SystemCorporate Strategy & ESG

The complete guide · November 2026

Supplier Scope 3 emissions, explained.

Most of a drug maker's climate footprint comes from what it buys: active ingredients, solvents, glass, packaging, contract manufacturing. Much of that number is still an estimate, often worked out from money spent. This work replaces the estimate with what suppliers report, after checking that what they report holds up.

This guide is for anyone who owns, builds, audits or feeds that number: heads of sustainability, ESG reporting managers, procurement category managers, supplier engagement leads, assurance teams, and leaders deciding whether to automate the work. No background needed.

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A quick example · fictional

Imagine you are the Head of Sustainability at Veltara Therapeutics, a drug maker closing its yearly carbon figures. Your auditors arrive in two weeks. One Monday morning in October, a supplier in India, Kestrel Fine Chemicals, sends a product carbon footprint, its own calculation of the emissions behind each kilogram it makes. The product is VT-114, the key intermediate of your oral cancer medicine: a chemical made partway to the finished drug. You bought 17.1 tonnes of it last year for €38.6 million.

Your emissions tally has that purchase at 410 kg of CO2e (carbon dioxide equivalent, the common unit for greenhouse gases) per kg, because that is what the money implies. Kestrel's page 2 says 182. Same chemical, same year.

Worked out from spend
Per kg
410 kg CO2e
On 17.1 t
7,011 t
Supplier's footprint, page 2
Per kg
182 kg CO2e
On 17.1 t
3,112 t
3,900 tonnes lower on paperFiled as a method changeThe air saw no change from this swap.

Careful work checks what the 182 covers, which year it describes, how it was split among products and whether it fits the chemistry. Then it catches the trap: those 3,900 tonnes are a change in the calculation, and calling them a reduction would be wrong.

Supplier Scope 3 emissions management guide
Part A · Understand it

Supplier Scope 3 in pharma: the calculation methods, the 2026 rules, the footprints suppliers send and the people who check them

What Scope 3 is, why so much of it is an estimate, how a product carbon footprint is read, what you may and may not demand of a supplier after the 2026 changes, and how to keep a change in method apart from a real cut. If you are new to carbon accounting, start here.

01 · In plain words

What supplier Scope 3 data collection is: replacing an estimate of what you buy with what your suppliers measured

A company's climate footprint comes in three parts, called scopes. Scope 1 is what it burns itself, such as gas in its boilers. Scope 2 is the power it buys. Scope 3 is everything else its business causes, upstream and downstream: the making of what it buys, freight, business travel, and what happens to its products after sale. The yearly tally of all three is called an emissions inventory. For public drug and biotech companies, Scope 3 in 2023 was 5.4 times Scopes 1 and 2 combined, "primarily driven by purchased goods and services".1

Nobody can meter a supplier's plant from the outside, so many companies start with money. They take what they spent with a supplier, multiply it by an average emissions figure for that kind of industry, and call the answer emissions. This is a spend estimate. It is quick and it covers everything. It also knows nothing about the supplier. A plant that moves to solar power looks the same as one that does not. A supplier that raises its price looks dirtier the next year.

The better source is the supplier. Some send a product carbon footprint, a figure for one kilogram of one product. Some send company totals through a disclosure system such as CDP, a nonprofit platform for environmental reporting, or fill in a questionnaire. Smaller ones may send a short voluntary report. Each arrives in its own format, for its own year, with its own assumptions. Somebody has to read each one, match it to what was bought, decide whether it holds up, and only then put it in place of the estimate.

That somebody is often a small team, with hundreds of suppliers and a reporting deadline. And the job has a trap in it. When a supplier's figure replaces an estimate, your reported number often falls. The atmosphere has not changed. Calling that fall a reduction is the fastest way to lose an auditor's trust, so the good teams record it as what it is: a method change.

For public drug and biotech companies, Scope 3 outweighs Scopes 1 and 2 by 5.4 to 1

Emissions as a multiple of Scopes 1 and 2 combined, 2023

Scope 35.4 ×
Scopes 1 and 2 combined1 ×

Source 1

Show the numbers
ScopeValue
Scope 35.4 ×
Scopes 1 and 2 combined1 ×

The yearly supplier data cycle in five steps, from request to signed figure

  1. Screen and rankEstimate all categories, find where the tonnes sit, and pick the suppliers that matter. In the example, 240 of 1,860 suppliers cover 82% of purchased goods spend.
  2. AskSend the climate data request in July, through a disclosure system, a questionnaire or a data exchange.
  3. Read, check and swap inRead each submission, match it to the purchase line, test it, and replace the estimate only where it holds up. Ask a precise question where it does not. This step is what this guide is about.
  4. Separate and write upSplit what changed into real change and method change, and write the method notes behind each figure.
  5. Sign and defendThe head of sustainability approves the figures, and the assurance provider, an outside auditor of these figures, samples them and asks for method and source.

The people, companies and figures in this example are fictional.

Four surprises in Scope 3 supplier engagement, starting with data worse than an average

A supplier's figure can be the weaker one

The Greenhouse Gas (GHG) Protocol, the carbon accounting standard this work follows, warns that "data collected from a supplier may actually be less accurate than industry-average data for a particular product", especially after allocation.2 That warning is why the checking matters as much as the collecting.

The industry code can swing the estimate 29 times

In the US factor set behind many spend estimates, a dollar of "pharmaceutical preparation" carries 0.044 kg of CO2e and a dollar of "other basic organic chemical" carries 1.277.3 Which code an intermediate gets is a choice someone made.

The percentage everyone chased is leaving the EU standard

ESRS E1, the climate part of the EU's sustainability reporting standards, asks for "the percentage of emissions calculated using primary data". The simplified standards, which apply from financial year 2027, no longer carry those words.4,5 The GHG Protocol still requires a share per category.6,7

You may no longer be able to demand a footprint

From 2027, a supplier with up to 1,000 employees can decline requests made for the CSRD, the EU's corporate sustainability reporting law, beyond a short list of datapoints, and no product's footprint is on that list.8,9 Requests made for other reasons sit outside that limit, so the same supplier may hear two different things.

Scope 3, product carbon footprint, cradle-to-gate, method change: the vocabulary of supplier carbon data

Scope 3

Indirect emissions outside purchased energy, in 15 categories. Category 1 is purchased goods and services.

Product carbon footprint

The emissions behind one unit of one product, often shortened to PCF. In this work the unit is usually one kilogram.

Cradle-to-gate

From raw materials to the moment the product leaves the supplier's site. Use and disposal are left out.

Method change

A reported number moved because you calculated it differently. The emissions themselves did not move.

Fourteen terms are defined in the one-page summary. Tonne (t) means a metric ton, the unit carbon accounts use, and CO2e means carbon dioxide equivalent.

02 · Four calculation methods

Spend-based vs supplier-specific emissions, with hybrid and average-data between them: four ways to count one purchase, and why a dollar is a weak measure

In shortThe GHG Protocol names four methods for purchased goods. They differ in what you know: the supplier's product, the supplier's company, the material, or only the money. Most companies mix them, and the mix is what a reader wants to see. A spend estimate is a fair place to start and a poor place to stay, because it moves with price and with the industry code someone picked.

The GHG Protocol's guidance sets out the four methods for Category 1.2 The supplier-specific method takes a cradle-to-gate product inventory from the supplier. The hybrid method uses what the supplier knows and fills the gaps with secondary data, meaning published or database averages. The average-data method multiplies the mass you bought by an industry-average factor. The spend-based method multiplies money by a factor per unit of money. Sphera's 2025 survey of 315 sustainability professionals found 65% of companies combining these approaches, and 15% relying on spend alone, down from 30% in 2024.10

MethodWhat you multiplyWhat it can showWhat it cannot show
Supplier-specificKilograms bought × the supplier's footprint per kilogramA real change at that plant, on that productAnything, if the footprint's boundary or allocation is wrong
HybridThe supplier's own Scopes 1 and 2, allocated to your purchases, plus secondary data for its inputsRenewable power or efficiency at the supplierWhich product carries the emissions at a diversified supplier
Average-dataKilograms bought × a life-cycle database factor for the materialBuying less, or switching materialOne supplier against another
Spend-basedMoney spent × an input-output factor for the industryWhere to look firstAny supplier's action. It rises when prices rise
Relying on spend alone halved in a year

Respondents relying solely on spend-based methods

30%2024 survey
15%2025 survey

Source 10

Show the numbers
PeriodValue
2024 survey30%
2025 survey15%

The same dollar across a drug maker's purchases: how far spend factors sit apart

Spend factors come from input-output tables, which divide a whole economy into industries. The set that many US companies use publishes its factors by industry code. Here is what one 2024 dollar carries in its "without margins" column, for things a drug maker buys.3

A dollar of organic chemicals carries 29 times the carbon of a dollar of finished medicine

Supply chain emission factors without margins, kg CO2e per 2024 US dollar, version 1.4.0

All other basic organic chemicalNAICS 3251991.28 kg
Plastics packaging film and sheetNAICS 3261120.483 kg
Glass containerNAICS 3272130.441 kg
Folding paperboard boxNAICS 3222120.432 kg
Medicinal and botanicalNAICS 3254110.139 kg
Biological productNAICS 3254140.121 kg
Pharmaceutical preparationNAICS 3254120.044 kg

Source 3 · The top value is 1.277 before rounding. These are US factors, in US dollars. Other sets, such as those priced in euros, give other numbers.

Show the numbers
Industry codeValue
All other basic organic chemical1.28 kg
Plastics packaging film and sheet0.483 kg
Glass container0.441 kg
Folding paperboard box0.432 kg
Medicinal and botanical0.139 kg
Biological product0.121 kg
Pharmaceutical preparation0.044 kg

A code for finished medicines is a poor fit for a late-stage chemical intermediate, and so is a bulk organic chemicals code. Two careful analysts could choose either. The factor may be defensible, yet it tells you about an industry's average dollar in one country. It says nothing about your supplier's plant in another.

Worked example, spend estimate. In this guide's fictional case, Veltara spent €38.6 million on 17.1 tonnes of the VT-114 intermediate, and its spend factor gives 7,011 tonnes of CO2e, about 0.18 kg per euro. That works out at 410 kg of CO2e per kilogram of product. If the supplier raised its price 9% with no change at the plant, the same calculation would report about 7,642 tonnes, 631 more. The price rise is illustrative. The arithmetic is why a spend estimate can never show progress.

How one inventory splits across the four methods

Laying an inventory out by method shows how much of the number you know. Veltara's fictional FY2025 inventory shows the pattern: known in the categories where suppliers have data, averaged in travel, commuting and waste, and still mostly money in capital goods.

Purchased goods lead on supplier data; capital goods are still mostly a spend estimate

Thousand tonnes of CO2e by method, three large categories and the whole inventory, after one supplier's swap

Supplier product dataSupplier company dataAverage dataSpend estimate
Purchased goods and services118.6142.328.6
Capital goods4.19.827.9
Upstream freight11.214.33.4
All ten categories118.6159.3117.759.9

Fictional example from this guide

Show the numbers
CategorySupplier product dataSupplier company dataAverage dataSpend estimate
Purchased goods and services118.6142.322.928.6
Capital goods04.19.827.9
Upstream freight011.214.33.4
All ten categories118.6159.3117.759.9
03 · The rules and their dates

ESRS E1, the CSRD Omnibus, California's SB 253 and the GHG Protocol revision: what each asks of Scope 3 in November 2026

Status as of November 3, 2026

In shortThese rules moved again and again in 2026. The CSRD now reaches far fewer companies. The EU standards were rewritten and apply from financial year 2027. California's first report falls due November 10, 2026, with Scope 3 proposed for 2027. The GHG Protocol's Scope 3 revision is still a draft, with public consultation slated for Q2 2027. Date every statement you make about any of them.

