer

GHG accounting for suppliers has become a commercial necessity: large customers ask for emissions data because their suppliers' emissions are part of their own scope 3, and companies reporting under the CSRD, the ISSB standards or California's SB 253, or setting science-based targets, need better data than spend-based estimates. For a small or mid-sized supplier, the starting point is scope 1, from fuels, vehicles and refrigerants it controls, and scope 2, from purchased electricity and heat, calculated from invoices with published emission factors, followed by an intensity figure such as tonnes per million of revenue. Where customers need it, the supplier can allocate its emissions to the products it sells them, or calculate product carbon footprints using a method such as the PACT methodology. In the EU, the voluntary standard set by Delegated Regulation 2026/1560, based on the VSME, gives a common format, and from financial years starting in 2027 the value chain cap stops CSRD reporters requiring companies with 1,000 employees or fewer to provide more than it lists. In this guide's example, a packaging maker with 80 employees calculates scope 1 and 2 emissions of 355 tonnes.

At a glance

Why customers ask
Part of their scope 3
Start with
Scope 1 and scope 2
Data from
Invoices and meters
Then
Intensity and allocation
EU format
Voluntary standard (VSME)
EU protection
Value chain cap from 2027
GHG accounting for small and mid-sized suppliersWhy customers ask: Part of their scope 3; Start with: Scope 1 and scope 2; Data from: Invoices and meters; Then: Intensity and allocation; EU format: Voluntary standard (VSME); EU protection: Value chain cap from 2027.KEY FACTS AT A GLANCEGHG accounting for small and mid-sized suppliersWhy customers askPart of their scope 3Start withScope 1 and scope 2Data fromInvoices and metersThenIntensity and allocationEU formatVoluntary standard (VSME)EU protectionValue chain cap from 2027Tax BakersGHG accounting for small and mid-sized suppliersWhy customers ask: Part of their scope 3; Start with: Scope 1 and scope 2; Data from: Invoices and meters; Then: Intensity and allocation; EU format: Voluntary standard (VSME); EU protection: Value chain cap from 2027.KEY FACTS AT A GLANCEGHG accounting for small andmid-sized suppliersWhy customers askPart of their scope 3Start withScope 1 and scope 2Data fromInvoices and metersThenIntensity and allocationEU formatVoluntary standard (VSME)EU protectionValue chain cap from 2027Tax Bakers
Key facts at a glance, as set out in this guide.

Why does GHG accounting for suppliers matter now?

A supplier's scope 1 and 2 emissions are part of its customers' scope 3, category 1, purchased goods and services. Customers reporting under the CSRD, IFRS S2 or, from 2027, SB 253's scope 3 rules, and those with science-based targets, want supplier-specific data to replace rough spend-based estimates and to track suppliers' progress. Some customers set supplier targets or prefer suppliers that report, which puts pressure on SMEs that have never measured their emissions. See scope 3 supplier-specific data.

Where should a small supplier start?

  1. Define the boundary: the sites and vehicles the company owns or controls.
  2. List scope 1 sources: gas, oil and other fuels burned on site, company vehicles, refrigerants in air conditioning and refrigeration, and any process emissions.
  3. List scope 2 sources: purchased electricity, heat, steam and cooling.
  4. Collect a year of quantities from invoices, meter readings and fuel cards.
  5. Multiply by published emission factors, such as government conversion factors, recording the source and year.
  6. Report scope 2 location-based, and market-based if the company buys renewable electricity with certificates.
  7. Calculate an intensity figure, such as tonnes per million of revenue, and keep the evidence.

See calculating scope 1 and 2 emissions.

GHG accounting for suppliers in practice: a packaging maker

A packaging maker with 80 employees and revenue of EUR 12 million calculates its first inventory, using illustrative factors.

