Greenhouse gas emissions reporting by Local Authorities and other Scottish public bodies: Research into Scope 3 Group 3 emissions

Appendix B: Further details on the analysis

This section elaborates on the findings above, including the relevance, impact, influence, and value for money in reporting.

B.1 Relevance of Scope 3 Group 3 emissions

Table 4. Overview of the types of activities that may have relevant Scope 3 Group 3 emissions in Scottish public bodies

Activity	Relevant to…	Category 9 Transportation [see Footnote [32]]	Category 10 Processing	Category 11 Use[see Footnote [33]]	Category 12 End-of-life[see Footnote [34]]
					Table 4 provides an overview of the potential Group 3 activities that have been identified, which Scope 3 category they are likely to fall into, and (where possible) a qualitative indication of the potential scale. It also provides comments on how the organisational structure and the GHG emissions reporting organisational boundary can impact the relevance of the emissions.
Selling of food that is generally eaten on-site	Organisations selling food such as through a café or staff canteen	No, transportation of food is paid for by the reporting organisation. Emissions from transportation would fall under Category 4 Upstream distribution and transportation	No, as not selling raw ingredients	Minor, indirect use-phase emissions if food is taken away to be reheated later such as using a microwave. This is likely to be down to consumer choice and very small so considered immaterial here.Note indirect use-phase emissions are optional to report under the GHG Protocol.	Minor. A small amount of waste from purchased food may be disposed off-site and not accounted for under Category 5 – Waste Generated in Operations.

Notes:

• If the reporting organisation (or a subsidiary it controls) sells food such as in a canteen or café, the categorisation of emissions is shown above.
• Where waste is collected and managed on site, the associated emissions are likely to be captured through the organisation's waste management reporting (typically Scope 3 Category 5). Where customers remove food or packaging from the premises, emissions associated with downstream disposal could theoretically fall within Category 12.
• If the food is sold by a subsidiary such as an ALEO which the reporting organisation does not control, those emissions would likely be reported under Category 15 – Investments.
• If the reporting organisation pays another entity to sell food, those emissions would be reported under Category 1 - Purchased goods and services.
• If the reporting organisation leases space to another organisation to sell food, the energy used by the other organisation could be reported under Category 13 Downstream leased assets, or under the reporting organisation’s scope 1 and 2, depending on the organisational boundary. However, the selling of products by the lessee is unlikely to fall within the reporting organisation’s boundary, so the Group 3 emissions from selling the products would not be relevant.

Activity	Relevant to…	Category 9 Transportation [see Footnote 30]	Category 10 Processing	Category 11 Use[see Footnote 31]	Category 12 End-of-life[see Footnote 32]
Distributing inhalers	NHS	No, NHS boards are generally not selling or distributing inhalers themselves.	No, there is no further processing of the products.	Yes, there are F-gas emissions from the propellants of inhalers.Note that the emissions from propellants during the use of inhalers are already reported by NHS boards.	Yes, there are emissions from waste at end-of-life disposal, including the inhaler cases themselves (likely to be a minor source of emissions) and any propellants remaining in the inhaler (potentially a significant source of emissions).Note, at present the methodology NHS boards are using to estimate emissions from inhalers will include any residual propellant in the use-phase emission estimates. The full impacts are therefore likely being accounted for even if they are not being classed as Category 12.

Notes:

• If the reporting organisation sells or distributes inhalers, the categorisation of emissions is shown above.
• NHS boards are generally reimbursing distributers such as pharmacies, not selling or distributing inhalers themselves.
• If the reporting organisation pays another entity (such as a pharmacy) to sell or distribute inhalers, any downstream emissions relating to the products sold would be reported under Category 1 - Purchased goods and services.
• If the reporting organisation (or a subsidiary it controls) sells or distributes inhalers, there may be relevant emissions under Category 9, 11 and 12.

