Reimagining Greenhouse Gas Disclosures
Summary
The Coalition on Materials Emissions Transparency (COMET) argues that current corporate GHG reporting, primarily based on the GHG Protocol, is insufficient for driving decarbonization because it relies on averages and corporate boundaries rather than actionable product-level data. To address this, COMET proposes shifting toward the use of primary data from direct suppliers, implementing fixed boundaries for comparability, and defining product boundaries that incentivize market-driven decarbonization. These principles aim to make Scope 3 emissions visible and traceable, facilitating a transition to zero-carbon production.
Key insights
- Current carbon accounting frameworks often fail to drive decarbonization because they focus on corporate-level reporting and rely on life-cycle inventory databases providing average emissions estimates, which can lead to bias, manipulation, and greenwashing.
- COMET proposes that companies shift from estimating the emissions of other companies to utilizing primary data from direct suppliers and providing quality data to customers to make Scope 3 emissions actionable.
- To enable meaningful comparison between products and companies, COMET recommends using a 'fixed boundary' based on all processes required to make a product, rather than a 'corporate boundary' defined by company ownership.
- Environmental product declarations (EPDs) and product boundaries must be defined to incentivize decarbonization; overly broad definitions can allow companies to claim low-carbon status without making local investments, while overly narrow definitions may limit purchaser choice.
- The proposed principles will form the basis of the COMET Framework, developed in partnership with the United Nations Framework Convention on Climate Change, to provide sector-specific guidance on calculating Scope 1, 2, and 3 emissions.
Cite the original document
- APA
- Cannon, C., & Wright, L. (2022). Reimagining Greenhouse Gas Disclosures. RMI. https://rmi.org/app/uploads/2022/02/reimagining_greenhouse_gas_disclosures.pdf
- Chicago
- Cannon, Charles, and Lachlan Wright. Reimagining Greenhouse Gas Disclosures. RMI, 2022. https://rmi.org/app/uploads/2022/02/reimagining_greenhouse_gas_disclosures.pdf.
- Wikipedia
- {{cite report |last1=Cannon |first1=Charles |last2=Wright |first2=Lachlan |title=Reimagining Greenhouse Gas Disclosures |publisher=RMI |date=January 2022 |url=https://rmi.org/app/uploads/2022/02/reimagining_greenhouse_gas_disclosures.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}
- BibTeX
- @techreport{cannon2022reimagining, author = {Cannon, Charles and Wright, Lachlan}, title = {{Reimagining Greenhouse Gas Disclosures}}, institution = {RMI}, year = {2022}, month = jan, url = {https://rmi.org/app/uploads/2022/02/reimagining_greenhouse_gas_disclosures.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }
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