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Eligibility of Facility Relocation or Nearshoring Costs

Facility relocation and nearshoring costs may be eligible as a Value Chain Abatement (VCA) project when the move is expected to reduce operational or supply chain emissions. A fixed 10% of direct relocation costs are eligible under Tier 5 of the multi-purpose expenditure guidance.

This article defines what a qualifying relocation is and which types of costs count. The guidance applies to the relocation, consolidation or nearshoring of warehouses, distribution centers, manufacturing sites and other operational facilities, whether owned or leased by the brand. It covers moves within a country and moves that bring production or storage closer to the brand's primary markets or suppliers.

Eligibility

Relocation costs qualify when the move is expected to reduce emissions from the brand's operations or supply chain. To be eligible, a relocation must meet all of the following conditions:

  1. Qualifying pathway. The move is expected to reduce emissions through at least one of the pathways described below.

  2. Within the brand's footprint. The affected emissions fall within the brand's measured cradle-to-customer inventory.

A relocation must be expected to reduce emissions through one or more of the pathways below.

Pathway

What qualifies

Typical emissions affected

Shorter transport routes

Moving closer to suppliers, customers or ports to cut tonne-kilometers, or consolidating sites to remove intermediate legs

Scope 3 upstream and downstream transportation and distribution

Low-carbon transport fuel

A new site that gives access to rail, short-sea shipping, or carriers using renewable diesel, biomethane or other low-carbon fuels, or that shifts freight away from air

Scope 3 transportation; Scope 1 for owned fleets

Efficiency and electrification

A building with better insulation, efficient HVAC and lighting, or heat pumps; an electrified process; or charging infrastructure that lets the fleet or yard equipment run on electricity

Scope 1 fuel combustion; Scope 2 electricity; Scope 3 transportation

Renewable energy generation

A site that allows on-site solar, wind or geothermal, or that is served by a grid or utility tariff with a materially lower emission factor

Scope 2 electricity; Scope 1 where generation replaces on-site fuel

Employee commuting

A site closer to where employees live, or with access to public transit, cycling infrastructure or workplace EV charging, that reduces car commuting

Scope 3 employee commuting

Business travel

A site near key suppliers, customers or other company sites that reduces the need for flights and long-distance travel

Scope 3 business travel

Low-GWP refrigerants

Cold storage, refrigeration or HVAC at the new site that uses low-global-warming-potential refrigerants in place of high-GWP systems at the old site

Scope 1 fugitive emissions

Nearshoring, meaning moving production or storage closer to the brand's main markets, will usually qualify under the shorter-routes pathway and often under the low-carbon fuel pathway, because it shortens or removes ocean and air freight legs.

Boundaries

Furthermore, two key principles set the limits of what counts.

  • Additionality: Only costs caused by the move are eligible. Costs the brand would have incurred anyway, such as routine replacement of equipment at end of life, are not.

  • Leakage: A move that shifts an emitting activity to a supplier, contractor or another site where it continues unchanged does not count as a reduction pathway.

Eligible and ineligible costs

Only the direct, one-time costs of carrying out the relocation are eligible under Tier 5. Ongoing operating costs at the new site, and costs the brand would have incurred without the move, are not. Equipment and renewable generation added at the new site are not Tier 5 costs; they are weighted by their own tier.

Cost category

Eligible

Notes

Moving equipment, inventory and fixtures

Yes

Freight, rigging, packing and temporary storage during the move

Decommissioning the old site

Yes

Dismantling, removal and site restoration required by the lease or permit

Fit-out of the new site

Yes

Installation and commissioning of relocated equipment; new efficient or electrified systems are weighted by their own tier

Lease break or early termination fees

Yes

Where directly caused by the relocation

Project management and engineering studies

Yes

Planning and coordination of the move; an emissions assessment for the move falls under OC instead

Purchase price of buildings

Yes

Where the building itself delivers a qualifying pathway, such as a high-efficiency envelope, all-electric systems or on-site renewable generation.

Ongoing rent, utilities and staffing at the new site

No

Operating costs, not relocation costs

Severance, recruitment and relocation of staff

No

Not linked to emissions outcomes

Routine replacement of equipment at end of life

No

Would have occurred without the move

Where a cost serves both qualifying and non-qualifying purposes, brands should allocate it by a reasonable, documented method, such as floor area or share of output, and claim only the qualifying share.

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