Activity	Relevant to…	Category 9 Transportation [see Footnote 30]	Category 10 Processing	Category 11 Use[see Footnote 31]	Category 12 End-of-life[see Footnote 32]
Distributing pharmaceutical medicines	NHS boards	No, NHS boards are not selling or distributing these products themselves	No, there is no further processing of the products.	No, NHS boards are not selling or distributing these products themselves	No, NHS boards are not selling or distributing these products themselves

Notes:

• If the reporting organisation pays another entity (such as a pharmacy) to sell or distribute pharmaceutical medicines, the categorisation of emissions is shown above.
• NHS boards are generally reimbursing distributers such as pharmacies, not selling or distributing pharmaceutical medicines themselves. Therefore, the downstream categories (Category 9-12 and 14) are not considered relevant, but the emissions might be classified under upstream Scope 3 emissions e.g. Category 1 - Purchased goods and services. If, however, the reporting organisation (or a subsidiary it controls) sells or distributes pharmaceutical medicines, there may be relevant emissions under Category 9, 11 and 12.

Activity	Relevant to…	Category 9 Transportation [see Footnote 30]	Category 10 Processing	Category 11 Use[see Footnote 31]	Category 12 End-of-life[see Footnote 32]
Distributing medical equipment such as hearing aids, mobility aids and at-home monitoring equipment	NHS, organisations distributing equipment to end-users	Unlikely. Only applicable if the recipient of the equipment, or another entity (not the reporting organisation) is paying for the transportation and storage of the waste.	No, there is no further processing of the medical equipment.	Minor, direct-use phase emissions may occur for any products that require electricity or batteries to use.	Yes, the emissions from the end-of-life treatment of medical equipment that is sold or distributed would be reported under this category.

Notes:

• If the reporting organisation (or a subsidiary it controls) distributes medical equipment, the categorisation of emissions is shown above.
• If the reporting organisation pays another entity to sell medical equipment, those emissions would be reported under Category 1 - Purchased goods and services.

Activity	Relevant to…	Category 9 Transportation [see Footnote 30]	Category 10 Processing	Category 11 Use[see Footnote 31]	Category 12 End-of-life[see Footnote 32]
Selling of waste (e.g. plastics) to be processed into new products	Local authorities and any other organisations selling waste	Unlikely. Only applicable if the organisation purchasing the waste (not the reporting organisation) is paying for the transportation and storage of the waste.	Yes, the emissions from the further processing of e.g. plastics sold would be reported under this category.	Minor, there are no emissions associated with the direct use-phase of recycled plastic, although some recycled plastic products (e.g. clothing) may have indirect use-phase emissions.Note indirect use-phase emissions are optional to report under the GHG Protocol.	Yes, the emissions from the end-of-life treatment of e.g. plastics sold would be reported under this category.

Notes:

• If the reporting organisation (or a subsidiary it controls) sells waste to be processed into new products, the categorisation of emissions is shown above.
• If the waste is sold by a subsidiary such as an ALEO which the reporting organisation does not control, those emissions would likely be reported under Category 15 – Investments.
• If the reporting organisation pays another entity to process its waste into new products, those emissions would be reported under Category 1 - Purchased goods and services.

Activity	Relevant to…	Category 9 Transportation [see Footnote 30]	Category 10 Processing	Category 11 Use[see Footnote 31]	Category 12 End-of-life[see Footnote 32]
Selling of timber	Organisations selling timber for further processing such as Forestry and Land Scotland	Yes, for downstream transportation and distribution not paid for by the reporting organisation. Category 9 would apply if, for example, the products are transported further or shipped to customers after the timber reaches the sawmills.	Yes, processing of timber at sawmills and processing into final products.	Yes, any timber sold as fuel would have direct use-phase non-CO2 emissions associated with combustion.	Yes, the methane (CH4) emissions from the end-of-life disposal of any timber products by landfill.

