As companies race to meet emissions reduction targets and comply with evolving regulations, Product Carbon Footprint (PCF) data has become a crucial component of sustainability reporting. But with growing reliance on supplier-provided emissions data, one key question arises: How can businesses ensure that the PCF data they receive is credible, consistent, and verifiable? In this article, we break down how to vet PCF data from suppliers—covering who is responsible, what to look for, and how to implement a robust due diligence process. This process is especially important in light of emerging regulations like the EU’s Carbon Border Adjustment Mechanism (CBAM), which requires importers to report embedded carbon emissions in certain goods.
What is PCF Data?
Product Carbon Footprint (PCF) data measures the total greenhouse gas (GHG) emissions associated with a product’s lifecycle. The scope typically includes raw material extraction, processing, product manufacturing, and transportation. Often, the supplier PCF scope will encompass up to the point of distribution to their customer, sometimes referred to as a cradle-to-gate PCF value.
Companies rely on suppliers to provide this data, particularly for Scope 3 emissions reporting or to support external claims. However, the quality and consistency of this data can vary significantly. This variance causes challenges for the customer as well as concern amongst suppliers, particularly when PCF values are used to influence purchasing decisions.
Why Validation Matters
PCF data plays a growing role in:
- corporate sustainability disclosures (e.g., CSRD, SEC climate rules),
- internal carbon accounting and product design decisions,
- meeting Scope 3 decarbonization targets such as SBTi,
- regulatory compliance, such as under CBAM, which demands accurate reporting of embedded emissions in imports, and
- supplier engagement and performance tracking.
Unverified or inaccurate data can have critical consequences, including compliance risks, greenwashing allegations and litigation, and poor decision-making on emissions strategy.
Who is Responsible for PCF Data Quality?
PCF data quality responsibility is shared across the value chain.
- Suppliers are expected to calculate and report PCF data, ideally using recognized methodologies such as ISO 14067, GHG Protocol Product Standard, or CX-PCF Rules. At times, a specific methodology will be prescribed, as we have seen in the EU 1542 Battery Regulation when determining the carbon footprint of batteries.
- Buyers must assess the data’s credibility, consider alignment with reporting standards, and address any inconsistencies. These items are especially critical if PCF data will be used to support external claims or influence purchasing decisions. Buyers must also recognize that a single PCF value is a snapshot in time, and therefore consider how they will efficiently collect this data moving forward while also minimizing administrative burden.
How to Vet PCF Data from Suppliers
To ensure the reliability of PCF data, companies need a structured vetting process. These steps can help assess data quality, identify red flags, and build trust in supplier emissions disclosures.
1. Request Methodological Transparency
Ask suppliers to document:
- the calculation methodology used and the scope (e.g., cradle-to-gate, cradle-to-grave),
- emission factors and data sources (see #3),
- allocation approaches (especially for shared processes), and
- boundaries and exclusions.
Use a standardized PCF template or form to ensure consistency across suppliers.
2. Check for Alignment with Standards
Validate that the PCF aligns with ISO 14067, the GHG Protocol Product Standard, or other industry-specific guidelines (e.g., PACT, Pathfinder Framework by WBCSD). Standards help ensure comparability and methodological rigor. See below for more information on how third-party validations vet alignment with specific standards.
3. Evaluate Primary vs. Secondary Data Use
Customers prefer PCF data based on primary data (actual emissions, energy use, material inputs) over secondary data (averages or proxies). In some instances, primary data may be required by the PCF methodology. Ask suppliers to specify what portion of their data is primary (see DQR below).
4. Assess Completeness and Boundaries
Look for red flags like:
- unjustified exclusions (e.g., omitting transportation),
- incomplete upstream data,
- unusual use of credits, and
- missing co-product allocation methods.
Use a checklist to ensure each stage of the product life cycle is covered, and that all supplier data is vetted in a consistent manner.
5. Use Data Quality Ratings (DQRs)
Since buyers may not be able to audit every supplier PCF in detail, Data Quality Ratings offer a structured way to evaluate the credibility of submitted data. The DQR score includes key attributes—such as methodological rigor, data source reliability, and completeness—which help prioritize review efforts and flag potentially unreliable figures.
6. Perform Spot Checks and/or Third-Party Validations
Where feasible, conduct reviews or request third-party assurance to confirm PCF accuracy. Third-party validation is especially valuable when data underpins public claims, third-party reports, or product labeling, and not just when regulations demand it. Often suppliers may be hesitant to share internal data with a customer, yet otherwise willing to seek external validation through a reputable third-party certifier.
7. Use Trusted Data-Sharing Platforms
Consider digital ecosystems (i.e. Catena-X, iPoint, Circulor) to streamline PCF data exchange. These platforms offer:
- standardized data formats aligned with recognized methodologies,
- secure sharing of emissions data across supply chain partners, and
- improved traceability through shared digital product passports.
Leveraging such platforms can reduce manual validation efforts and enhance overall data reliability.
When and How Often to Vet
Vetting supplier PCF data isn’t a one-time task—it should be an ongoing part of your emissions management process. Start by reviewing and vetting all new supplier submissions during initial onboarding, before any data is used in reporting or decision-making.
As your reporting cycles progress, conduct annual reviews to ensure existing PCF data remains accurate and aligned with current methodologies and regulatory expectations. It is common to see a supplier revising their PCF values annually. This step is especially important when updating your emissions inventory or preparing disclosures under frameworks like the CSRD or GHG Protocol.
Be prepared to revisit and validate data more thoroughly when regulatory triggers arise. These might include external audits, requests for third-party assurance, or new requirements under evolving mechanisms such as the EU’s Carbon Border Adjustment Mechanism (CBAM). A proactive approach helps ensure compliance, credibility, and resilience in your sustainability reporting.
Building a Repeatable Validation Process
To streamline vetting:
- use supplier questionnaires with embedded guidance or a trusted sharing platform,
- seek industry alignment where possible to decrease the administrative burden,
- develop a PCF validation checklist or scoring framework,
- offer supplier training and support, and
- implement data collection during the procurement process.
Over time, this encourages higher-quality data and strengthens trust across the supply chain.
Get Support
Vetting supplier PCF data is no longer a “nice-to-have”—it’s essential for credible sustainability reporting and effective climate strategy. By establishing clear expectations, validating data rigorously, and promoting transparency, companies can turn emissions data into a competitive advantage.
Want to take your PCF due diligence further? Contact our team at [email protected] to learn how to implement best-in-class supplier engagement strategies.