Ten dates, four of them still ahead, reset Scope 3 reporting for a drug maker
  1. Apr 2025PACT Methodology v3

    Product footprint method. Primary data share required; quality rating from 2027.

  2. Nov 2025PAS 2090 and the buyers' letter

    Pharma product rules on Nov 30; updated supplier targets on Nov 21.

  3. Feb 26, 2026CSRD Omnibus published

    Directive 2026/470: over 1,000 employees and EUR 450 million.

  4. Mar 2026GHG Protocol progress update

    Draft proposals on data tiers and allocation. No consultation yet.

  5. Jun 2026SBTi net-zero standard v2

    Target validation opens Q1 2027.

  6. Sep 21, 2026Simplified ESRS and cap published

    Delegated regulations 2026/1563 and 2026/1560.

  7. Nov 10, 2026Two dates in one day

    Simplified ESRS enters into force. California's first report is due, Scopes 1 and 2.

Source 11,12,13,8,7,14,15,5,16,17,18

Show the numbers
WhenWhat
Apr 2025PACT Methodology v3
Nov 2025PAS 2090 and the buyers' letter
Feb 26, 2026CSRD Omnibus published
Mar 2026GHG Protocol progress update
Jun 2026SBTi net-zero standard v2
Sep 21, 2026Simplified ESRS and cap published
Nov 10, 2026Two dates in one day
Dec 15, 2026ISSA 5000 applies
Jan 1, 2027Simplified ESRS and cap apply
2027 proposedCalifornia Scope 3
TextWhat it asks of Scope 3 workStatus, November 3, 2026
ESRS E1 as adopted in 2023Disclosure E1-6: gross Scope 3 from each significant category, and "the percentage of emissions calculated using primary data obtained from suppliers or other value chain partners".4 Companies up to 750 employees may omit Scope 3 in early years.19In force. Applies to FY2025, and may still be chosen for financial years starting in 2026.5
Simplified ESRS, Delegated Regulation 2026/1563Scope 3 moves to E1-8, "from each significant scope 3 category as a total and per category". Instead of a percentage, its application requirement AR 24(d) tells companies to favor data from specific activities, timely and representative data, "and data that has been verified". An undertaking "may use" counterparties' data or estimates, including "spend-based data".5Adopted July 3, published September 21, enters into force November 10, 2026. Applies to financial years beginning on or after January 1, 2027.5
CSRD, as amended by Directive 2026/470 (the Omnibus)Sustainability reporting for companies with over 1,000 employees and over EUR 450 million in net turnover. A value-chain cap (see section 04). Limited assurance, an auditor's lighter level of review, stays, and the path to reasonable assurance, the stricter level, is removed.8Published February 26, 2026. National laws due March 19, 2027. EU limited assurance standards postponed to July 1, 2027.8
California SB 253US entities doing business in California with over $1 billion in revenue report Scopes 1 and 2 in 2026, with no third-party assurance this year, and Scope 3 from 2027.16,20 Penalties up to $500,000 a year. Through 2030, Scope 3 penalties reach only a failure to file, and Scope 3 misstatements "made with a reasonable basis and disclosed in good faith" draw no penalty.16,21Regulation approved October 12, 2026.20 First report November 10, 2026, moved from August 10.22,23 For 2027, CARB staff previewed five Scope 3 categories, Category 1 among them, as "preliminary staff concepts".17,23 CARB's August deck promised a draft rule for 45-day comment this fall and a board item by the end of 2026; we found no notice on November 3, 2026.22 On the court challenge, no Ninth Circuit ruling as of October 23.24
US SEC climate ruleIts 2024 final text left Scope 3 out.Stayed since April 4, 2024, so never in effect, with the court case on hold. The SEC proposed full rescission on May 29, 2026; published June 3, comments closed August 3.25 We found no final rule on November 3, 2026.
IFRS S2 and UK SRSA climate disclosure standard from the IFRS Foundation, and the UK's standards: Scope 3 disclosure, with a transition relief. The December 2025 amendment eases specific emissions requirements, financed emissions among them; the summaries we read name no change to Category 1.26IFRS S2 amended December 11, 2025, for periods from January 1, 2027. UK standards final on February 25, 2026, voluntary until a regulator requires them.26
GHG Protocol Scope 3 Standard, 2011The method behind nearly all of the above. It requires "for each scope 3 category, the percentage of emissions calculated using data obtained from suppliers or other value chain partners".6,7In force as written. Revision in progress: the March 2026 update says it "is not a GHG Protocol Standard", and a draft for public consultation "will be forthcoming".7 A consolidated consultation covering Scope 3 is slated for Q2 2027, and a joint GHG Protocol-ISO Corporate Standard for Q4 2028.27
Science Based Targets initiative (SBTi) Corporate Net-Zero Standard v2Scope 3 targets, with options such as supplier alignment. Larger companies cover categories above 5% of Scope 3.15Published. Submissions from Q1 2027; version 1 stays open "until the end of 2027", per SBTi's page.14
EU due diligence directiveThe climate transition plan article is deleted. Thresholds rise to 5,000 employees and EUR 1.5 billion.8Applies from July 26, 2029.8
Three changes to read twice. First, E1-6 now means different things by year: Scope 3 in the 2023 text, and Targets in the simplified text, where Scope 3 is E1-8. Check which one a document means.
Second, a company in the first CSRD wave that falls under the new thresholds leaves scope from financial year 2027, and member states may exempt it for 2025 and 2026.8
Third, losing the EU percentage does not end the need for it: the GHG Protocol asks for it, the proposed revision would go further, and your assurance provider will still ask how much of the number you know.7
04 · The value-chain cap

What you may demand of a supplier under the CSRD value-chain cap, and how to ask for a product footprint anyway

Status as of November 3, 2026

In shortA supplier with up to 1,000 employees is a "protected undertaking". For CSRD reporting, you may not require more from it than a short list of datapoints, and that list holds company-level figures with no product's footprint among them. You may still ask. If you do, you must say which part goes past the limit and that the supplier may decline. Estimates remain acceptable for what you cannot get.

The rule sits in the amended Accounting Directive. A reporting company "shall not require" a protected supplier to provide information beyond the voluntary standards, and a contract clause saying otherwise "shall not be binding". Where a request goes past the limit, the company "shall ensure" the supplier is told which information exceeds it and that it has a "statutory right to decline". A company that stays within the limit is "deemed" to have met its value chain duty.8

The list itself is Annex II of Delegated Regulation 2026/1560, and the simplified ESRS says it applies to non-EU suppliers too.9,5 The list applies to financial years beginning on or after January 1, 2027, and national laws are due by March 19, 2027.9,8

For a protected supplier, company emissions can be required; a product footprint can only be requested

Our reading of Annex II and Article 19a(3), for requests made for CSRD reporting, financial years from 2027

May ask; it may declineWithin the capNo cap applies
Up to 10 employees11 to 1,000 employeesOver 1,000 employeesCompany profile, headcount, turnoverWithin the capWithin the capNo cap appliesTotal energy useMay ask; it may declineWithin the capNo cap appliesEstimated gross Scope 1 and 2May ask; it may declineWithin the capNo cap appliesProduction tonnesMay ask; it may declineMay ask; it may declineNo cap appliesScope 3 emissionsMay ask; it may declineMay ask; it may declineNo cap appliesProduct carbon footprintMay ask; it may declineMay ask; it may declineNo cap applies

Our reading of the sources 8,9 · Annex II lists turnover in the supplier's general information (B1, paragraph 27(e)), so a revenue key can sit inside the cap. Production volume is not listed. Read the annex with counsel for your own requests.

Show the numbers
Up to 10 employees11 to 1,000 employeesOver 1,000 employees
Company profile, headcount, turnoverWithin the capWithin the capNo cap applies
Total energy useMay ask; it may declineWithin the capNo cap applies
Estimated gross Scope 1 and 2May ask; it may declineWithin the capNo cap applies
Production tonnesMay ask; it may declineMay ask; it may declineNo cap applies
Scope 3 emissionsMay ask; it may declineMay ask; it may declineNo cap applies
Product carbon footprintMay ask; it may declineMay ask; it may declineNo cap applies

Four things the cap leaves open for Scope 3 teams

Voluntary sharing

The recital says the cap "should not prohibit the sharing of information on a voluntary basis, such as information that is commonly shared among undertakings in a given sector".8 Some chemical suppliers already make footprints for customers.

Other purposes

Requests for due diligence or risk management sit outside the cap.8 Science-based target programs and health-system buyers also ask on their own terms. Write down why you are asking, because the reason decides which rule applies.

Estimates

You "may use estimates", including sector averages and spend-based data, and you must report your reliance on them and any plan to improve.5 So a declined request costs you data quality and leaves your report lawful.

Size is self-declared

You may rely on a supplier's own statement of its size, and need not verify it, unless you know or should know it is "manifestly incorrect".8 Keep a field for it, and capture it once.

What this means for a follow-up question. Suppose a vial supplier with 800 staff sends an old footprint. A letter asking for a new one, or for furnace energy and glass tonnage, goes past the list. From financial year 2027, if it is made for CSRD reporting, it needs two extra sentences: "this request goes beyond the voluntary standard" and "you have the right to decline". The supplier's total turnover is on the list, so asking for that needs neither. A letter template that lacks them is a defect worth fixing now.
05 · What suppliers send

Footprints, CDP responses, questionnaires, VSME reports and freight files: what each document can and cannot prove

In shortFive kinds of document arrive, and they answer different questions. A product footprint is the only one built for a single purchase line. A CDP response gives a company total, with no key to divide it by unless you ask. A short report from a small supplier may cover Scopes 1 and 2 only. Knowing what each one lacks tells you what to ask next.

DocumentWhat one looks likeMethod it feedsWhat usually trips you up
Product carbon footprintA PDF, sometimes with a machine-readable data file, built on ISO 14067, the PACT Methodology, Together for Sustainability (TfS) guidelines for chemicals or PAS 2090 for pharmaceutical products28Supplier-specificYear, boundary, allocation, declared unit
CDP climate responseDozens of pages of company-level answers, with Scope 1 and 2 totals and sometimes Scope 3HybridNo revenue or tonnage to allocate by, and upstream emissions left blank
Your own questionnaireA spreadsheet or portal form, filled by whoever received itHybridFree-text units, missing evidence, a different answer each year
VSME or voluntary SME reportA short report on the EU's voluntary standard, with a basic module and a comprehensive module; Scope 3 is optional9Hybrid, when you can allocate itA whole company's total, which only makes sense once you know your share of it
Carrier shipment emissionsLane-level data to the GLEC Framework, the freight method named in the Sustainable Markets Initiative's supplier toolkit28Feeds Categories 4 and 9A reporting period that does not match your year
Only a product footprint answers every question a purchase line asks

What each document usually provides, before any follow-up

AbsentPartlyUsually
Value for your productBoundaryReference periodAllocation statedPrimary shareVerificationProduct carbon footprintUsuallyUsuallyUsuallyUsuallyUsuallyPartlyCDP climate responseAbsentPartlyUsuallyAbsentAbsentPartlyYour questionnairePartlyPartlyPartlyAbsentAbsentAbsentVSME reportAbsentAbsentUsuallyAbsentAbsentAbsentCarrier shipment filePartlyUsuallyUsuallyPartlyPartlyAbsent

Our reading of the sources 2,11,9 · Our classification from the methods the sources describe. Your suppliers may do better or worse.

