Just last year, global demand for energy and products rose 1.3%, driven by continued rising economic and human development. The challenge is that it also brought record high global energy-related CO₂ emissions of nearly 38.4 billion tons (IEA). This wake-up call requires action at the product-level to drive demand for low carbon industrial transformation. That type of policy requires trusted, comparable, and verifiable product-level carbon intensity data. That’s what we urgently need to work on.

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Strong Partnerships

The reality is that no single organization can solve this challenge alone, we need to increase the pool of ideas. If product-level carbon accounting is going to help reduce emissions at scale, it must be capable of being adopted and implemented by businesses and policymakers across every region of the world. 

That’s the reason why Carbon Measures partnered with the International Chamber of Commerce (ICC), an organization of over 45 million companies from small and medium-sized enterprises to large multinational companies across sectors in over 170 countries. It also has a long history of developing standards and industry frameworks and building bridges between business and policymakers, helping translate complex challenges into practical approaches that can work across markets. These are the strengths we are bringing together, because for companies to play their role in reducing carbon emissions they need a rigorous methodology for doing so. This requires independent technical work that businesses and governments alike can trust. 

Towards that end, ICC and Carbon Measures are co-hosting the Technical Expert Panel on Carbon Accounting (TEP), bringing together renowned professionals from industry, academia, science, policy and the accounting profession to help design a ledger-based carbon accounting framework.

To guide the work of the TEP and establish a common ground, there have been two publications: Guiding Principles, which outline the criteria for ‘good carbon accounting’: accuracy, verifiability, comparability, representational faithfulness, fungibility, conservation across entities, and completeness of scope; all of that underpinned by a focus on operability. And a Landscape Review – which is a point-in-time assessment of the existing approaches, standards, regulations and initiatives, shaping product-level carbon accounting. This publication includes a feedback mechanism to allow us to capture a broad set of insights. Let me be crystal clear on this: we are very eager to get feedback and engage with others, including those doing important work on product-level carbon accounting.

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Landscape Review

What is key for me about this review is that it acknowledges the amazing progress made over decades and the new ideas that form a deep knowledge base in carbon accounting. It establishes a common foundation, identifying how existing frameworks contribute to what is needed, where important gaps remain, and where future efforts should be focused.

While the report spans a broad and rapidly evolving landscape, I think that a few findings are worth highlighting in particular:

1. The basis is there, but still fragmented: The Landscape Review shows that the foundations for product-level carbon accounting are largely in place, but they remain fragmented. Over the past decade, governments, standards bodies, industry coalitions, and companies have developed tools to measure, exchange, and verify carbon data. At the same time, regulations such as the EU Carbon Border Adjustment Mechanism (CBAM), California's Low Carbon Fuel Standard (LCFS), and China's emerging Carbon Footprint Management System are rapidly increasing demand for robust product-level carbon information. Without a commonly agreed upon approach to underpin the regulations, bespoke frameworks are being created – raising the cost of compliance, adding complexity for industry, and reducing comparability across jurisdictions needed for efficient global trade.
2. “AND” not “OR”: Maybe the central and most important message is not that existing standards have failed, but that they each solve different parts of the problem, and we are still in an evolutionary process. We have to look at what is missing, as well as how what is existing and new can both contribute to a better whole.
3. What remains open: While the science underpinning product carbon footprint quantification is well established, important questions remain around the consistent treatment of removals, capital goods, circular flows, and other complex accounting topics. Beyond quantification, the report identifies a broader architectural gap: there is no common framework whose product-level data can support investment, procurement, trade, and regulations. Differences in methodologies, system boundaries, and verification rules are creating real friction, increasing costs for firms and regulators alike.

The opportunity presented by this review is to build a harmonized accounting architecture capable of supporting emerging markets, investment and regulation at scale.

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My Reflections on the Landscape Review and What It Means for Our Work at Carbon Measures

Since our launch, there have been a variety of reactions to Carbon Measures’ work, which is normal with every new initiative. To clarify, we haven’t set out to replace existing reporting requirements, become a disclosure standard, eliminate Scope 3 reporting, duplicate others' work, or slow progress. We are here to build on the work done to date and advocate for mandatory product carbon intensity policy, with the ultimate goal of reducing emissions at scale, with lower costs, and with urgency. We are here to be a catalyst, to build, to improve, and to speed up progress – and are starting to show it.

However, what’s clear to me is that maintaining inflexible positions will not move us forward and will paralyze innovation. To shift from theory to implementation, we need to embrace constructive technical disagreement, reduce blind spots, and challenge assumptions. Innovation depends on technical dialogue amongst professionals, active listening, and co-creation. Closing the door to new perspectives and ideas will ultimately slow the decarbonization progress we all want to achieve. 

