Measuring Scope 3 Emissions Is Complex

The data dilemma behind decarbonization

As global climate regulations tighten and investor scrutiny rises, companies are under mounting pressure to quantify and disclose the carbon footprint of their products. Product carbon footprint (PCF) data is essential for setting science-based targets, complying with regulations and demonstrating climate leadership. Yet, despite its importance, collecting accurate PCF data remains one of the most persistent and complex challenges in corporate sustainability.

According to the Greenhouse Gas (GHG) Protocol, 83% of companies struggle to access accurate emissions data, particularly for Scope 3 emissions, which often represent the majority of a company’s total footprint.^[1] These indirect emissions — spanning upstream suppliers to downstream product use — are difficult to measure because they lie outside a company’s direct control. The result is a data landscape riddled with gaps, inconsistencies and inefficiencies.

Why Scope 3 is so hard to measure

Scope 3 spans 15 categories — from purchased goods and services to transportation, waste and product use. Unlike Scope 1 and 2, these emissions fall outside a company’s direct control and require collaboration across the value chain, often with the majority of emissions originating from suppliers.

Most suppliers lack incentives, tools or expertise to measure their own emissions.^[2] Even when data is available, it’s often inconsistent or incomplete. Suppliers may use outdated methodologies, rely on estimates or omit key categories, like transportation or waste. For companies with global supply chains, this creates a fragmented picture that’s difficult to reconcile and compare.

Verdantix reports that Scope 3 emissions typically account for over 70% of an organization’s total carbon footprint, making them a crucial element of any successful net zero strategy.^[3] Yet, accurately measuring and managing these emissions throughout the value chain remains a complex challenge for many sustainability leaders.

The cost of inaccurate emissions data

Poor PCF data isn’t just a reporting issue — it’s a strategic liability. According to PricewaterhouseCoopers (PwC), while 82% of CEOs say they’ve taken steps to reduce their carbon footprint, only 34% trust the accuracy of their emissions data.^[4] In the context of carbon accounting, inaccurate data can lead to flawed reduction strategies, regulatory penalties and reputational damage.

What’s at stake:

• Financial risk
  Inaccurate emissions data can lead to flawed reduction strategies, regulatory penalties and missed cost-saving opportunities. It also slows down reporting cycles and complicates audit readiness, increasing compliance costs.
• Operational risk
  Low-quality data undermines efforts to embed sustainability into core business functions. It prevents teams from integrating emissions insights into product design, procurement decisions and supplier negotiations. This creates friction between sustainability and operational teams, making it harder to scale initiatives.
• Reputational risk
  Without reliable data, sustainability remains a siloed initiative rather than a strategic driver. Companies may face public scrutiny for greenwashing or failing to meet stated goals, damaging brand trust and stakeholder confidence.
• Market access risk
  Investors and customers are increasingly demanding transparency. Companies that cannot provide credible emissions data risk losing access to capital, falling behind competitors and missing out on sustainability-driven market opportunities.

Why data quality matters more than ever

One of the most overlooked challenges in carbon footprinting is the reliance on generic emissions factors and proxy data. Many organizations default to spend-based estimates or industry averages when calculating Scope 3 emissions. While these methods offer a quick starting point, they lack the specificity needed for meaningful action and can undermine long-term strategies.

Spend-based data assumes a linear relationship between cost and emissions, which often doesn’t hold true. A $1,000 purchase from a low-carbon supplier may have a vastly different footprint than the same spend with a high-emissions vendor. Similarly, industry averages obscure the nuances of individual supply chains, masking hot spot emissions and making it difficult to prioritize interventions.

This lack of granularity has real consequences. It limits the ability to embed sustainability into day-to-day operations — whether it’s selecting lower-impact materials, redesigning products or negotiating with suppliers. Teams across procurement, product development and operations are left without the insights they need to make climate-smart decisions.

Moreover, as sustainability reporting becomes more integrated with financial disclosures, the stakes are rising. Investors, regulators and rating agencies are scrutinizing not just what companies report — but how they calculate it. Without high-quality, supplier-specific data, organizations risk falling short of compliance requirements and losing credibility with stakeholders.

Companies need accurate and actionable data to operationalize sustainability effectively. That means moving beyond proxies and averages  toward real, verified emissions data that can inform strategy, guide investments and drive measurable impact.

What companies can do

1. Prioritize high-impact categories

   Not all Scope 3 categories contribute equally to a company’s carbon footprint. Purchased goods and services, transportation and product use often represent the largest emissions sources. By focusing on these high-impact areas first, companies can accelerate progress and maximize the return on their data collection efforts. Sustainability advisory services can support organizations in conducting materiality assessments to identify which categories matter most, allocating resources strategically and aligning efforts with business goals.