Show the numbers
Value for your productBoundaryReference periodAllocation statedPrimary shareVerification
Product carbon footprintUsuallyUsuallyUsuallyUsuallyUsuallyPartly
CDP climate responseAbsentPartlyUsuallyAbsentAbsentPartly
Your questionnairePartlyPartlyPartlyAbsentAbsentAbsent
VSME reportAbsentAbsentUsuallyAbsentAbsentAbsent
Carrier shipment filePartlyUsuallyUsuallyPartlyPartlyAbsent
Allocating a company total, and why it may get harder. To use a supplier's company figure you multiply by your share of its output or revenue. The GHG Protocol warns this "can add a considerable degree of uncertainty".2 Its draft Revision A8 goes further: corporate-level allocation "shall not be used" except for homogeneous suppliers, those "with relatively uniform emissions throughout" their operations.7 It is a proposal, with no adoption date. If you lean on allocated company data, sort your suppliers now into uniform and diversified.
06 · Reading a footprint

How to read a supplier product carbon footprint: boundary, reference period, allocation, primary data share and verification

In shortFive fields decide whether a footprint can replace an estimate. Boundary must be cradle-to-gate for Category 1. The period must be close enough to your year. Allocation between co-products follows a set order. Primary data share says how much of the figure the supplier measured. Verification says who else has looked. PACT sets rules for each, and its verification roadmap runs in two stages, to 2030 and beyond.

The Partnership for Carbon Transparency, or PACT, is an initiative hosted by the World Business Council for Sustainable Development, and version 3 of its method is dated April 2025. Companies "shall assess the primary data share". From 2027 they also assess a data quality rating. If upstream values are unknown, they apply the worst case: 0% primary data and a rating of 5.11

FieldWhat to look forIn the example
Declared unitPer kilogram of the product you bought, at the purity you bought182 kg CO2e per kg of VT-114
BoundaryCradle-to-gate. A cradle-to-grave figure double counts your own downstream stepsCradle-to-gate, page 2
Reference periodThe period the data represents. PACT says it "shall always be disclosed".11 How old you accept is your own ruleJanuary 1 to December 31, 2025. Veltara's limit is 24 months
AllocationHow emissions were split among products from one processMass, with a recovered by-product
Primary data shareThe share of the footprint from measured activity and emissions data71%. Veltara's minimum is 40%
Energy claimsRenewable shares backed by certificates or a contract62% from a solar contract started in March 2025, certificates retired
VerificationWho checked, at what level, on what date. PACT's short-term route (2025 to 2030) verifies the calculation model; from 2030, the program11Limited assurance by a third party, dated October 2, 2026, page 6

Allocation, worked: why a vial's footprint depends on who else buys the tubing

When one furnace makes glass for vials and tubing sold to others, you have to split its emissions. PACT's order is to avoid allocation if you can. If you cannot, compare the economic value of the co-products: when the most valuable is worth more than five times the least valuable, allocate by value; otherwise use a physical measure where one fits. "In doubt, mass allocation should be prioritized".11 Here is why it matters, on illustrative numbers.

The same furnace reports 75% more for the vials under economic allocation

A furnace emits 1,000 t of CO2e. Vials are 40% of its output by mass and 70% by value

Allocated by massAllocated by value
Vials400 t700 t
Tubing sold to others600 t300 t

Illustrative · replace with your own numbers · Value per tonne differs here by 3.5 times (70÷40 against 30÷60), below 5, so PACT's order points to a physical measure. Neither split is wrong by arithmetic. Only one follows the order.

Show the numbers
ProductAllocated by massAllocated by value
Vials400 t700 t
Tubing sold to others600 t300 t

How to state the share of Scope 3 resting on supplier data without overstating it

The word "primary" invites overstatement. A footprint with a 71% primary data share is 29% secondary data inside. A company total, allocated to your purchases, is supplier data that you have divided by a key of your own. So "61% on supplier data" and "61% primary" are different claims. Veltara's fictional 3,112 tonnes from Kestrel contains about 2,210 tonnes that the supplier's document calls primary (3,112 × 71%).

ESRS's 2023 text speaks of "primary data obtained from suppliers"; the Scope 3 Standard of "data obtained from suppliers or other value chain partners".4,6 The GHG Protocol's draft adds that data type "is not by itself an indicator of data quality or data accuracy".7 State what your percentage counts. If you can, publish the product layer and the company layer separately. In the example they are 26% and 35% of the total.

07 · The swap, worked

Swapping a spend estimate for a verified footprint, line by line, and booking 3,900 tonnes as a method change

In shortThe arithmetic takes one line: kilograms bought times the supplier's figure. The accounting takes more care. The fall goes on a separate line from real reductions, your target and base year have to be treated consistently, and the share of supplier data moves too. Here is one swap, in full, from this guide's fictional case.

StepCalculationResult
Estimate for the line17.1 t bought × 410 kg CO2e per kg7,011 t
Footprint for the line17.1 t bought × 182 kg CO2e per kg3,112 t
Change on the line3,112 − 7,011−3,899 t, shown as −3,900
Category 1316,300 − 3,900312,400 t
Total Scope 3459,400 − 3,900455,500 t
On supplier data(115,490 + 3,112 + 159,300) ÷ 455,50061.0%, up from 59.8%
Swapping in the footprint cuts the line by more than half and moves the total by under 1%

Tonnes of CO2e, before and after one supplier's footprint

Spend estimateSupplier footprint
VT-114 purchase line7,011 t3,112 t

Fictional example from this guide

Show the numbers
LineSpend estimateSupplier footprint
VT-114 purchase line7,011 t3,112 t

Real change against method change: what moved between two inventories

A year-on-year comparison mixes two things. Purchases grew, and suppliers cut emissions: that is real change. Better data replaced worse data: that is method change. In the example the reported total fell 25,800 tonnes. Only 7,700 of that is real.

Better data moved the number more than twice as far as real change did

FY2024 481,300 t to FY2025 455,500 t, size of each move in tonnes of CO2e, method change in blue

Supplier data below the estimatemethod change · takes off21,600 t
Supplier data above the estimatemethod change · adds3,500 t
Renewable power at 14 suppliersreal change · takes off9,800 t
Solvent recovery at 6 suppliersreal change · takes off4,100 t
More purchases, up 4%real change · adds6,200 t

Fictional example from this guide · Real: 9,800 + 4,100 − 6,200 = 7,700 lower. Method: 21,600 − 3,500 = 18,100 lower.

Show the numbers
What movedValue
Supplier data below the estimate21,600 t
Supplier data above the estimate3,500 t
Renewable power at 14 suppliers9,800 t
Solvent recovery at 6 suppliers4,100 t
More purchases, up 4%6,200 t

A swap can also push the number up. In the example, one supplier of recovered solvent reports a footprint 410 tonnes above its estimate, because its recovery runs on gas. A program that only ever shows falls should make a reader suspicious.

Base years and targets: what the method change does to your reduction goal

If you hold a Scope 3 target, the Scope 3 Standard requires a policy for recalculating your base year, the year you track progress against, and says to recalculate "when significant changes in the company structure or inventory methodology occur".6 You set the threshold for "significant" yourself, so write it down before the swaps begin. Otherwise the base year stays on spend estimates while the current year moves to supplier data, and your apparent progress is partly an artifact. The opposite failure is restating every year, which leaves readers no fixed point.

Supplier data share more than tripled in two years while suppliers asked went from 60 to 240

Share of Scope 3 on supplier data, by inventory year

18%FY2023 · 60 asked
34%FY2024 · 150 asked
61%FY2025 · 240 asked

Fictional example from this guide

Show the numbers
PeriodOn supplier data
FY2023 · 60 asked18%
FY2024 · 150 asked34%
FY2025 · 240 asked61%
Method change and error are different entries. ESRS 1 says a company "shall correct material prior period errors by restating the comparative amounts" unless that is impracticable.5 A better method is a change you explain. A figure that was wrong is an error you restate. Public plans show the pattern: one drug maker's UK plan says it "updated its methodology for scope 3 reporting" and "will be assuring and restating its baseline and reporting year".29 Announced in advance like that, a restatement is ordinary.
08 · Plausibility checks

Testing a chemical supplier's footprint against process mass intensity, peer ranges and the estimate it would replace

In shortA footprint can be well formatted and still wrong. Drug chemistry gives you tests that need no plant visit: how much material the route uses per kilogram of product, how much solvent is recovered, what similar routes report, and how far the figure sits from the estimate. A large gap in either direction earns a second look. Passing shows only that a figure is plausible.

Process mass intensity, or PMI, is the mass of everything used to make one kilogram of product: reagents, solvents, water. It is the drug chemist's shorthand for how heavy a process is, and it varies enormously by type of medicine. Published work puts small molecules at a median of 168 to 308, biopharmaceuticals at about 8,300, and solid-phase peptide synthesis at about 13,000.30

McKinsey, in an article we could read only in excerpts, gives average material intensity of 70 to 433 kg per kg for active ingredients, and emission factors of 50 to 1,000 kg of CO2 per kg of active ingredient.31

Peptide routes use at least 40 times the material of a typical small molecule, so one range cannot fit all

Process mass intensity, kg of input per kg of product, as published

Small molecules, upper median308 kg/kg
Biopharmaceuticals8,300 kg/kg
Peptides, solid-phase synthesis13,000 kg/kg

Source 30 · Authors mostly work at drug and peptide manufacturers. Water is included in PMI, so a high figure does not map to carbon one for one.

Show the numbers
Type of medicineValue
Small molecules, upper median308 kg/kg
Biopharmaceuticals8,300 kg/kg
Peptides, solid-phase synthesis13,000 kg/kg

Eight checks for a supplier footprint on a chemical intermediate

CheckThe testIn the exampleIf it fails
BoundaryCradle-to-gate, as Category 1 needsPassHold and ask
PeriodWithin your age limit2025, inside 24 monthsHold and ask
AllocationFollows the published orderMass, with a by-productHold and ask
UnitMatches the purchase linePer kg; 17.1 t boughtConvert, or hold
Mass balancePMI and solvent recovery are consistent with the footprintPMI 210, 78% recoverySecond look
Peer rangeSits among similar routes, and within published rangesOwn suppliers 120 to 260; published 50 to 1,000Second look
Biogenic carbonCarbon from plant or animal sources, reported separately where it mattersAbsent; note only, for a synthetic routeNote
VerificationPresent above your thresholdPage 6; required above 1,000 tHold and ask

The thresholds in that table are the fictional company's choices. No rule sets a maximum footprint age or a minimum primary data share for a buyer. Published ranges are wide: 50 to 1,000 would pass almost anything, so your own suppliers' range on similar routes does most of the work. That range grows more useful every year you collect.