This Landscape Review shows we need to hear more from practitioners and understand more deeply the financial consequences of carbon accounting. A great deal of progress has been made on the scientific side, but many questions remain when practitioners try to operationalize this work. For example, when companies do business with one another, how can they efficiently transfer accurate, trusted carbon data across value chains, maximizing the power of primary data? To what extent is the return on investment justified – not only for large companies, but also for smaller and medium-sized businesses that may not have the resources or personnel to produce highly precise calculations, comply with multiple standards and regulatory jurisdictions? And how can a procurement professional quickly assess the relative carbon intensity of products when making purchasing decisions?

Carbon accounting is also beginning to reveal significant financial consequences for companies and governments, through increased compliance costs, risks to industrial and national competitiveness, and the ability to attract investment. Some of the uncertainty and flexibility in current approaches can make it difficult to plan long-term product roadmaps and develop decarbonization strategies with confidence, making greater clarity and consistency increasingly important. 

Using steel as an example, assumptions used to calculate the lifecycle emissions per ton can vary widely (IEA). This methodological flexibility can mask real differences in performance, allowing producers with identical physical operations to legitimately report carbon intensity figures that, in some cases, differ by more than 100% depending on the accounting boundary used. The challenge is further illustrated by the definition of "green steel," where qualifying thresholds vary by a factor of 44 across existing taxonomies (Oxford Institute for Energy Studies). For example, under the EU’s CBAM, carbon cost can range anywhere between €150-540 per ton of steel, which can translate into a difference of millions of euros per shipment at current EUA prices based on different carbon intensity assumptions. This level of variation results in real financial impacts.

This also illustrates a broader reality. Carbon information is increasingly informing commercial, financial, trade, and regulatory decisions, yet today’s approaches raise important questions about whether markets can rely on the underlying data. Imagine if ~75% of public companies routinely revise their contracts or financial statements like Harvard found they currently revised their reported emissions. As carbon information plays an increasingly important role in the global economy, practitioners, governments, and investors need this information to meet the same standard. 

The next decade won't be defined only by whether we can measure product-level carbon emissions. It will be defined by whether we can come together meaningfully to use product-level carbon accounting AND regulation to change the emissions trajectory we’re on. For us, product-level carbon accounting is a means to an end, not an end in itself. Our focus is enabling business leaders to make capital expenditure decisions that generate decades of emissions impact reduction. We want to enable the policy tools and market infrastructure needed to make decisions that deliver long-term business returns and reduce emissions at the pace we need.

I encourage all of you to read the full analysis, engage in the co-creation and provide input. Your voice will make the work better.

-Amy

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Useful Links:

• Landscape Review
• Feedback Form

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Q&A: 

Is Carbon Measures intended to replace Scope 3 reporting or all other established carbon (ac)counting methodologies?

No, there is no reason why introducing product-level accounting and a ledger-based carbon accounting framework would change entity-level reporting, Scope 3 requirements, or other methodologies or replace other standards. Carbon Measures is trying to find a solution for a different need. Our focus is to help businesses differentiate their products and enable governments to make more informed policy decisions. 

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Product-level accounting is not a new concept. Why is a new framework needed?

As outlined in the Landscape Review, most existing approaches address a single piece – a product, or an individual company – rather than a full system for carbon accounting. Existing standards have not failed, but they each solve different parts of the problem, important questions remain unanswered (e.g. circular flows), and we are still in an evolutionary process. 

Addressing these points presents the opportunity to build a harmonized accounting architecture capable of supporting emerging markets, investment and regulation at scale. 

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How will Carbon Measures’ work on product-level carbon accounting avoid fragmentation?

The Landscape Review demonstrates that the foundations for product-level carbon accounting are already in place, but they remain fragmented across jurisdictions and standards. We have the opportunity to build a harmonized accounting architecture capable of supporting emerging markets, investment and regulation at scale, and Carbon Measures wants to be the catalyst to make that work possible.

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Can people contribute to this review? 

Yes, open collaboration and feedback are welcome and encouraged. A feedback form is available on the ICC’s website for those who would like to contribute. 

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Is this Landscape Review independent from Carbon Measures? 

Yes. This Landscape Review was prepared by the Secretariat of the Technical Expert Panel.  This work has been informed by publicly available literature and has benefited from the knowledge, expertise, and engagement of Panel members, industry professionals, and other subject-matter experts.

In addition, we are asking for open collaboration and feedback.

Further details on the governance structure of the ICC and Carbon Measures’ Technical Expert Panel are reflected on the ICC's website.  

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Is this work trying to prove points that can be used by hard-to-abate sectors to transfer responsibility for their carbon emissions onto consumers? 

No, the analysis does not discuss transferring responsibility for carbon emissions onto consumers in any capacity. It is focused solely on identifying how existing frameworks contribute to what is needed, where important gaps remain, and where future efforts should be focused.