Scope 3 accounting starts asking transport to be measured.
The GHG Protocol Scope 3 standard is revising its accounting rules. It doesn’t target a single category — it reworks the whole rulebook — but several of those rules land especially hard on transport data. Below are the public proposals (Series A·B·C) and what they imply for transport (Scope 3 categories 4 and 9).
Transport lives in categories 4 and 9.
In Scope 3, transport is upstream transport (category 4) and downstream transport (category 9). This revision reworks the accounting rules across the board — data quality (how to trust), boundary setting (how much to include), and investment redefinition — and those rules squarely target the "spend-based estimate" habit in transport.
How do you trust an emissions figure?
The direction is to make it transparent how much spend-based estimation is mixed in.
Mandatory disclosure by data type
Disclose Scope 3 emissions split by data-type grade (primary data / activity-based / spend-based). The point is to reveal how much spend-based estimation is mixed in.
Mandatory verification disclosure
Verified companies must state "fully / partially / not verified". Alignment with ISO 14065 is under review.
Data-quality recommendations
Use high-completeness factors (≤5% cutoff), reflect trade in regional factors, and set primary-data-ratio and improvement targets.
Limit allocation of diversified suppliers’ company-wide emissions
Restrict splitting a "diversified" supplier’s company-wide emissions by spend ratio. Only homogeneous suppliers allowed; others need product/facility-level data.
How much emissions do you include?
The direction: "it was too small to count" no longer holds.
95% completeness rule
For conformance, calculate and report at least 95% of required Scope 3 emissions. Exclusions capped at 5%. Aligned with SBTi/CDP’s 5%.
100% quantification to justify exclusion
To prove exclusions stay within 5%, quantitatively assess 100% of required emissions annually. Simplified methods (hotspot analysis) allowed.
Clarified hotspot-analysis definition
Any calculation/estimation method may be used for hotspot analysis.
Exclusion disclosure, justification, notation
Excluding required emissions requires disclosure and justification; standard notation ("NA"/"X") introduced. A de minimis concept is introduced but kept within the 5% cap.
Separate reporting of required vs optional
Report required emissions and optional emissions separately.
New category 16 — facilitated activities
A category for "facilitated activities" not caught by the existing 15 — activities you neither buy/sell nor own but earn transaction revenue from (brokerage, licensing, financial services). Mostly optional (oil & gas distribution is required).
Category 15 is narrowed to financed emissions.
Category 15 is narrowed to "financed emissions" — investments only — while other financial services such as insurance/underwriting move to category 16.
- Clarified that category 15 applies to all companies (not only asset managers).
- Include Scope 1·2·3 of the investee within the boundary.
- Include debt in the denominator for share-proportional calculation (PCAF-aligned).
Four places the rules land hard on transport.
A whole-rulebook revision — yet it touches transport data especially sharply.
Spend-based estimation gets branded lowest-grade
A1Many shippers handle categories 4·9 as spend-based — "we spent X on freight, times an emission factor". The proposal requires disclosure split by data-type grade, and spend-based is explicitly labeled the lowest grade. Transport emissions get publicly shown as "the item we counted most poorly".
3PLs and forwarders can’t use company-wide averages
A83PLs and forwarders are mostly "diversified" operators mixing many shippers and modes. Until now their company-wide emissions could be split by volume/spend ratio, but A8 restricts this. This is the key pressure point of the transport cascade.
You can’t leave transport out as "negligible"
B1·B2Under the 95% completeness rule, even items you want to exclude must first be quantified to prove they’re within 5%. "Transport is small, so we left it out" no longer works — to exclude it you have to compute it first. For manufacturers/distributors, transport is far from negligible, so it is effectively forced in.
Verification status becomes public
A2With "fully / partially / not verified" required, unverified transport data shows up as "not verified".
Under this revision, measurement becomes a grade.
The revision converges on one thing — measured activity data, not spend or averages, in a verifiable form. LCS measures driving, fuel, and load at the vehicle every second with Carbon DTG, and calculates & reports to ISO 14083 with the LCS standard. Not lowest-grade spend-based, but verifiable primary data at the shipment and leg level.
Raise your transport data’s grade, starting now?
We’ll design the path from spend-based to measured primary data for your transport emissions in a 30-minute assessment.
This page summarizes public GHG Protocol Scope 3 revision proposals (Technical Working Group) and per-proposal public survey support. Final standard wording and effective dates are not confirmed; the source text prevails once in force.