Scenario: a factory receives a GHG inventory notice and panics: “I thought only big enterprises had to do this — why us now?” The answer: the list of facilities required to inventory is expanding (2024 update), and GHG inventory is no longer a “campaign” but a mandatory input to the carbon market and CBAM.
Coverage: the list expands by sector
The list of sectors and GHG-emitting facilities required to inventory (updated in 2024, replacing the old list) extends across: energy, industry, transport, construction, agriculture and waste — with emission thresholds per facility type. The clear trend: thresholds falling, coverage widening. Businesses must check the latest list instead of assuming exemption under the old one — the most common mistake today.
Reporting cycle and forms: every 2 years
Covered facilities must inventory every 2 years and report on prescribed forms to the competent authority. Reports cover: inventory scope (Scope 1 — direct emissions; Scope 2 — indirect from purchased energy; Scope 3 encouraged), calculation methods (emission factors) and verifiable activity data. The common corporate error: lacking verifiable activity data (fuel invoices, power consumption) — inventories without source data fail verification.
Verification and internal MRV systems
Inventory reports must pass independent verification — verifiers check data completeness and accuracy. To pass first time, businesses need an internal MRV system: measurement (collecting fuel, power and material data by procedure), reporting (standard forms, record retention) and internal verification before hiring independent verifiers. Experience: good MRV means much lower independent verification costs — and inventory data is the basis for carbon allowance allocation (see EXP-5178) and emissions data for EU buyers (see EXP-5180).
Recommended actions
1. Check the updated 2024 facility list now — do not assume exemption. 2. Start collecting verifiable activity data. 3. Build internal MRV before the first reporting cycle. 4. Use inventory results for all three purposes: compliance, carbon allowances and CBAM.
This article has been quality-reviewed by the FLAW AI Legal Council
Frequently Asked Questions
Which facilities must conduct GHG inventories?
Per the updated 2024 list of sectors and GHG-emitting facilities: energy, industry, transport, construction, agriculture and waste — with emission thresholds per facility type. Trend: thresholds falling, coverage widening.
What are the reporting cycle and forms?
Inventory every 2 years, reporting on prescribed forms to the competent authority. Reports cover inventory scope (Scopes 1, 2; Scope 3 encouraged), calculation methods (emission factors) and verifiable activity data.
What is inventory report verification?
Independent verification of the report’s completeness and accuracy. Reports without verifiable source data (fuel invoices, power consumption) fail verification.
How to build an internal MRV system?
Three pillars: measurement (collecting fuel, power and material data by procedure), reporting (standard forms, record retention) and internal verification before hiring independent verifiers. Good MRV sharply lowers independent verification costs.
How do GHG inventories relate to carbon allowances?
Inventory data is the basis for allocating carbon allowances to businesses in the carbon market (see EXP-5178): no credible inventory data, no calculable allocation.
Why do exporters additionally need inventories?
To provide embedded-emissions data to EU buyers for CBAM (see EXP-5180) — buyers will demand this data in contract negotiations from CBAM’s definitive phase.