Scope 3 Emissions for Consumer Goods Suppliers
Whether you’re a consumer goods manufacturer, a branded supplier, or a private-label producer, Scope 3 emissions are now one of the most common data requests from retail customers across Europe. Some organisations report directly under CSRD; others use VSME voluntarily—but retailers increasingly expect suppliers to contribute emissions data either way.
For small and growing businesses, Scope 3 can feel abstract and technical. The terminology is unfamiliar, the calculations seem complex, and requests often arrive without clear guidance. In reality, retailers are usually looking for reasonable estimates, clear assumptions, and consistency over time.
This guide explains how consumer goods suppliers can calculate and report Scope 3 emissions in a proportionate, practical way, with a focus on upstream raw materials and downstream product use and disposal.
Why Retailers Ask for Scope 3 Data
Under CSRD, retailers must disclose greenhouse gas emissions across their entire value chain—not just their own stores and warehouses. For most consumer goods businesses, the majority of emissions sit in Scope 3.
Retailers rely on supplier data to support:
- Category 1: Purchased goods and services
- Category 12: End-of-life treatment of sold products
- Broader value chain risk and transition planning
This is part of wider CSRD supplier requirements that now affect many SMEs, even when they are not directly in scope.
What “Scope 3” Means for Consumer Goods Suppliers
Scope 3 covers indirect emissions that occur outside your own operations. For consumer goods suppliers, the most relevant categories are usually:
Upstream Emissions (Before Your Factory)
These often represent the largest share:
- Raw material production (e.g. plastics, paper, food ingredients)
- Packaging materials
- Transport from suppliers
Retailers typically ask for emissions linked to what they buy from you, not your entire corporate footprint.
Downstream Emissions (After Sale)
Depending on the product, this may include:
- Energy or water used during product use
- Disposal or recycling of packaging and products
For many fast-moving consumer goods, downstream emissions are simpler than they sound and can be estimated using standard assumptions.
What Retailers Actually Expect From SMEs
Despite the complexity of Scope 3 in theory, most retailers do not expect SMEs to perform full lifecycle assessments.
In practice, they look for:
- A clear calculation method
- Credible emission factors
- Transparent assumptions
- Year-on-year consistency
This aligns with proportionality principles embedded in CSRD and ESRS guidance.
Simplified Calculation Methods That Work
Method 1: Spend-Based Estimates (Common for Raw Materials)
This method uses:
- Spend on a material or input (€)
- An average emission factor (kg CO₂e / €)
It is widely accepted when supplier-specific data is unavailable and is often the fastest way to respond to first-time requests.
Method 2: Mass-Based Estimates (Preferred Where Possible)
This method uses:
- Quantity of material (kg or tonnes)
- Emission factor per unit (kg CO₂e / kg)
For consumer goods suppliers with stable formulations, this approach is more accurate and easier to repeat annually.
Method 3: Supplier-Specific Data (Optional)
If some upstream suppliers provide emissions data, you can integrate it selectively. Retailers do not expect full coverage—partial improvement is normal.
Emission Factor Sources Retailers Recognise
Retailers rarely mandate a single database. Commonly accepted sources include:
- National environmental agencies
- Industry-average datasets
- Public lifecycle databases referenced by ESRS
What matters is documenting which source you used and why. This supports credibility under energy and GHG disclosures.
Example: Raw Material Scope 3 for a Consumer Product
Product: Household cleaning liquid Key inputs: Plastic bottle, chemical formulation
A typical SME response might include:
- Annual volume of bottles purchased
- Average weight per bottle
- Emission factor for plastic packaging
- Short explanation of data source and assumptions
Retailers usually accept this level of detail without further breakdown.
Downstream: Product Use and Disposal
Product Use
If products require energy or water (e.g. detergents, appliances):
- Use average consumer-use assumptions
- Apply standard energy emission factors
- Clearly state assumptions
If products do not consume energy, say so explicitly.
End-of-Life and Packaging Disposal
Retailers often ask:
- Is packaging recyclable?
- What material mix is used?
- Are EPR obligations met?
You can usually link this to existing packaging documentation and waste data, rather than creating new calculations.
Linking Scope 3 to Value Chain Workers
Although emissions are environmental, Scope 3 reporting under CSRD connects closely to workers in the value chain.
Retailers may cross-check:
- High-emission materials
- High-risk sourcing regions
- Labour conditions at key suppliers
This is why clear scope explanations and value chain transparency matter, as described in workers in the value chain.
How to Respond to Retailer Data Requests
When retailers request Scope 3 data, a strong SME response usually includes:
- A short description of the calculation method
- A table with headline numbers
- Assumptions and limitations
- Planned improvements (if any)
Avoid overly technical language. Clarity builds trust.
Frequently Asked Questions
Do consumer goods suppliers have to calculate full Scope 3 emissions?
No. Retailers usually ask for emissions linked to the products they buy from you, not your full corporate Scope 3 footprint. Proportionate estimates are widely accepted.
Are estimates acceptable for Scope 3 reporting?
Yes. Estimates using recognised emission factors are standard practice for SMEs. What matters is consistency and transparency.
How often should Scope 3 data be updated?
Most retailers expect annual updates. If inputs or volumes change significantly, you may be asked for interim updates.
Can Scope 3 be managed without consultants?
Yes. Many SMEs calculate Scope 3 internally using basic data, public emission factors, and structured data collection processes.
Key Terms
- Scope 3 Emissions – Indirect emissions across the value chain
- Emission Factor – Coefficient used to estimate emissions per unit
- CSRD – Corporate Sustainability Reporting Directive
- ESRS – European Sustainability Reporting Standards
- Value Chain – Upstream and downstream business relationships
Conclusion and Next Steps
For consumer goods suppliers, Scope 3 emissions reporting is becoming a routine commercial requirement rather than a technical exercise. Retailers are looking for reasonable, repeatable estimates—not perfection.
By focusing on key materials, using recognised emission factors, and documenting assumptions clearly, small and growing businesses can respond confidently to Scope 3 requests. With a clear structure and consistent effort, Scope 3 reporting becomes manageable—and supports stronger relationships with retail customers in a CSRD-driven market.