Estimate gap, both ways. A footprint far below the estimate looks like good news and deserves the hardest look. Kestrel's 182 sits 56% below 410. Veltara's second-look rule fires at ±60%, so it passes that test, narrowly. A gap is a reason to read further. It tells you nothing about which figure is right, since the estimate may be the poor one.
09 · What goes wrong

Common Scope 3 data errors: the wrong year, cradle-to-grave figures, double counted energy and reductions that were only method

In shortThe errors repeat. Old footprints, wrong boundaries, economic allocation, company totals with nothing to divide by, and unit mix-ups are what the checks exist to catch. The most damaging one is different in kind: a method change reported as a cut. We found no enforcement case on this exact point, and no public rate for any of these errors, so measure your own.

ErrorHow it happensWhat it does to the number
Old reference yearThe supplier reuses a footprint from before its plant changedMisses real change; may be above or below today
Wrong boundaryCradle-to-grave, or gate-to-gate with no upstreamToo high, or far too low
Economic allocation between co-productsSimple to run, often the default in a templateMoves with prices; shifts emissions onto your product
Unallocatable company totalA CDP response without revenue or tonnesUnusable as sent, and it may omit upstream altogether
Upstream left outCompany data covering Scopes 1 and 2 onlyUnderstates a cradle-to-gate figure unless you add a factor for raw materials
Unit or batch confusionFootprint per batch, with no batch sizeOff by orders of magnitude
Unsupported renewable claimsA share of renewable power with no certificatesUnderstates emissions, and fails at assurance
Mixed factor setsDifferent versions or price years inside one categoryMakes year-on-year comparison meaningless
Method change called a cutTotals compared with no split between real and methodOverstated progress against a target
Over-reach under the capOne template sent to every supplierNo effect on tonnes; a breach of the notice duty from 2027

From 1,860 suppliers to 168 usable answers: where supplier data falls away

Coverage narrows at each step, and each step is a place to act. Watch the gap between the third bar and the fourth. A supplier that sent something unusable has already made an effort, and a precise question can turn it into usable data.

Seven in ten suppliers asked send data that passes; another 41 are one question away

Veltara's fictional FY2025 cycle, supplier counts

All suppliers1,860
Asked, covering 82% of purchased goods spend240
Answered with something209
Accepted after checks168

Fictional example from this guide

Show the numbers
StageCount
All suppliers1,860
Asked, covering 82% of purchased goods spend240
Answered with something209
Accepted after checks168

Public evidence that supplier emissions disclosure is still thin

CDP looked at more than 18,700 companies' 2022 responses and found nearly 60% reported on no supply chain category at all.32 That data is old, so read it as background. BCG and EcoVadis, writing in September 2025 about companies on EcoVadis's platform, report 24% disclosing upstream Scope 3 and 8% with a target to reduce it.33 A 2025 benchmark for automated extraction found about half of the sustainability reports it studied held no usable greenhouse gas data, with other indirect emissions "rarely complete".34

What nobody publishes. We found no public figure for the share of Scope 3 on primary data across first-wave ESRS statements (the report on a review of 656 of them by EFRAG, which drafted the standards, gives none35), the rate of errors in supplier footprints, the share of footprints that fail a check, restatements caused by Scope 3 data, or hours per supplier. Vendor claims exist without an independent test. Treat any such figure as a question to ask.
10 · Who is pushing, and how hard

Why pharma suppliers are hearing about Scope 3 from health systems, big drug makers and auditors at the same time

In shortThe pressure comes from three sides. Health systems want lower supply chain emissions. Large drug makers have written to their suppliers with shared targets for 2027, 2028 and 2030. And auditors now sample these figures. The sector's footprint is large enough to attract attention, and a poor supplier data set blocks all three conversations at once.

Listed companies carry about two-thirds of the sector's 397 million tonnes
Public companies: 259 MtPrivate companies: 138 Mt
397Mt CO2e, 2023
  • Public companies259 Mt
  • Private companies138 Mt

Source 1

Show the numbers
PartValue
Public companies259 Mt
Private companies138 Mt
Four in five reporting teams name supplier data availability as a top challenge
79 in 100

say supplier data availability remains a top challenge, in a survey of 315 sustainability professionals across 18 industries

Source 10

Show the numbers
MeasureValue
say supplier data availability remains a top challenge, in a survey of 315 sustainability professionals across 18 industries79 of 100

The health-care buyers' targets, as of the November 2025 letter

In November 2025, procurement chiefs of the Sustainable Markets Initiative's Health Systems Task Force, large drug and health care companies, updated the targets their chief executives first set in 2023. They say the sector is about 5% of global emissions, more than half from the supply chain.13 NHS England, England's public health system and a sponsor of PAS 2090, reports 62% of its own emissions from its supply chain, over a quarter linked to medicines and prescribing.12,36

ByWhat suppliers are asked to doWhat it means for your data
2027Publicly set validated science-based targets across Scopes 1, 2 and 313You will need a base year your suppliers trust
2028Disclose Scopes 1, 2 and 3, and footprints or life cycle assessments for the top 10 products by annual emissions13Footprints will arrive whether you ask or not, and the same suppliers can reuse them for all their customers
2030At least 80% renewable electricity; process heat emissions down at least 20%13Real cuts your inventory can show only if the supplier's own data has replaced the estimate

The initiative's supplier toolkit says individual customers may still ask for products beyond the top 10, and that a request "may replace existing product-level data requirements".28 PAS 2090:2025, published November 30, 2025, sets product category rules for pharmaceutical life cycle assessments.12 Medicine makers in the UK should also watch NHS England's plan for product-level footprints from 2028. A draft market survey, out for testing in June 2026, asks suppliers how they collect and report this data, and says life cycle assessments will not be needed for every product.37

How few companies disclose upstream Scope 3, and how few of those are on track

About a quarter of companies disclose upstream Scope 3; only 3 in 100 are on track against a science-aligned target

Share of companies reporting on the EcoVadis platform

Disclose upstream Scope 324%
Set a target to reduce it8%
On track to a science-aligned target3%

Source 33 · From a ratings provider's own platform, published with a consulting firm. Both sell related services.

Show the numbers
ItemValue
Disclose upstream Scope 324%
Set a target to reduce it8%
On track to a science-aligned target3%

BCG and EcoVadis report that partnering with suppliers makes companies "nine times more likely" to set and deliver a Scope 3 target, and that upstream emissions average 21 times Scopes 1 and 2.33 Read the first as a correlation: companies that engage suppliers may be further along in other ways.

A note on wording. Since September 27, 2026, EU member states must apply Directive 2024/825, which bans product claims of reduced climate impact based on offsetting.38 That rule is about consumer claims, and your Scope 3 note is a report. The habit carries across all the same: say what changed in the world, and what changed in the calculation.
11 · What AI changes, and the limits

Reading supplier PDFs with AI: what automation does well in Scope 3 work, what no regulator has written, and what stays with people

Status as of November 3, 2026

In shortReading documents, matching purchase lines and running rule checks suit software. Judging a borderline footprint, deciding what to tell a supplier and signing the figure do not. No regulator has written an AI rule for Scope 3 work. Most AI rules aimed at drug makers govern other work, so the practical test is the assurance provider's question: show me the method and the source.

Start with reading and rule checks; keep judgment and signature with people

Where each task sits by volume and by the cost of a mistake

Cost of getting it wrong →
Keep with people
Automate, then check
Leave for later
Automate first
Signing the figuresReal or methodSetting thresholdsPlausibility rulesReading footprintsDrafting questionsMatching lines
How much of it there is →

Our reading of the sources 2,34 · Our judgment. Placement depends on your suppliers and your controls.

Show the numbers
ItemHow much of it there is (0–1)Cost of getting it wrong (0–1)
Signing the figures0.120.80
Real or method0.300.71
Setting thresholds0.120.62
Plausibility rules0.780.54
Reading footprints0.780.31
Drafting questions0.620.21
Matching lines0.780.11
Rule or textDoes it reach this work?Status
CSRD, Article 29fThe Commission must report on technological solutions to collect, process and exchange sustainability data.8Report due by March 19, 2028
Draft EU GMP Annex 22Written for AI in applications under Good Manufacturing Practice (GMP), the rules for making medicines, and generative AI and large language models (LLMs) "should not be used" in critical ones.39 A Scope 3 inventory is outside GMP. A check that fed batch decisions would be a different matter.A draft. EudraLex Volume 4, the EU's collection of GMP legislation and guidance, lists no Annex 22, and Annex 11 stays at January 2011.40
FDA draft guidance on AI, January 2025Scoped to AI that supports "regulatory decision-making regarding safety, effectiveness, or quality for drugs".41 A carbon inventory is outside that scope.Draft, not for implementation
EU AI ActWe read no high-risk category that names supplier data checks; confirm your own use with counsel.AI Omnibus in force July 27, 2026. High-risk rules for AI built into regulated products now apply from August 2, 2028, and for AI in the sensitive areas of Annex III from December 2, 202742
Limited assuranceNo AI wording in what we read. It reaches everything through sampling: the auditor picks a figure and wants its method and source.8,18EU standards due July 1, 2027; ISSA 5000 for periods from December 15, 2026

What automated reading gets wrong, and the controls that catch it

The authors of a 2025 benchmark on greenhouse gas extraction warn that users can place full trust in model output and overlook measurement errors that occur often.34 We found no independent error rate for reading supplier footprints specifically.

Four controls follow from that. Every value carries its page, so a person can check in seconds. A missing value stays missing, so nothing gets invented. The rule checks are plain rules with versioned thresholds, so an auditor can re-run them. And a person decides every swap above a size you set, with a record of who and why.

12 · How teams do it today

Who runs Scope 3 supplier engagement: sustainability, procurement and the auditor, and where their working days go

In shortA small sustainability team owns the number and procurement owns the suppliers. The hand-offs between them are where time disappears. Reading and checking take the largest share of the days, which is why many programs check a sample. Teams run it in house, with a consultancy, on a software platform, through a sector program, or by some mix of these.

The five roles behind a signed Scope 3 figure

HS

Head of Sustainability

Owns the climate figures in the annual report and the science-based target, and signs them.

Cares about: how much of the number is real.
RM

ESG reporting manager

Builds the disclosure, holds the factor sets and answers the auditor's samples.

Cares about: tracing any figure back to a document.
CM

Procurement category manager

Owns the supplier relationship, and often dozens of chemistry suppliers and hundreds of millions in spend.

Cares about: asking once, and only for what is needed.
EL

Supplier engagement lead

Runs the annual request, tracks who answered and chases the rest.

Cares about: the wrong year on half the PDFs.
AP

External assurance provider

Gives limited assurance on the sustainability statement, sampling figures.

Cares about: the method and the source.

How a supplier submission moves from inbox to inventory

A footprint crosses three desks before it changes a number, and a late question restarts the walk
  1. 1Request sent

    Climate data request to 240 suppliers.

    Engagement leadJuly 1
  2. 2Submission arrives

    PDF, data file, CDP response or short report, by email or portal.

    Engagement leadBy October 10
  3. 3Read and logged

    Values copied into a spreadsheet with their page.

    Reporting managerDays per batch
  4. 4Matched and checked

    Purchase line found; boundary, year, allocation and range tested.

    Reporting managerMost of the cycle
  5. 5Question or swap

    Hold and ask through the category manager, or replace the estimate.

    Category managerWeeks if held
  6. 6Figures signed

    Category approved, method notes written, file sent to the auditor.

