Since its creation, Value Change Initiative (VCI), together with its members, has been dedicated to developing sector-specific guidance that empowers companies to collaboratively tackle and reduce their Scope 3 emissions. As the sector rapidly evolves, with new Scope 3 standards emerging, and existing ones being refined by organisations such as the Science Based Targets initiative, GHG Protocol, and Verra, we’re pleased to see that VCI’s work has been a key contributor to these advancements.

We are proud to see that our pioneering work is increasingly being recognised and integrated into the development of these standards, helping to accelerate the transition to Net Zero across sectors. VCI’s primary goal is the creation of a harmonised and actionable framework for Scope 3, enabling companies to implement effective strategies on the ground.

The Advanced and Indirect Mitigation (AIM) Platform has recently incorporated key concepts developed by VCI into its AIM Platform Criteria, which they have opened for stakeholder consultation. The 11 criteria aim to enhance the integrity of value chain emissions management by guiding organisations to find adequate ways to mitigate emissions within their value chains through targeted interventions.

The draft criteria lay out crucial conditions for associating interventions with an organisation’s value chain, fostering pragmatic approaches to GHG mitigation while ensuring credible climate impact claims. The next step for the AIM Platform is to follow up with detailed requirements for assurance.

Convergence with the VCI guidance

Several key concepts developed by the VCI are prominently featured in the draft version of the 11 Criteria published by AIM. Notably, the Supply Shed concept as developed in the VCI Value Chain Interventions Guidance 1.1, which we’ve further expanded in our Working Groups in the Food & Agriculture and Apparel & Footwear sectors, as well as our foundational work on co-claiming, detailed in our May 2024 guidance, Building the case for value chain interventions: enabling credible co-claiming of impact and investments.

The concept of Supply Shed is instrumental in enabling credible Scope 3 interventions, even when traceability is challenging. By grouping together suppliers who provide functionally equivalent goods or services within a defined market, it offers a reasonable level of granularity while acknowledging the on-the-ground realities of value chain traceability. The Supply Shed concept is currently being refined by our Food & Agriculture Working Group to better align with practical implementation needs as well as with the sourcing region concept in the GHG Protocol’s upcoming Land Sector and Removals Guidance. Co-claiming, another key concept mentioned by AIM, is particularly significant in the context of Scope 3, as it involves emissions of another entity’s Scope 1 or Scope 2. Since most Scope 3 interventions require collaboration between value chain partners, it raises important questions about how multiple companies can credibly claim the resulting climate impacts. Our co-claiming guidance Building the case for value chain interventions introduces scenarios for establishing the “right to claim” in shared interventions or investments, and offers guidance on the equitable attribution of the mitigation outcomes.

Areas we have requested further clarifications

As can be expected for a standard under development, we found there are still open questions that need to be clarified. Below you can find a summary of our key feedback.

Sector-specific considerations

We believe it is essential to consider and accommodate sectorial differences, as each sector may have unique value chain structures or legal frameworks. Creating sector-specific guidance or allowing for sector-based variations is crucial in several instances:

• – Setting thresholds for interventions: Given the distinct transition pathways across sectors, uniform thresholds may not be appropriate, as proposed in Criterion 1. For example, differentiation between land-based and non-land-based sectors could be necessary.
• – Sector-specific accounting challenges: While we support Criterion 10’s focus on establishing a link between GHG emission reductions to the technologies or processes that cause them, sector-specific challenges might impact the feasibility. For instance, in the Apparel & Footwear sector, limited access to open data and supplier capabilities complicate the feasibility of any potential “shadow accounting.”
• – Verification: Instead of universal verification and assurance requirements, we recommend enforcing criteria tailored for each sector.

Clarifying the difference between ownership and right to report

Criterion 4 stipulates that a reporting organisation must either own or be allocated to the emission reductions associated with an intervention.  We suggest expanding the concept of “ownership” to reflect the “right to report.” At VCI we emphasise “proof of sourcing” as a critical factor in demonstrating active involvement in a specific Supply Shed. Organisations reporting emission factor changes and reductions should own those reductions, while those co-claiming must have the “right to report” or provide “proof of sourcing” to share the mitigation outcomes. This approach ensures transparent, fair and credible reporting aligned with established guidelines.

Our latest co-claiming guidance Building the case for value chain interventions provides detailed criteria to ensure integrity in co-claiming, particularly around causality, rights to report, eligibility through proof of sourcing, value-driven impact creation, and transferability of impact.

Consideration of Impact Layers in co-claiming

Criterion 5 addresses multiple organisations claiming the same emission reductions from an intervention. It requires that “an equivalent quantity of an overlapping value chain component would have been included in each organisation’s emission report.” It also stipulates that each organisation must either own or be allocated the right to claim and report these emission reductions.

We believe this definition requires clarification, particularly regarding whether emissions are addressed on different “Impact Layers” or value chain stages, also known as “vertical co-claiming,” as recognised by the GHG Protocol Corporate Scope 3 Standard.

We recommend including a safeguard to ensure that 100% of emissions can be claimed in each Impact Layer without exceeding this total. This is consistent with our co-claiming guidance Building the case for value chain interventions. Additionally, we maintain that interventions subject to co-claiming should be registered in a public registry to prevent double counting and ensure transparency.

Our guidance outlines actionable criteria to safeguard integrity in co-claiming, including eligibility through proof of sourcing and maintaining quantitative, functional, temporal, and Supply Shed consistency of interventions.

Setting clear temporal boundaries for intervention implementation and reporting

Criterion 7 proposes a 24-months temporal boundary of reporting an intervention. While we agree with the need for temporal boundaries, we emphasise that more detailed specifications are necessary to ensure a credible progression of implementing, reporting and claiming the outcomes of an intervention.

Further elaboration on the temporal boundary should include:

• – When the intervention was initiated,
• – When the impact occurred,
• – When the intervention was verified,
• – When the impact was registered, and
• – When the impact is claimed.

VCI’s innovative work feeds into standard development

Our work is uniquely positioned to contribute to the innovation and development of Scope 3 standards.The VCI, with over 100 members from corporates, civil society, and internationally recognised frameworks, aligns on practical Scope 3 challenges and solutions. We look forward to continuing our collaboration with standard-setting organisations to incorporate our insights into establishing Scope 3 guidance that helps companies achieve their climate ambitions.

You can find our full guidance documents here.