Notes:

• If the reporting organisation sells timber that they have grown, the categorisation of emissions is shown above. The table only includes non-CO₂ emissions as it assumes that the biogenic carbon stored in the harvested wood products would cancel out with any CO₂ emissions for the burning of timber (Category 11) or end-of-life disposal (Category 12).
• If the reporting organisation reports the carbon storage in wood products, the complete product life cycle GHG emissions should be considered.^[35]

Activity	Relevant to…	Category 9 Transportation [see Footnote 30]	Category 10 Processing	Category 11 Use[see Footnote 31]	Category 12 End-of-life[see Footnote 32]
Selling of products in shops	Cultural organisations	Yes, for the downstream transportation and distribution of products sold online that are paid for by the customer.	No, unlikely to be selling intermediate products that are processed further.	Minor, there may be some minor direct use-phase emissions for products that require batteries or electricity. There may also be minor indirect use-phase emissions of any products indirectly use energy during their use (e.g. the electricity from the washing of clothes). Note indirect use-phase emissions are optional to report under the GHG Protocol.	Yes, there will be end-of-life emissions from the disposal of products that are sold online and in-store.

Notes:

• If the reporting organisation (or a subsidiary it controls) operates shops, the categorisation of emissions is shown above.
• If the shops are operated by a subsidiary such as an ALEO which the reporting organisation does not control, those emissions would likely be reported under Category 15 – Investments.
• If the reporting organisation pays another entity to operate a shop, those emissions would be reported under Category 1 - Purchased goods and services.

Activity	Relevant to…	Category 9 Transportation [see Footnote 30]	Category 10 Processing	Category 11 Use[see Footnote 31]	Category 12 End-of-life[see Footnote 32]
Online learning	Organisations offering remote learning	No, as there are no physical products being distributed.	No, as there are no physical products that are processed further.	Yes, there are direct use-phase emissions for the electricity used to access the online learning platform (e.g. charging of laptops).	No, as there are no physical products being distributed.

Notes:

• If the reporting organisation (or a subsidiary it controls) is not developing and hosting software for online learning, the categorisation of emissions is shown above.
• If the reporting organisation pays another entity to develop and host software for online learning, the emissions associated with the provision of that service – including server hosting – would be reported under Category 1 - Purchased goods and services.

Activity	Relevant to…	Category 9 Transportation [see Footnote 30]	Category 10 Processing	Category 11 Use[see Footnote 31]	Category 12 End-of-life[see Footnote 32]
Selling of other products	Any organisation selling or distributing products	Possibly, for any downstream transportation and distribution that is not paid for by the reporting organisation. Category 9 would apply if, for example, the customer pays for the transportation of products.	Possibly, if selling intermediate products that are processed further.	Possibly, there may be some direct use-phase emissions for products that use energy (e.g. candles or electronic equipment) or release greenhouse gases directly (e.g. products with refrigerants). There may also be minor indirect use-phase emissions of any products indirectly use energy during their use (e.g. the electricity from the washing of clothes).Note indirect use-phase emissions are optional to report under the GHG Protocol.	Yes, there will be end-of-life emissions from the disposal of products.If the products are disposed of on-site of the reporting organisation, the emissions from the disposal of the products will be captured in Category 5 Waste generated in operations.

Notes:

• If the reporting organisation (or a subsidiary it controls) sells products such as manufactured goods like garden furniture or surplus quarry material, the categorisation of emissions is shown above.
• If the products are sold by a subsidiary such as an ALEO which the reporting organisation does not control, those emissions would likely be reported under Category 15 – Investments.
• When assessing the relevance of downstream emissions from sold products, it does not matter whether products are sold directly to the consumer or a third party to sell on. However, it may affect whether those emissions are considered material and therefore whether a public body should include them in its reporting. This is because materiality considers both impact and influence, and the organisation is likely to have more influence if selling directly to an end consumer.
• If the reporting organisation pays another entity to sell products on their behalf, those emissions would be reported under Category 1 - Purchased goods and services.