    Head of SustainabilityLate in the cycle

Fictional example from this guide

Show the numbers
StepWhat happensWhoTime
Request sentClimate data request to 240 suppliers.Engagement leadJuly 1
Submission arrivesPDF, data file, CDP response or short report, by email or portal.Engagement leadBy October 10
Read and loggedValues copied into a spreadsheet with their page.Reporting managerDays per batch
Matched and checkedPurchase line found; boundary, year, allocation and range tested.Reporting managerMost of the cycle
Question or swapHold and ask through the category manager, or replace the estimate.Category managerWeeks if held
Figures signedCategory approved, method notes written, file sent to the auditor.Head of SustainabilityLate in the cycle

Where a two-person team's 50 working days go on 240 suppliers

No one publishes this split. These are illustrative figures, an estimate for a cycle done by hand. Replace them with your own.

Reading and checking take three of every five working days

Estimated working days for one annual cycle of 240 suppliers, two people, by hand

Logging and readingMatching lines and factorsCheckingQuestions, real or method, write-up
50 working days15 days6 days15 days14 days

Illustrative · replace with your own numbers

Show the numbers
Logging and readingMatching lines and factorsCheckingQuestions, real or method, write-up
50 working days15 days6 days15 days14 days

In-house spreadsheets, a consultancy, carbon accounting software or a sector program: how teams staff this work

WaySuitsWatch for
Spreadsheets, in houseFew suppliers, one analyst who knows them allSampling; the method leaves with the analyst; a trail rebuilt each audit
ConsultancyA first inventory, or a screening before you hireKnowledge outside the company; a cost that repeats each cycle
Carbon accounting or supplier engagement softwareLarge supplier bases and repeat cyclesForms that collect but do not test; figures accepted as sent; unclear separation of method change
Disclosure systems and sector programsReaching many suppliers with one requestCompany-level answers that still need your key and still need checking
Part B · See it working

Watching Botminds take one supplier footprint from arrival to signed Scope 3 figures

Part A described the work without naming a product. This part shows how Botminds does it, for a fictional drug maker closing its FY2025 Scope 3 inventory. Every company, person, product, number and document in the screens is sample data, in the sample's euros and tonnes. The sample's calendar is illustrative too: it runs a late-October close, and a calendar-year company reporting under the CSRD would close months earlier.

13 · One footprint, start to finish

From a 410 kg estimate to a verified 182 kg footprint: Kestrel's VT-114 line, read, checked, confirmed and signed

In shortThis is the example from the top of the page, inside the product. The agents read the footprint, find the purchase line and run the checks in view. Nadia Brenner, the Head of Sustainability, looks at the evidence and confirms. The estimate turns into supplier data in place, the change is filed as a method change, and she signs the category before the auditors arrive.

1

The home screen asks how much of the Scope 3 number is real

Nadia's home screen is the FY2025 inventory: 459,400 tonnes across ten categories, 59.8% on supplier data, against 18% in FY2023. Each category is one bar in four layers: dark green for supplier product data, lighter green for supplier company data, blue-gray for average data and hatched gray for spend estimates.

On the right, five supplier submissions have arrived. Kestrel's is first, and it shows the gap at a glance: 410 in the estimate, 182 in the footprint.

Scope 3 by data quality. Ten categories as layered bars, the supplier data share against FY2023, and arrivals on the right.
2

The agents read Kestrel's file and run the checks in view

Nadia presses "Check and swap in". The supplier data reader pulls 182 kg of CO2e per kg, cradle-to-gate, January to December 2025, mass allocation. The factor matcher finds the line: 17.1 tonnes bought for €38.6 million, now an estimate of 7,011 tonnes. The plausibility checker runs through its tests, step by step, each with its result.

One note appears, on biogenic carbon, which is not material for a synthetic route. The figure passes, and because the line is above the 250-tonne limit for automatic acceptance, it stops and waits for a person.

Checks run, waiting for a person. Each step shows what it found. Confirm, hold or see the evidence.
3

Every value and check points at a page in Kestrel's document

Before confirming, Nadia opens the evidence. On the left is the footprint itself, with each value highlighted. On the right, the effect of the swap, the eight checks and the values read. Move to a check and its source lights up: process mass intensity of 210 kg per kg, 78% of solvent recovered on site, 62% of electricity from a solar contract, limited assurance dated October 2, 2026.

Rahul Menon, who owns this supplier, sees the same screen, and can send a question from it.

One submission, all its evidence. Hover a check to see its line on the page. The swap's effect is shown before anyone accepts it.
4

Confirmed: the estimate's gray slice turns dark green and Category 1 falls 3,900 tonnes

Nadia confirms. Kestrel's 7,011-tonne estimate becomes 3,112 tonnes in the product data layer. Category 1 goes from 316,300 to 312,400 tonnes, Scope 3 to 455,500 tonnes, and supplier data from 59.8% to 61.0%.

A note appears under the bar: supplier PCF, PACT-aligned, filed as a method change. It will show on the Progress screen apart from real change, and it never counts toward the reduction target.

The swap, confirmed. The slice moves in place, the totals follow, and the reason sits under the bar.
5

Nadia signs Category 1 at 312,400 tonnes for the sustainability statement

The other nine categories were approved on October 10. With Kestrel's line settled, she reviews the table and signs with her password. The record keeps her name, the time and the meaning of the signature: "I approve these figures for the FY2025 sustainability statement".

The figures lock, and the assurance file can go to Wexcombe & Pryce, the fictional assurance provider, read-only for 60 days.

Approve and sign. The dialog states exactly what is being approved.
14 · Held submissions and questions

When a supplier's footprint fails: a 2022 vial figure held, a company total with no key, and the question each one earns

In shortThe submissions that fail show the checks at work. A submission that fails a blocking check is held, the estimate stays, and a question is drafted that names what failed and cites the page. A category manager reads it, edits it and sends it under their own name.

A held footprint. Orvane Glass reports 0.21 kg of CO2e per 2R vial on 3.3 million vials, or 690 tonnes. Its reference year is 2022, past the 24-month limit, and it allocates by value between vials and tubing. Both checks fail, so the spend estimate of 1,180 tonnes stays, even though the footprint looks lower. A lower number gets no shortcut.
A company total with no key. Tamberly Excipients sends a CDP response with 41,200 tonnes of Scopes 1 and 2, no Scope 3 and no revenue or volume. The check says it cannot allocate the total to the 1,860 tonnes Veltara bought, and warns that company data alone would understate a cradle-to-gate figure.
A question for the supplier. Nine drafts, 21,757 tonnes at stake. The letter asks for two things, cites pages 2 and 4, and offers to calculate with the supplier if a new footprint is not ready. Elena Tarrow, the category manager, sends it as herself. PACT's actual order on allocation is in section 06. Where a supplier is protected by the value-chain cap, add the notice from section 04 to your template, because this sample draft does not carry it.
15 · Every other screen

Category drill-downs, the 240-supplier list, real against method change, the disclosure table and the settings behind them

In shortEach screen answers one question a person in the cycle asks. Which lines make up this category? Who has answered? What really changed since last year? What goes in the statement, and what stands behind each figure? Who decides, and on what thresholds?

Purchased goods, capital goods and freight, line by line

Purchased goods, line by line. 118,602 tonnes on footprints from 64 suppliers, 142,300 on company data from 88 suppliers, 22,900 on average data and 28,599 on spend. Each line opens to its evidence.
Share of each category. One switch redraws the bars at equal width, so small categories with weak data stop hiding.
Capital goods. Two-thirds still on spend, 27,900 tonnes: the next place to ask.
Upstream freight. Carriers report by lane to the GLEC Framework. The rest is by distance, and courier spend stays on money.
Suppliers in the cycle. All 240 suppliers, each scored on what it sent: 168 accepted, 41 held, 31 with no answer. Tomás Ferreira, the supplier engagement lead, reminds the silent ones in one step, copied to their category managers.

Real change, method change and the ESRS disclosure, each on its own screen

Real change and method change. From 481,300 tonnes: 6,200 more for volume, 9,800 and 4,100 less from renewable power and solvent recovery at suppliers. Then, on separate lines, 21,600 less and 3,500 more from supplier data replacing estimates. These are the figures behind the chart in section 07.
The disclosure table. The screen follows ESRS E1-6, which is right for the sample's FY2025. From FY2027, Scope 3 sits in E1-8 and the percentage leaves the EU text (5). The column header "from supplier data" counts both supplier layers, 26% product and 35% company, so read its "(primary)" with section 06 in mind.
Method notes. Drafted from approved figures only: the standard used, the categories left out and why, and the 18,100-tonne method change kept apart from the 7,700-tonne like-for-like change.
The trail behind a figure. Click a number: purchase lines, methods, the supplier line, factor sets, approval. It exports for assurance.
Signed for the auditors. All ten approved, the meaning recorded, the file ready to share read-only.

Your thresholds, factor sets and cycle calendar, set by you

Checks and acceptance. The ±60% gap, 24-month age, 40% primary data share and 1,000-tonne verification limit are this sample's choices, each with what it affected this cycle. Change one, and the change is versioned and on the audit trail. A category manager sends every message to a supplier. The VSME setting's "under 1,000" is the sample's shorthand: the directive's line is up to 1,000 employees, and a request past the list may still go out with the notice from section 04.
Factor sets and calendar. One approved version per factor set, so a category never mixes them. The second custom rule follows the health-system buyers' 2028 target from section 10.
16 · Agents and who signs

The Head of Sustainability signs every Scope 3 category; five agents prepare what she signs

In shortEach agent does one job and has one thing it may never do. Nothing goes to a supplier without a person, no figure that fails a blocking check gets used, and a method change never counts as a reduction. Roles, approvals and the audit trail are built in, for an enterprise supplier base and an external assurance review.

The five agents behind a supplier data cycle

Supplier data reader

Reads footprints, CDP responses, questionnaires, VSME reports and PACT data files, and pulls out value, unit, boundary, period, allocation, primary data share and verification, each with its page.

Never guesses a missing value.

Factor matcher

Maps every purchase line to the most specific method the data supports, in the GHG Protocol order, and records the factor set and its version.

Never mixes factor sets in one category, or changes one without approval.

Plausibility checker

Runs boundary, period, allocation, unit, mass balance, peer range and verification checks, scores data quality from 1 to 5, and classes every change as real or method.

Never swaps in a figure that fails a blocking check, or calls a method change a reduction.

Follow-up writer

Drafts the question for what failed, in the supplier's terms, citing the page, for the category manager to send.

Never sends anything itself.

Disclosure drafter

Writes the Scope 3 table, the method notes and the assurance file from approved figures.

Never changes a figure.

Who confirms a swap, who sends a question, who signs the Scope 3 figures

Approves and signsHead of SustainabilitySigns each category with name, time and meaning. Signed figures lock for the auditors. Restating a prior year is a separate, signed act.
Confirms and preparesESG reporting managerConfirms swap-ins above the limit, approves factor sets and prepares the disclosure. Preparer and signer are two people.
Sends the questionsCategory managerReads, edits and sends each follow-up to their own suppliers, and sees only those.
Runs the cycleSupplier engagement leadSends requests and reminders, and watches who has answered.
Reads, read-onlyAssurance providerSees figures, trails and documents for 60 days in the sample. Supplier contacts see only their own requests.

