ANSWERING BUYER CARBON-DATA REQUESTS: A MINIMUM ACCOUNTING CONTOUR FOR SECOND-TIER EXPORTERS IN EMERGING ECONOMIES

Abstract

Exporters in emerging economies increasingly receive greenhouse-gas data requests not from regulators but from their customers, who need supplier figures to complete their own value-chain inventories. Two instruments adopted in 2026 reshape this pressure in opposite directions. Directive (EU) 2026/470 introduced a value chain cap limiting the sustainability information that companies within the scope of the Corporate Sustainability Reporting Directive may require from counterparties with 1,000 or fewer employees, and on 3 July 2026 the European Commission adopted the corresponding voluntary standard as a delegated act. Simultaneously, the Greenhouse Gas Protocol’s Scope 3 revision, published as a Phase 1 progress update on 31 March 2026, proposes to make Scope 3 a required component of a conforming inventory, to require at least 95 per cent coverage, and to withdraw the method by which a purchase footprint is estimated from a diversified supplier’s company-wide data. This article analyses what the combination means for a second-tier supplier located outside the European Union, using an Uzbek textile component manufacturer as an illustrative case. Three findings follow from a structured reading of the instruments. First, the cap limits volume but not specificity, while the accounting revision raises specificity: the supplier faces fewer but more demanding questions. Second, the cap binds the buyer rather than conferring a right on the supplier, and applies only to requests made for the purpose of reporting under the directive; requests arising from lending, due diligence, product compliance or ordinary procurement fall outside it, and these channels account for most requests reaching a non-EU supplier. Third, the data required to answer a compliant request is already held by such a firm in dispersed form. The article specifies a minimum accounting contour of eleven data items, each mapped to an existing internal record, and argues that the binding constraint is organisational rather than technical.