Certificates from Another Market and a Base Year That Cannot Stay Still

Almost certainly not defensible as zero.

Contractual instruments used for the market-based method must convey the environmental attributes of the electricity, be tracked and redeemed on behalf of the reporting company, be as close as practicable to the reporting period, and - critically - be sourced from the same market in which the reporting company operates. Unbundled certificates from a wind portfolio in a country where the group has no operations fail the market-boundary criterion: the group has no load, no operations and no market connection there, so it cannot claim that generation as its own.

What to do:

• Report the location-based figure (21,400 tCO2e) prominently.
• Recalculate the market-based figure using residual-mix or supplier-specific emission factors for the electricity actually consumed, rather than zero.
• If a market-based claim is wanted, procure instruments in the markets where the breweries operate - sleeved power purchase agreements, on-site generation, or same-market certificates with a documented chain of custody.
• Disclose the criteria assessment and the reason the certificates were rejected.

Reporting zero alongside a "100% renewable electricity" claim is a greenwashing exposure and, in the EU, potentially an unfair commercial practice. The €0.40/MWh price is itself a warning sign about the vintage and quality of the instruments.

Keeping the base year unchanged is the wrong default.

Base years are recalculated for structural changes (acquisitions, divestments, mergers), methodology changes and significant errors, where the cumulative effect exceeds the significance threshold the company has set - 5% is common.

• Divestment of the maltings (9% of base-year emissions). 9% on its own exceeds a 5% threshold. Recalculate 2019 to exclude the maltings, so the 2030 target compares like with like. Otherwise the group books a 9% "reduction" that is purely a boundary change.
• Acquisition (4%). If the soft-drinks producer existed in 2019 and data is available, add it to the base year. If data is unavailable, document the gap and apply the stated policy consistently to future acquisitions.
• Recalculate the target as well as the base year. The 42% absolute reduction must be re-expressed against the recalculated baseline, and the report must disclose the recalculation, the reason, and the effect on reported progress.
• Communicate. A short recalculation note is far less damaging than a target that appears to move without explanation. The board should be told in advance that reported progress will change, and the assurance provider needs the recalculation policy.

68% spend-based is not unusual in year one, but it determines what can honestly be claimed.

• Label it. Disclose, per category, the share calculated with spend-based (input-output) methods versus supplier-specific data. A single Scope 3 total without this disclosure implies a precision that does not exist.
• Do not claim reductions that are price effects. Spend-based estimates move with inflation, currency and input prices. A 6% fall in category 1 emissions could be a 6% fall in spend. Deflate to a constant price base, or state plainly that the movement is not a demonstrated physical reduction.
• Apply a data-quality hierarchy. Move the high-spend, high-emission suppliers first - malt and barley, aluminium cans, glass - where a small number of suppliers usually dominates the category. Publish a dated improvement plan and report progress against it.
• Quantify uncertainty. Provide a range, or at minimum a qualitative uncertainty statement, for spend-based categories, and explain the method in the basis of preparation.
• Check target coverage. If Scope 3 is the large majority of total emissions, the near-term target must cover it, and progress claims should rest on the categories with better data rather than on the whole inventory.