The people in Veltara's fictional Scope 3 cycle

NB

Nadia Brenner · Head of Sustainability

Owns the annual report's climate figures and the science-based target.

"I need to know how much of our Scope 3 is real before I sign it."
CD

Claire Dufort · ESG reporting manager

Builds the disclosure and answers the auditors' samples.

"Every figure the auditor picks, I have to trace back to a document."
RM

Rahul Menon · category manager, APIs and intermediates

Owns 31 chemistry suppliers.

"Ask my suppliers once, in their language, and only for what you need."
ET

Elena Tarrow · category manager, primary packaging

Owns suppliers such as Orvane Glass, and tells each exactly what is wrong.

"Name the page, and I can send it today."
TF

Tomás Ferreira · supplier engagement lead

Runs the annual climate data cycle.

"Half of what comes back is a PDF with the wrong year in it."

Supplier files and purchase lines going in, a signed Scope 3 table and assurance file coming out

Supplier files

  • Product carbon footprints, PDF and PACT data file
  • CDP climate responses
  • Questionnaires
  • VSME reports
  • Carrier shipment data to the GLEC Framework

Your records

  • Supplier spend and purchase lines, with material data
  • Approved factor sets
  • Your reporting rules and thresholds
Agents read, match, check and draft Every value with its page, every change classed
People confirm the large swaps
One person signs

Outputs

  • Scope 3 by category, supplier data against estimate
  • Supplier data quality scores from 1 to 5
  • Follow-ups with owners and tonnes at stake
  • Real change and method change, year on year
  • Disclosure table and method notes
  • An assurance file linking each figure to its document and check

Systems a Scope 3 rollout connects to

ERP and purchasingPurchase lines, with the material master
Supplier portal or emailWhere submissions land
PCF data exchangePACT data files
Disclosure systemsCDP responses
Life-cycle and input-output databasesYour licensed factor sets
Carbon accounting toolsYour inventory, if another tool holds it
Reporting toolsThe sustainability statement and its export
Single sign-onRoles by person and category

Design targets for the sample program, and the controls behind them

These are labeled design targets for the sample program, to be measured in your own run. They are goals and carry no promise for your data.

61%

of Scope 3 on supplier data, up from 18% in the sample's FY2023.

Design target, sample data
240

suppliers checked in one cycle: every submission, with no sampling.

Design target, sample data
0

restatements of Scope 3 at assurance, with every figure carrying its method and source.

Design target, sample data

Botminds is SOC 2 Type II audited, with information security managed to ISO 27001. Supplier documents are kept for 10 years in the sample's settings. Records and approvals support your assurance process; the responsibility for the statement stays with your company.

Part C · Are you ready to automate?

Automating supplier Scope 3 data: what weak data costs, what automation returns and how to test it on your own suppliers

You own the number, or build it, or buy from the people who feed it. This part is written for you: what weak supplier data costs today, what automating it could return, whether your team is ready, and what to ask any vendor of Scope 3 software, including us.

17 · What weak data costs

The price of spend estimates and unchecked supplier data: analyst days, audit samples and progress you cannot show

In shortThe hours are the part you can price, and they are modest. The larger costs do not fit a calculator. You cannot show a supplier's real cuts. An auditor's sample can turn into a late rework. A customer asks for the footprint you do not have. Start by measuring the few things below, which takes about a week.

$500,000

a year: the top administrative penalty under California's SB 253. For Scope 3, through 2030, only a failure to file is penalized.16

PwC, updated October 15, 2026
$44,000

a year per entity: California staff's estimate for limited assurance, which commenters called too low.43

Davis Polk, April 7, 2026, on CARB's workshop
2028

the year large drug makers ask suppliers to disclose footprints for their top 10 products. If you sell to them, the request is already written.13

SMI letter, November 21, 2025
Reading and checking fall furthest; the disclosure write-up shrinks least in proportion

Working days for one annual cycle of 240 suppliers, two people

By hand (estimate)With the solution (estimate)
Logging and reading submissions15 days2 days
Matching lines to methods and factors6 days1 day
Checking boundary, period, allocation, range15 days2 days
Writing questions to suppliers5 days1 day
Separating real change from method change3 days0.5 days
Disclosure table, notes and trail6 days2 days

Illustrative · replace with your own numbers · 50 days against 8.5. Neither is a measurement. Time your own next batch, and measure the second column in a pilot.

Show the numbers
StepBy hand (estimate)With the solution (estimate)
Logging and reading submissions15 days2 days
Matching lines to methods and factors6 days1 day
Checking boundary, period, allocation, range15 days2 days
Writing questions to suppliers5 days1 day
Separating real change from method change3 days0.5 days
Disclosure table, notes and trail6 days2 days
No public benchmark for your case. We found no independent figure for hours per supplier, the cost of a Scope 3 restatement, or how much supplier data changes a drug maker's total. A swap's effect depends on your factor set. In the example, one line fell 56%, while another came in above its estimate. Test on your own lines before you tell anyone what to expect.

Timing ten supplier files and tracing ten Scope 3 figures to find your baseline

CostWhere it hidesHow to find your number in a week
Reading timeAn inbox and a spreadsheetTime ten files of mixed type, from opening to a logged figure with its page
Checks you skip"Reviewed by sample"Count submissions received and submissions tested on boundary, year and allocation
Tonnes on moneyThe category totalSplit Category 1 into the four methods. Rank the top 20 spend-based lines
Figures you cannot traceNumbers typed into a slidePick ten figures from last year's statement and time the trace to a document
Hidden method changeThe year-on-year headlineSplit last year's change into real and method. Note how long it takes
Repeat requestsA supplier asked by three peopleCount requests per top supplier last year, across sustainability, quality and procurement
Exposure under the capOne template for all suppliersRead your template against Annex II. Count suppliers with 1,000 employees or fewer

A supplier's real cut you cannot show, and other costs no Scope 3 calculator counts

Real cuts you cannot reportA supplier moved to renewable power, and your estimate did not notice. You may have paid for that in price, and you got no credit for it.
A target you cannot readWhen method and real change are mixed, nobody knows whether you are on track, including you.
Goodwill with suppliersA vague question, asked twice by different people, wears out the people you need next year.
A late audit sampleA figure with no trail in the last week before signing takes the whole team off everything else.
What leaves with your analystWhich supplier always sends the wrong year, and why that factor code was chosen.
18 · Your return

What automating supplier data checks returns: analyst days and audit hours against the tool's cost, for your supplier count

In shortPut in your own numbers. Every default is an assumption to replace. On the defaults, hours alone do not pay for a $100,000 yearly tool at 240 suppliers; they begin to at about 645. For most drug makers the case rests on checking every submission, a trail that holds at assurance, and being able to show suppliers' real cuts. A small supplier list may do well with a better spreadsheet.

Analyst days, audit samples, full coverage: where Scope 3 automation can pay back

Reading and matching

Days off the cycle

Files read and matched by software, with pages attached, and reviewed by a person.

suppliers ÷ 100 × days saved per 100 × 8 × hourly cost
Assurance

Faster trace on each sample

A figure opens to its document, its checks and its approval.

samples × hours saved per sample × hourly cost
Coverage

Every submission tested

Errors found this cycle instead of in next year's restatement.

submissions tested ÷ submissions received
Data quality

Tonnes moved off spend

More of each category rests on something a supplier can change.

tonnes on supplier data ÷ total, by category
Target

Real change, visible

Suppliers' cuts show up, and method moves stay on their own line.

like-for-like change, split from method change
Suppliers

Fewer, better questions

One precise question, citing a page, in place of a repeat questionnaire.

questions per supplier; share answered first time

Suppliers, analyst days and audit samples: your Scope 3 cycle in numbers

No source publishes these inputs. Every default is an assumption, marked illustrative.

Your cycle
Your assurance
The tool
Illustrative yearly value
Supplier cycle today, valued$0
Cycle time saved, valued$0
Assurance tracing saved, valued$0
Hours saved, valued$0
Less the tool's yearly cost$0
Suppliers at which hours cover the tool0

Cycle saved = suppliers ÷ 100 × (days today − days automated) × 8 hours × cost. Tracing saved = samples × (hours today − hours automated) × cost. Suppliers at which hours cover the tool = (tool cost − tracing saved) ÷ cycle saved per supplier. The 21 and 3.5 restate an estimated 50 and 8.5 days for 240 suppliers; neither is a measurement.

19 · Readiness check

How ready your team is for supplier data automation: purchase lines, acceptance rules, a base year policy and a named signer

In shortEight questions, scored 0 to 2, and one for reflection. A low score usually means writing down your acceptance rules and base year policy before buying anything. Your answers stay on this page.

1
Suppliers in the cycle

How many suppliers do you ask for climate data each year?

Why it mattersWith a few dozen, a careful person can read every file. Past that, teams begin to sample.
A strong answer"Over 200, covering about 80% of purchased goods spend, rising each year."
2
Knowing where the tonnes sit

Have you screened all 15 Scope 3 categories and split each by method?

Why it mattersThe GHG Protocol asks you to screen first, because supplier collection takes time and money. Otherwise you chase the wrong suppliers.
A strong answer"Yes, and we can rank the 20 largest spend-based lines."
3
Purchase lines you can match

Can you see kilograms bought, by supplier and material, for last year?

Why it mattersA footprint per kilogram is useless without the kilograms. Spend-only records block the swap.
A strong answer"Our purchase records carry quantity and unit for all direct materials."
4
Written acceptance rules

Do you have a written rule for what makes a supplier figure usable?

Why it mattersSoftware can only apply rules you have stated. Age limit, boundary, allocation and verification threshold are your choices.
A strong answer"Yes: age, boundary, allocation, primary share and verification, approved by the reporting manager."
5
Real change and base year

Do you report method change apart from real change, with a base year policy?

Why it mattersThe Scope 3 Standard calls for a recalculation policy. Without one, every swap blurs your target.
A strong answer"Yes, a written threshold, and last year's statement split the two."
6
Supplier owners and the value-chain cap

Does each top supplier have a named owner, and do you know which ones are protected?

Why it mattersA question needs someone to send it. From 2027, requests past the cap to suppliers with up to 1,000 employees need a notice.
A strong answer"Category managers own them, and we hold a self-declared size for each."
7
Who decides and who signs

Is it agreed who confirms large swaps and who signs each category?

Why it mattersAutomation moves the work to review. A preparer and a separate signer give the auditor what they look for.
A strong answer"The reporting manager confirms above a set size, the head of sustainability signs."
8
Trail for your assurance provider

Could you trace ten figures from last year's statement to documents in a day?

Why it mattersThis is the auditor's question, and a fair test of how much rework sits ahead of you.
A strong answer"Yes, and our provider has agreed what a good trail looks like."
9
If suppliers' real cuts showed in your number · for reflection

If your inventory could show what each large supplier actually did this year, what would you do differently in procurement, and what would have to be true of your data?

Why it mattersYour answer lists the gaps. Each is a job to do, for people or for software.
A strong answerA short, specific list, for example: "add carbon to the category reviews for two API families, get quantities for excipients, and agree an allocation rule with our top ten suppliers."

A low score means writing your acceptance rules before anything else

0–6

Explore

Screen your categories, split Category 1 by method, and write one page of acceptance rules and a base year policy. Those steps improve your next statement with no tool at all.