2. Engage suppliers proactively

   Supplier engagement is essential for improving data quality and building trust across the value chain. Rather than simply requesting data, leading companies are investing in supplier enablement — offering training, tools and incentives to help partners measure and report emissions accurately. Developing supplier engagement strategies — such as onboarding programs, data-sharing frameworks and collaborative decarbonization initiatives — can significantly improve transparency and strengthen long-term supplier relationships.

3. Standardize methodologies

   Consistency is key to credible carbon accounting. Using established frameworks like the GHG Protocol, ISO 14067^[5] and the Together for Sustainability Product Carbon Footprint Guideline (TfS PCF Guideline)^[6] helps align emissions data using comparable assumptions and boundaries. Applying these standards across complex product portfolios and supply chains reduces the risk of misreporting, simplifies verification, and enables benchmarking across business units and industry peers. It also helps internal teams build a common language and approach to sustainability data.

4. Invest in technology and integration

   Manual processes and disconnected systems are major barriers to accurate and timely PCF reporting. To overcome these challenges, companies are increasingly turning to intelligent software platforms that automate data collection, reformat supplier inputs and validate emissions data against trusted databases. These integrated technologies work seamlessly with existing enterprise resource planning (ERP), product life cycle management (PLM) and procurement systems, enabling sustainability teams to work within familiar workflows while gaining access to high-quality carbon data.

Advanced platforms powered by artificial intelligence (AI) can extract and standardize product information from diverse file formats — such as bills of materials (BOMs) in PDFs, spreadsheets or documents — reducing the burden on suppliers and accelerating data readiness. Smart validation features flag missing or inconsistent data, offer benchmarking against industry norms, and help build confidence in the results. Establishing a cross-functional committee to guide technology selection, implementation and change management helps align the approach with organizational needs and drives measurable impact.

With the right technology, reporting becomes just the beginning. It empowers teams to embed sustainability into every layer of product development — from how products are designed to how materials are sourced and operations are run. Carbon data shifts from being a regulatory checkbox to a catalyst for smarter decisions, bold innovation and long-term impact.

From reporting to real impact

Ultimately, collecting PCF data allows companies to move beyond regulatory compliance and begin embedding sustainability into the core of their operations. When companies invest in accurate, actionable data, they unlock the ability to operationalize sustainability across functions. Product teams can design with lower-impact materials. Procurement can prioritize suppliers with verified emissions reductions. Finance can model the cost of carbon and align budgets with climate targets.

This shift reframes PCF data from a backward-looking disclosure into a forward-looking capability for innovation, risk management and resilience.

It allows organizations to move beyond static disclosures and toward dynamic decision-making — where carbon data informs everyday choices. The payoff is clear: Better data leads to smarter operations, stronger stakeholder trust and long-term competitive advantage.

How UL Solutions helps you solve these challenges

By leveraging our software and advisory services, you can help turn carbon complexity into clarity — and position your business to lead in low-carbon innovation.

ULTRUS™ Product Sustainability software combines AI-powered BOM processing, automated product emissions calculations and seamless supplier engagement to streamline PCF reporting and unlock actionable insights. It integrates with existing systems to reduce manual effort, improve data accuracy and accelerate sustainability decision-making. Paired with our sustainability advisory services, organizations gain expert guidance on standardizing methodologies, validating data and aligning PCF strategies with regulatory and decarbonization goals.

Sources:

1. GHG Protocol: Data Access Challenges
2. GEP: Scope 3 Emissions Data Collection Challenges
3. Verdantix: Net Zero Strategy & Scope 3 Emissions
4. PwC. CFO’s playbook for sustainability strategies
5. ISO. ISO 14067: Greenhouse gases — Carbon footprint of products — Requirements and guidelines for quantification.
6. Together for Sustainability (TfS). Product Carbon Footprint Guideline.

Footnotes:

• GHG Protocol: The most widely used global standard for measuring and managing greenhouse gas emissions across Scope 1, 2 and 3. Developed by the World Resources Institute (WRI) and the World Business Council for Sustainable Development (WBCSD), it provides comprehensive guidance for corporate, product and value chain emissions accounting. Source: GHG Protocol
• ISO 14067: An international standard that outlines principles and requirements for quantifying and reporting the carbon footprint of products (CFP), based on life cycle assessment (LCA) methodologies. It focuses specifically on climate change impacts and is aligned with ISO 14040 and ISO 14044. Source: ISO
• TfS PCF Guideline: Developed by the Together for Sustainability initiative, this industry-specific guideline provides a harmonized method for calculating Product Carbon Footprints (PCFs), particularly for the chemical sector. It bridges gaps between product-level and corporate Scope 3.1 (Purchased Goods & Services) reporting. Source: TfS Initiative