Danish technical paper on establishing a common, freely accessible EU database on GHG
emission factors
European companies are increasingly being required to calculate and measure their environmental footprint and
climate emissions, particularly on greenhouse-gases (GHG), including scope 1, 2 and 3. These calculations may be
used for the purpose of corporate
sustainability
reporting,
resulting
from the Corporate Sustainability Reporting
Directive (CSRD). Yet companies outside the scope of CSRD are also experiencing that calculating their climate
footprint in a transparent, standardised, comparable, and
verifiable way is becoming a ‘license-to-operate’.
Ideally, companies would be able to carry out their calculations based on actual, consistent, and high-quality data
for their concrete activities. Unfortunately, the sources which companies rely on for relevant data e.g., emissions
factors (estimated average values), are often from private actors, non-transparent, not robust,
non-consistent
and
insufficiently updated,
and behind paywalls.
This not only makes results less comparable and reliable but also more
costly for especially SMEs to collect the required data.
We recommend that the European Commission establishes a common, freely accessible EU database
with
authoritative
GHG emission factors, with
high requirements on transparency and credibility and
sufficient coverage
and differentiation on materials, products, and geography
– supplemented with basic guidance on how to apply
the database in corporate GHG calculations.
This can
reduce the administrative burdens for companies in
identifying and collecting the data they require, strengthen the capacity in companies to calculate their climate
emissions and
increase the transparency, reliability, and standardisation of data,
method, and calculations.
The
emission factors should be verified by relevant authorities, making the data authoritative, comparable and
harmonised.
Furthermore, to contribute further to the reduction of the substantial administrative burdens for
companies in collection and handling data for their sustainability reporting, it is key that the emissions factor
database is established with a technical setup that allows for digital and automated requests and use of data from
the database, through close integration with the IT-systems for ESG-data management and reporting, which calls
for collaboration with both companies using the data and vendors of software, IT-infrastructure and ESG-service
providers.
We encourage the Commission to consider establishing a database for emissions factors, possibly by:
•
Establishing
–
as soon as possible
–
an emission factor database
with emission factors for central
corporate emitting activities across industries and regions in the EU
suitable for use by
European
companies' assessment of their carbon footprint
in scope 1, 2 and 3
in accordance with the GHG protocol
and for voluntary use
for their reporting under the Corporate Sustainability Reporting Directive (CSRD).
•
Establishment of the database could be supported through a call for proposals under a suitable funding
scheme
e.g.,
by drawing inspiration from the HorizonEurope call of 2023 regarding transport emission
factors
(HORIZON-CL5-2023-D6-01-08):
https://ec.europa.eu/info/funding-
tenders/opportunities/portal/screen/opportunities/topic-details/horizon-cl5-2023-d6-01-08
•
Ensuring that the common emission factor database adheres to key principles for data sharing, in
particular that data is interoperable and machine-readable, that access is provided through the use of
non-proprietary data formats, standards and protocols without vendor lock-in to enable seamless data
exchange with different it-systems, platforms and organisations.
•
If a regulatory framework for the establishment of the database is needed, a proposal could draw
inspiration from part of the Commission's "CountEmission EU" proposal for transport-related carbon
emissions, COM(2023)441, which among other things proposes to establish a common database of the
emission intensity factors for transport services established at the central EU level (by the European
Environment
Agency):
https://ec.europa.eu/info/law/better-regulation/have-your-
say/initiatives/13217-Count-your-transport-emissions-CountEmissions-EU_en
The Danish Business Authority is available to further discuss the elements proposed. For more information, please
contact:
Jacob Frellesvig ([email protected])
Anders Bomholdt ([email protected])