SourceQuantityFactorTonnes CO2e
Gas for ovens and heating, scope 1400,000 kWh0.183 kg per kWh73.2
Diesel for delivery vans, scope 120,000 litres2.5 kg per litre50.0
Refrigerant top-up, scope 13 kg of R-410A2,256 per kg6.8
Electricity, scope 2 location-based900,000 kWh0.25 kg per kWh225.0
Total scope 1 and 2355.0
A packaging maker's scope 1 and 2 emissions (tonnes CO2e)A packaging maker's scope 1 and 2 emissions (tonnes CO2e)73Gas50Diesel vans7Refrigerant225ElectricityScope 1Scope 2
Electricity is the biggest source and the easiest to switch.

Electricity is 63% of the total, so a renewable electricity contract with certificates would cut market-based scope 2 sharply. The intensity is 29.6 tonnes per EUR million of revenue. Its largest customer buys 30% of output by weight, so the supplier allocates 106 tonnes to that customer, explaining the allocation basis. See location-based and market-based scope 2.

What can customers ask for?

For financial years starting on or after 1 January 2027, the CSRD's value chain cap means a reporting company may not require a company in its value chain with 1,000 employees or fewer to provide information beyond the datapoints listed in the voluntary standard, with a shorter list for companies with ten or fewer employees. The basic module of the voluntary standard, based on the VSME, covers energy use and scope 1 and 2 emissions, among other topics. The cap covers requests for CSRD reporting, not those made under other laws or by customers outside its scope, such as US companies reporting under SB 253. See the value chain cap and the voluntary standard.

When does a supplier need product footprints?

When customers want emissions per product they buy, rather than a share of the company total. The PACT methodology, from the WBCSD's Partnership for Carbon Transparency, sets rules for calculating and exchanging cradle-to-gate product carbon footprints, consistent with the GHG Protocol's product standard and ISO 14067. A simpler first step is to allocate company emissions to products by mass, units or machine hours, and explain the basis. See purchased goods and services.

Does a small supplier need scope 3?

Not to start with. The voluntary standard treats scope 3 as optional for smaller companies, and most customers ask first for scope 1 and 2. When a supplier does add scope 3, the largest categories are usually its own purchased materials and transport, which it can estimate with a spend-based method and refine later. See the spend-based method.

What tools and support are available?

Government emission factor sets, free calculators such as the SME Climate Hub's, industry association tools, and customers' supplier programmes, which sometimes fund data collection. A spreadsheet with clear sources is enough for a first inventory; what matters is consistent boundaries, documented factors and evidence that can be shown to customers or an assurance provider. See building a GHG inventory.

Need help applying the standards?

Our Chartered Accountants help finance teams and students apply IFRS and US GAAP to real transactions.

Questions people ask

Why do customers ask suppliers for emissions data?

Because suppliers' emissions are part of the customer's scope 3, and reporting rules and targets require better data than spend-based estimates.

What should a small supplier calculate first?

Scope 1 emissions from fuels, vehicles and refrigerants it controls, and scope 2 emissions from purchased electricity and heat, from invoices and published factors.

Can CSRD customers demand any data from small suppliers?

From financial years starting in 2027, not beyond the datapoints listed in the EU voluntary standard for companies with 1,000 employees or fewer.

Does a small supplier need scope 3 emissions?

Usually not at first. Most customers ask for scope 1 and 2, and the voluntary standard treats scope 3 as optional.

Sources

Every fee, date and rule on this page was taken from these official and primary sources.

  1. Commission Delegated Regulation (EU) 2026/1560 establishing sustainability reporting standards for voluntary use
  2. Garrigues: EU publishes voluntary sustainability standard and caps value chain reporting requirements, September 2026
  3. GHG Protocol Corporate Accounting and Reporting Standard
  4. GHG Protocol Scope 2 Guidance
  5. WBCSD: PACT Methodology Version 3 for calculating and exchanging cradle-to-gate product carbon footprints
  6. US EPA: GHG Emission Factors Hub
  7. UK Department for Energy Security and Net Zero: greenhouse gas reporting conversion factors 2026
  8. IPCC Sixth Assessment Report, Working Group I, chapter 7, including global warming potentials

Rules and fees change. If you are reading this long after October 12, 2026, confirm the figures with the source before you rely on them.

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This guide is general information. It is not tax or legal advice for your situation.