Disclaimer: New EUDR developments - December 2025
In November 2025, the European Parliament and Council backed key changes to the EU Deforestation Regulation (EUDR), including a 12‑month enforcement delay and simplified obligations based on company size and supply chain role.
Key changes proposed:
These updates are not yet legally binding. A final text will be confirmed through trilogue negotiations and formal publication in the EU’s Official Journal. Until then, the current EUDR regulation and deadlines remain in force.
We continue to monitor developments and will update all guidance as the final law is adopted.
Scope 3 emissions — the indirect greenhouse gas emissions in a company’s value chain — represent the largest part of most companies’ carbon footprints, often accounting for more than 70% of total emissions. Yet they are also the hardest to measure. This article examines the biggest challenges companies face when measuring Scope 3 and practical approaches to overcoming them.
Unlike Scope 1 and 2 emissions (which come from sources your company directly controls or can easily meter), Scope 3 emissions span your entire value chain — upstream through suppliers and raw materials, downstream through customers using your products. This creates several structural challenges:
The most significant challenge for most companies is getting emissions data from suppliers. For purchased goods and services (Scope 3 Category 1) — typically the largest category — the most accurate approach is to use supplier-specific data. But most suppliers don’t calculate or share this data.
Practical approaches: start with spend-based estimates as a baseline; identify your top 10–20 highest-emission suppliers and engage them directly; use the GHG Protocol’s hybrid approach to combine spend-based for most categories with supplier-specific for material ones.
Spend-based calculations use industry-average emission factors that may not reflect your specific supply chain. Activity-based data requires manual collection across many sources. Supplier-specific data requires third-party verification. Choosing the right methodology for each category and applying it consistently is a significant analytical challenge.
Scope 3 data comes from across your organization — procurement (Category 1), HR and travel (Category 6), logistics (Category 4), facilities (Category 5). Getting consistent, clean data from these functions requires internal coordination that many sustainability teams lack the authority to enforce.
Under CSRD, your Scope 3 disclosures will go to limited assurance. This raises the bar significantly compared to voluntary reporting — every figure needs a traceable source and a documented methodology. The data quality standards required for assurance are substantially higher than most companies’ current practices.
Coolset’s carbon accounting platform supports the full spectrum of Scope 3 calculation methods — from spend-based estimates to activity-based and supplier-specific data — in a single system. The platform automatically identifies emission hotspots, supports supplier data requests, and maintains the audit trail needed for CSRD assurance. Book a demo to see how it works.
Measure Scope 1, 2 and 3 according to the Greenhouse Gas Protocol methodology with Coolset's decarbonization platform.

This free compliance checker scans your packaging documentation and maps it against mandatory PPWR data requirements, giving you a clear view of your compliance status. Get actionable insights on documentation gaps before they become compliance issues.
Measure Scope 1, 2 and 3 according to the Greenhouse Gas Protocol methodology with Coolset's decarbonization platform.