7–11

Ready to pilot

Take last cycle's submissions, with your hand decisions, and run them again. Score what the software reads and what it holds against what you know now.

12–16

Ready to implement

Plan every category, supplier owner, factor set, role and the assurance file. Agree the trail with your assurance provider before the next cycle opens in July.

20 · Vendors and a pilot

What to ask Scope 3 software about footprints, allocation, the value-chain cap and method change, and a 14-week test

In shortAsk any vendor, including us, to show a held submission as readily as a passed one. Ask how it treats a figure below the estimate and a request to a protected supplier. Then replay last cycle's files against your own decisions, run one batch in parallel, and decide on four numbers.

Questions for any Scope 3 vendor, including us

A

Reading supplier files and citing pages

A1

Show a value, then the page it came from. What happens when a value is missing?

Why it mattersA blank stays a blank. A guessed value is the worst failure here.
Strong answer"Each value opens at its page, and a missing one stops the check."
A2

What did you test extraction on, and what was the error rate on our kind of document?

Why it mattersIndependent rates are scarce. Your own files are the honest test.
Strong answer"Run it on your last cycle and count the errors with us."
B

Plausibility checks on a chemical footprint

B1

Which checks block a swap, and who set them? Can we change them, and is that recorded?

Why it mattersThe thresholds are your method. An auditor will ask about them.
Strong answer"Your settings, versioned, with what each one affected this cycle."
B2

Show a figure far below the estimate. Does it get extra scrutiny or an easy pass?

Why it mattersLower figures are tempting, so they deserve the harder look.
Strong answer"Either direction past your gap triggers a second look."
B3

How do you handle allocated company data for a diversified supplier?

Why it mattersThe GHG Protocol's draft would restrict it. Your layers may shift.
Strong answer"Shown as its own layer, with the key recorded per supplier."
C

Requests to suppliers and the value-chain cap

C1

Who sends messages to suppliers? Show what a person sees before it goes.

Why it mattersSupplier relationships belong to category managers.
Strong answer"A named person reads, edits and sends every one."
C2

Show a request to a supplier with 800 employees. Where is the notice of its right to decline?

Why it mattersFrom financial year 2027 this is a legal duty for CSRD requests.
Strong answer"Our template holds it, and you decide when it applies. Check that with counsel."
D

Method change, base year and the assurance trail

D1

Show how a swap appears on the year-on-year view. Can it reach the reduction target by accident?

Why it mattersThis separation is what makes the number trustworthy.
Strong answer"Its own line, with the target calculated on real change."
D2

Which ESRS version does your table follow, and what happens for FY2027?

Why it mattersE1-6 means something else in the simplified text. A vendor who has not read it will trip you.
Strong answer"The year sets the template, and E1-8 is ready for FY2027."
D3

Can our assurance provider see a figure's trail without a person assembling it?

Why it mattersAssembling trails is where audit weeks go.
Strong answer"Read-only access for a period you set, plus an export."

Replay last cycle's supplier files, then run one batch in parallel

  1. Choose 30 submissions from last cycle: mixed types, some you accepted and some you held, with your decisions recorded.
  2. Write the rules: age, boundary, allocation, primary share, verification, gap, and who confirms.
  3. Connect a purchase extract: one category, with quantities, and your approved factor sets.
  4. Replay and score: compare values read, decisions and questions with your own record.
  5. Decide on four numbers: extraction errors, decisions that differ, days per 100 suppliers, and minutes to trace a figure.
A 14-week pilot ends with one live batch of suppliers compared side by side
Your teamVendor
Trace ten figures; time ten files
Write acceptance rules and base year policy
Connect purchases; load factor sets
Replay 30 past submissions
Score reading and decisions
Clear the supplier letter with counsel
Run one live batch in parallel
Decide with sustainability and procurement
Week 0481214

Illustrative · replace with your own numbers

Show the numbers
ActivityFromTo
Trace ten figures; time ten files02
Write acceptance rules and base year policy14
Connect purchases; load factor sets25
Replay 30 past submissions47
Score reading and decisions68
Clear the supplier letter with counsel69
Run one live batch in parallel813
Decide with sustainability and procurement1314

Reading errors, differing decisions and trace time: how to score a Scope 3 pilot

MeasureHowWhy
Values read correctlyCompare every value and its page with a person's readingA wrong value with a right-looking page is the failure to find
Decisions that differPass or hold, against your past decision. Read each differenceSome differences will be your own past errors
Days per 100 suppliersTimed, including reviewReplaces the illustrative inputs in the calculator
Minutes to trace a figureTen figures, by someone who did not build themThe auditor's test, run early
Questions answered first timeShare of questions answered with what was askedA supplier-side check on whether the question was clear, to track beside the four numbers you decide on
The full working-session questions: 12 more for sustainability, procurement, IT and your assurance provider

Bring the reporting manager, two category managers, IT, privacy and your assurance provider into one room.

E

Your categories, factor sets and thresholds

E1

Which categories are significant, and on what basis?

Why it mattersESRS and the Scope 3 Standard both ask for it, and it sets the work.
Strong answer"A screening, redone every three years or after a major change."
E2

Who approves a factor set, and how do you handle a new version mid-cycle?

Why it mattersA new version is a method change too.
Strong answer"One version per inventory, with changes recorded and explained."
E3

What is significant for base year recalculation?

Why it mattersYou set it, so set it before the swaps.
Strong answer"A written percentage, agreed with the assurance provider."
E4

Are peer ranges available for each modality you buy?

Why it mattersPeptides and small molecules cannot share a range.
Strong answer"Ranges by route family, from our own accepted footprints."
F

Suppliers, contracts and confidentiality

F1

Do supply contracts already require climate data, and do they exceed the cap?

Why it mattersTerms past the limit "shall not be binding" for protected suppliers, for CSRD purposes.
Strong answer"Legal has reviewed the clauses and separated the reasons we ask."
F2

What in a footprint is confidential to the supplier: routes, yields, solvents?

Why it mattersPMI and route details can be trade secrets, and an NDA may limit who reads them.
Strong answer"Access by role, and no supplier data used to train a model."
F3

Who speaks to a supplier that three teams already question?

Why it mattersQuality, procurement and sustainability often ask separately.
Strong answer"The category manager, from one queue."
F4

How will you handle a supplier that declines?

Why it mattersIt may, and your report stays lawful on an estimate.
Strong answer"The estimate stays, the reason is recorded, and we ask again next year."
G

Systems, assurance and security

G1

Does the purchase system hold quantity and unit by line?

Why it mattersWithout it, a footprint has nothing to multiply.
Strong answer"Yes for direct materials; a plan for the rest."
G2

What does your assurance provider need to see, and when?

Why it mattersAgreeing the trail early saves the last-week scramble.
Strong answer"Sampling approach agreed before the cycle opens."
G3

Where is the data held, and for how long?

Why it mattersSupplier contacts are personal data, and retention has to match your policy.
Strong answer"Named regions, stated retention, roles by person."
G4

Does your work touch GMP records?

Why it mattersA carbon inventory is outside GMP. Reusing batch records as a source may raise other controls.
Strong answer"Read-only extracts, with quality consulted."
21 · Questions people ask

Supplier Scope 3 questions answered: primary data, spend-based estimates, ESRS E1, PACT, VSME and restatements

In shortDirect answers to what people search for, each one standing on its own. Status statements are as of November 3, 2026.

What are supplier Scope 3 emissions?

They are the greenhouse gases released by your suppliers in making what you buy, which fall in your Scope 3 inventory, mainly Category 1, purchased goods and services. For drug makers these usually make up the largest part of the footprint. My Green Lab found Scope 3 at 5.4 times Scopes 1 and 2 for public biotech and pharma companies in 2023, driven primarily by purchased goods and services.

What is the difference between spend-based and supplier-specific Scope 3 data?

A spend-based figure multiplies money spent by an average factor for an industry. A supplier-specific figure multiplies the quantity you bought by the supplier's own footprint for that product. Spend data covers everything cheaply, but it moves with price and shows no supplier's action. Supplier data can show real change, provided it passes checks on boundary, year and allocation.

Is supplier data always more accurate than an estimate?

No. The GHG Protocol's Technical Guidance warns that data from a supplier "may actually be less accurate than industry-average data for a particular product", depending on data sources and allocation. Specific data earns its place when you have tested it. That is why teams check a footprint's boundary, year, allocation and range before using it.

Does ESRS E1 still require the percentage of Scope 3 from primary data?

It depends on the year. The 2023 text of ESRS E1 asks for "the percentage of emissions calculated using primary data obtained from suppliers", and it applies to FY2025 and may be chosen for financial years starting in 2026. The simplified standards in Delegated Regulation 2026/1563 apply from financial year 2027, move Scope 3 to E1-8 and drop those words. The GHG Protocol Scope 3 Standard still requires a share per category.

Who is in scope of the CSRD after the Omnibus?

Directive (EU) 2026/470 limits it to companies with more than 1,000 employees and more than EUR 450 million in net turnover, with separate terms for groups and non-EU companies. Member states must transpose it by March 19, 2027. Check your own position with counsel, because companies from the first wave below the thresholds leave scope from financial year 2027, and member states may exempt them for 2025 and 2026.

What is the value-chain cap, and does it stop me asking for a product carbon footprint?

The cap limits what you may require from suppliers with up to 1,000 employees for CSRD reporting, to the datapoints in Annex II of Delegated Regulation 2026/1560. A product footprint is outside that list. You may still ask, but you must say what goes past the limit and that the supplier may decline. The cap applies from financial year 2027. Requests for other purposes, such as due diligence, fall outside the cap.

What is the PACT Methodology?

It is a cross-industry method for calculating and exchanging cradle-to-gate product carbon footprints, published through the World Business Council for Sustainable Development, with version 3 dated April 2025. It sets an allocation order, requires a primary data share, adds a data quality rating from 2027, and lays out a verification roadmap. Its technical specifications let footprints travel as data files between companies.

What is PAS 2090?

PAS 2090:2025 is a publicly available specification of product category rules for life cycle assessments of pharmaceutical products, published November 30, 2025. NHS England, the UK's Office for Life Sciences and a pharmaceutical consortium sponsored it, and BSI facilitated its development. The industry's supplier toolkit points finished pharmaceutical products to it, and chemicals to the PCF Guidelines of Together for Sustainability (TfS).

Should replacing a spend estimate with supplier data count as an emissions reduction?

No. It is a change in how you calculate, so it belongs on its own line, apart from real change such as renewable power or solvent recovery at a supplier. The Scope 3 Standard also calls for a base year recalculation policy, so progress is measured on a consistent method. Showing both lines lets a reader see what moved.

How do you check a chemical supplier's product carbon footprint?

Test the boundary, reference period, allocation and unit first. Then compare the figure with the route's process mass intensity and solvent recovery, with similar routes in your own data, with published ranges for active ingredients, and with the estimate it would replace. Ask for a verification statement above a size you set. Passing shows the figure is plausible, and a person should still decide the large ones.

When does California require Scope 3 reporting?

SB 253 calls for Scope 3 from 2027, and the first report, on Scopes 1 and 2, is due November 10, 2026. Staff at the California Air Resources Board (CARB) previewed five mandatory Scope 3 categories for 2027, including Category 1, and promised a draft rule for 45-day comment in fall 2026; we found no notice as of November 3, 2026. Through 2030, Scope 3 penalties reach only a failure to file, and the Ninth Circuit had not ruled on the pending appeal as of October 23, 2026.

