The methodology for carrying out Greenhouse Gas (GHG) emissions assessments has been updated by the French Environment Agency (ADEME).
This new version, the fifth one, provides new and updated regulatory guidelines. These new guidelines must be taken into account when undertaking a GHG assessment as of 2023.
Emission categories and sub-categories
One of the main changes is a change in emission categories and sub-categories. Previously, 23 regulatory entries (or sub-categories) were divided into three scopes. Now, 22 regulatory entries are divided into six categories.
Scope 1, direct emissions, was renamed as category 1 and scope 2, energy-related indirect emissions, as category 2. Scope three is now divided into 4 categories (categories 3 to 6), respectively indirect emissions from transport, purchased products and sold products, and other indirect emissions.
The former regulatory entry "Purchases of goods or services" is split between the entries "Purchases of goods" and "Purchases of services". In addition, energy-related emissions not included in categories 1 and 2 are to be included in the regulatory entry "Purchases of goods".
Finally, the former entry "Downstream franchises" was removed: franchise-related emissions are to be taken into account as "Other indirect emissions". In some cases, franchises can also be consolidated by the legal entity carrying out the GHG assessment.
Transition Plan
Another key change is that the mandatory action plan is rebranded as a transition plan.
The transition plan should no longer solely focus on actions to be implemented and targets to be reached, but also on the human and financial resources that are considered and provided to achieve these objectives.
Moreover, the transition plan is embedded in long-term strategy. As of the second GHG assessment, a company must review the actions that were indeed implemented in previous years and monitor the set targets. If discrepancies are identified, the company must understand and justify these discrepancies.
Other new requirements
In addition to direct emissions, companies must compute and report significant indirect emissions.
To do so, significance criteria must be defined and selected, along with a justification, by the organisation carrying out a GHG assessment. A magnitude criterion (i.e. at least 80% of indirect emissions taken into account) is mandatory. Other criteria are optional: level of influence, strategic importance and vulnerability, sector-specific guidelines, staff commitment.
The maximum penalty is increased from €1,500 to €10,000 or €20,000 for repeated offences.
Some obligations linked to the definition of the organisational boundary (French NAF codes) are no longer required.