What are the pharma supplier sustainability targets for 2028?

In November 2025, procurement chiefs of the Sustainable Markets Initiative's Health Systems Task Force asked suppliers to disclose Scopes 1, 2 and 3 and footprints or life cycle assessments for their top 10 products by 2028. They also ask for validated science-based targets by 2027, and 80% renewable electricity by 2030. These are customer requests with no force of law, though individual members may set stricter terms.

Can AI read supplier carbon reports reliably?

Software can read a well-formed footprint and save time, but we found no independent error rate for this kind of document, and researchers warn that people over-trust model output. The practical controls are a page behind every value, blanks left blank, plain rules for the checks, and a person deciding the large swaps. Test it on your own past files and count the errors.

Do GMP rules such as draft Annex 22 apply to Scope 3 data?

Not directly. Draft EU GMP Annex 22 addresses AI in GMP applications, and it is still a draft on November 3, 2026, with no Annex 22 in EudraLex Volume 4. A carbon inventory sits outside GMP, as it does outside FDA's January 2025 draft guidance on AI for regulatory decision-making on drugs. The practical test for this work is limited assurance.

22 · One-page summary

Supplier Scope 3 at a glance: seven steps, the rules at November 2026 and 14 terms

Print this page

In shortThe whole guide on one screen: the method, the rules as of November 3, 2026, the readiness bands and the terms.

The method
  1. Screen all 15 categories, and split each by the four methods.
  2. Rank the largest spend-based lines, and name an owner for each supplier.
  3. Write acceptance rules: boundary, age, allocation, primary share, verification, gap.
  4. Read each submission with its page. Leave a missing value blank.
  5. Check against the route, peers, published ranges and the estimate. Hold what fails, and ask a precise question.
  6. Confirm large swaps by a person. File every swap as a method change, and report it apart.
  7. Sign each category, lock it, and give the assurance provider its trail.

Readiness: score 0–2 on eight questions: 0–6 explore · 7–11 pilot · 12–16 implement.

As of November 3, 2026: ESRS 2023 text for FY2025, optional for FY2026 · simplified ESRS in force November 10, 2026, applies from FY2027, Scope 3 in E1-8 · CSRD over 1,000 employees and EUR 450 million, national laws due March 19, 2027 · value-chain cap from FY2027.

Elsewhere: SB 253 first report November 10, 2026, Scope 3 proposed for 2027 · SEC rule stayed, rescission proposed, no final rule found · GHG Protocol revision still a draft, consultation slated for Q2 2027 · SBTi v2 submissions from Q1 2027 · PACT v3 and PAS 2090 published · draft EU GMP Annex 22 not adopted.

14 terms
Scope 3
Indirect emissions outside purchased energy, in 15 categories. Category 1 is purchased goods and services.
CSRD and ESRS
The EU's corporate sustainability reporting law, and the reporting standards under it.
CO2e
Carbon dioxide equivalent, a common unit for all greenhouse gases.
Spend estimate
Money spent times an average factor for an industry.
Product carbon footprint (PCF)
Emissions behind one unit of one product.
Cradle-to-gate
Raw materials to the supplier's site exit.
Allocation
Splitting a process's emissions among its products.
Primary data share
The part of a footprint from measured data.
PMI
Process mass intensity: all inputs per kilogram of product.
Method change
The number moved because the calculation changed.
Base year
The year you track progress against.
Value-chain cap
The limit on what you may require from suppliers with up to 1,000 employees.
VSME
The EU's voluntary reporting standard for smaller companies.
Limited assurance
An auditor's lighter level of review, the level the CSRD requires.
23 · Sources

Sources

Accessed November 3, 2026. Regulatory status statements are as of that date. Where a page would not open, the source line says the wording came from an excerpt.

  1. My Green Lab, The Carbon Impact of Biotech and Pharma, 2024 report (2023 data). mygreenlab.org
  2. GHG Protocol, Technical Guidance for Calculating Scope 3 Emissions, 2013, Category 1 and Box 1.1. ghgprotocol.org
  3. Ingwersen W, Young B, Supply Chain Greenhouse Gas Emission Factors for U.S. Commodities, v1.4.0, October 14, 2025, sheet CO2e, factors without margins, kg CO2e per 2024 US dollar. Dataset for the US EPA's supply chain factors. zenodo.org
  4. Commission Delegated Regulation (EU) 2023/2772, European Sustainability Reporting Standards, ESRS E1, Disclosure Requirement E1-6 and application requirement AR 46(g). publications.europa.eu
  5. Commission Delegated Regulation (EU) 2026/1563 of July 3, 2026, Official Journal, September 21, 2026: Articles 2 and 3; ESRS E1, E1-8 and AR 24; ESRS 1, paragraphs 65, 66, 98 and 99. publications.europa.eu
  6. GHG Protocol, Corporate Value Chain (Scope 3) Accounting and Reporting Standard, 2011: reporting requirements and chapter 9. ghgprotocol.org
  7. GHG Protocol, Scope 3 Standard Revisions: Phase 1 Progress Update, March 2026 (states it is a draft and not a standard). ghgprotocol.org
  8. Directive (EU) 2026/470 of February 24, 2026 (Omnibus I), Official Journal, February 26, 2026: recitals 4, 5, 12, 37, 47; value-chain cap in Article 19a(3) as amended; Article 29f; Article 5 (transposition). publications.europa.eu
  9. Commission Delegated Regulation (EU) 2026/1560 of July 3, 2026, standards for voluntary use, Article 3 and Annex II. publications.europa.eu
  10. Sphera, press release on the 2025 Scope 3 Report, April 29, 2025: 315 sustainability professionals, 18 industries, November 2024 to February 2025. sphera.com
  11. WBCSD, PACT Methodology, version 3, April 2025: summary of guidelines, section 3.3.1.4 on allocation, section 4.2 on data reliability, section 5 on verification (read in the copy at cecodes.org.co). cecodes.org.co
  12. EFPIA, on PAS 2090:2025, published November 30, 2025; article December 10, 2025. efpia.eu
  13. Sustainable Markets Initiative Health Systems Task Force, open letter from Chief Procurement Officers to supplier partners, November 21, 2025. SMI letter
  14. Science Based Targets initiative, Corporate Net-Zero Standard development page, read November 3, 2026. sciencebasedtargets.org
  15. Watershed, on SBTi Corporate Net-Zero Standard version 2, June 12, 2026 (commentary; a vendor). watershed.com
  16. PwC Viewpoint, SB 253 and SB 261, updated October 15, 2026. viewpoint.pwc.com
  17. PwC Viewpoint, California SB 253: CARB rulemaking for 2027 and beyond, updated July 30, 2026. viewpoint.pwc.com
  18. RSM US, on the IAASB's ISSA 5000: periods beginning on or after December 15, 2026. rsmus.com
  19. Commission Delegated Regulation (EU) 2025/1416 of July 11, 2025, phase-in for E1-6 Scope 3 datapoints up to 750 employees. publications.europa.eu
  20. Vinson & Elkins, on the Office of Administrative Law's approval of CARB's initial regulation, October 19, 2026. velaw.com
  21. Jones Day, California climate disclosure countdown, June 2026: Scope 3 misstatement safe harbor and 2027 to 2030 limit. We did not read the statute itself. jonesday.com
  22. California Air Resources Board, SB 253 Listening Session slides, August and September 2026: deadline deferred to November 10; rulemaking package for 45-day comment this fall; proposed board item for the end of 2026. arb.ca.gov
  23. Morgan Lewis, CARB extends SB 253 deadline and previews 2027 reporting rules, August 7, 2026. morganlewis.com
  24. Crowell & Moring, on SB 253 as the November 10 deadline approaches, October 23, 2026. crowell.com
  25. US Securities and Exchange Commission, Rescission of Climate-Related Disclosure Rules, proposed, 91 FR 33296, June 3, 2026, Release 33-11421, comments due August 3, 2026. govinfo.gov
  26. EY, on ISSB's targeted amendments to IFRS S2, January 12, 2026; HSF Kramer, on the final UK Sustainability Reporting Standards, 2026 (we read an excerpt, not the full page, which would not open). ey.com hsfkramer.com
  27. GHG Protocol, Scope 2 Market-based Method Update, October 16, 2026: consolidated public consultation slated for Q2 2027, joint GHG Protocol-ISO Corporate Standard for Q4 2028. ghgprotocol.org
  28. Sustainable Markets Initiative, Supplier Targets Toolkit, 2026. SMI toolkit
  29. Takeda UK, Carbon Reduction Plan 2025, notes on Scope 3 methodology. takeda.com
  30. Kekessie I et al., on process mass intensity in current peptide manufacturing, J Org Chem 2024;89(7):4261-4282, abstract. Most authors work for drug and peptide manufacturers. PubMed
  31. McKinsey & Company, "Decarbonizing API manufacturing: Unpacking the cost and regulatory requirements" (wording from excerpts seen on two dates; we could not open the full page, and its date could not be confirmed). mckinsey.com
  32. ESG Today, on CDP's review of more than 18,700 companies' 2022 responses, March 15, 2023. esgtoday.com
  33. Boston Consulting Group, "From liability to advantage: decarbonizing the supply chain", September 23, 2025, with EcoVadis, which sells supplier ratings; BCG sells related consulting. bcg.com
  34. LMU Munich, on Beck et al., "Addressing data gaps in sustainability reporting", Scientific Data 2025, September 5, 2025. lmu.de
  35. EFRAG, State of Play 2025 report on 656 sustainability statements for reporting year 2024, 2025 (report text only; its dashboard was not read). efrag.org
  36. BSI, NHS England's PAS 2090 pilot use case, 2026. bsigroup.com
  37. NHS England, draft 2028 market insights survey, for testing June 15 to 29, 2026 (we read excerpts, not the full page, which would not open). england.nhs.uk
  38. Directive (EU) 2024/825, recital 12 and Article 4. publications.europa.eu
  39. Draft EU GMP Annex 22, joint consultation of the European Commission and PIC/S, July 7 to October 7, 2025. picscheme.org
  40. European Commission, EudraLex Volume 4, read November 3, 2026: Annex 11 listed at its January 2011 revision and no Annex 22. health.ec.europa.eu
  41. FDA, draft guidance, Considerations for the Use of Artificial Intelligence to Support Regulatory Decision-Making for Drug and Biological Products, January 2025. fda.gov
  42. European Commission, regulatory framework for AI: AI Omnibus, Regulation (EU) 2026/1744, in force July 27, 2026. digital-strategy.ec.europa.eu
  43. Davis Polk, SB 253/261 update on CARB's workshop and proposed rules for 2027, April 7, 2026: limited assurance cost estimate. davispolk.com
Next step

See it on your own supplier files.

Explore the solution, or bring a sample of your supplier footprints, CDP responses and one purchase extract, and we will check them with you, every figure linked to its page.

botminds.ai The complete guide to supplier Scope 3 emissions management · November 2026. Veltara Therapeutics, Kestrel Fine Chemicals, Orvane Glass, Tamberly Excipients, Wexcombe & Pryce, VT-114, every other company, person, product and figure in the example and the screens are fictional. Regulatory status is as of November 3, 2026; these rules have moved often, so check the sources before relying on them. This guide is general information and is not legal or assurance advice.