Activity	Relevant to…	Category 9 Transportation [see Footnote 30]	Category 10 Processing	Category 11 Use[see Footnote 31]	Category 12 End-of-life[see Footnote 32]
Relocation travel and commuting of students	Universities and educational institutions with international students and students who commute.	Potentially could be considered Category 9 but see notes below.	No	No	No

Notes:

• The EAUC Standardised Carbon Emissions Framework for Further and Higher Education (SCEF) classifies student relocation travel and student commuting under Category 9 Downstream transportation and distribution. It is debatable whether this is the most appropriate category allocation given that students are not ‘sold products’. Other options would be Category 6 – Business Travel or Category 7 – Employee Commuting.
• Some universities are already starting to report the emissions from student relocation travel and student commuting in their PBCCDRs.

B.2 Materiality of Scope 3 Group 3 emissions

This section provides more detail on the rationale for the impact and influence ratings presented in Figure 4, based on different categories of activity. For each example, it then describes potential calculation methodologies, including the relative level of effort to collect data or undertake calculations. Calculation approaches and effort classifications have been assigned by the Aether project team for each activity based on information from stakeholder engagement, data available online and expert judgement. Here, effort is defined by the effort estimated to perform the calculation, based on how difficult it is likely to be to obtain relevant activity data and emission factors (EFs).

• Low effort: activity data and EFs are expected to be readily available, with EFs available through credible published sources and activity data easily obtained and collated internally.
• Medium effort: more detailed data are required than may currently be available, such as where the activity data required is not currently collected, identifying reliable EFs may require further research, or calculation approaches are more complex.
• High effort: activity data or EFs are understood to be unavailable or very difficult to collect or calculation approaches are very complex.

Based on these considerations, the value for money and (where applicable) potential timescales for reporting for each activity have then been indicated.

B.2.1 Inhaler propellants

Impact: 4

The emissions impact of the five regional NHS health boards that are already reporting emissions from inhaler propellant R-134a and inhaler propellant R-227a ranges from 10% to 25% of the total emissions reported in their 2024-25 PBCCDRs. The Category 11 – Use of sold products emissions from inhaler propellants are therefore considered significant compared to the rest of the health board emissions. Category 12 – End-of-life treatment of sold product emissions from the inhaler casing are likely to be minor. Category 12 – End-of-life treatment of sold product emissions from propellants remaining in the inhaler at end-of-life are currently reported with the Category 11 emissions as the methodology NHS boards are using to estimate emissions from inhalers will include any residual propellant.

Influence: 3

NHS Scotland and the NHS health boards can influence inhaler propellant emissions through providing updated prescribing guidance. Measures to reduce inhaler propellant emissions include, for example, reducing the prescribing of the pressurised metered dose inhaler (pMDI) salbutamol, and instead prescribing an inhaler with two combined treatments. New prescribing guidance also prioritises lower global warming potential inhalers such as dry powder inhalers (DPIs) or soft mist inhalers (SMIs). In addition, next-generation pMDIs using low-global-warming-potential propellants are becoming available and offer substantially lower emissions than current pMDIs.

Calculation effort: Medium to High

The calculation approaches for the emissions from distributed inhalers are outlined below.

Category	Calculation approach	Effort
Category 11 – Use of sold products	Total quantity of propellant per inhaler (mL/inhaler) x number of inhalers (#) x EF for propellantCalculation to be repeated for each type of inhaler	Medium
Category 12 – End-of-life treatment of sold products	Inhaler propellant: As above, but adjust the total quantity of propellant per inhaler (mL/inhaler) x average proportion remaining upon disposal (%) to obtain the amount emitted during end-of-life treatment x proportion not recycled[36]Inhaler casing: Average weight of material (kg) x EF per disposal method for each material	High

The main effort involved in this calculation is collecting data on the number of inhalers of each type and the amount of propellant they contain. However, this is already being done by some NHS boards, so it is assumed that the data are accessible to others as well and that the effort is not too onerous.

Our understanding is that some of the NHS health boards already reporting the use-phase emissions from inhaler propellants may consider these to be classified under Category 1 Purchased goods and services rather than the downstream Scope 3 emissions categories. It is not important to define precisely which category applies; the important thing is that these emissions are considered and reported, and that public bodies take steps to reduce them.

Value for money in reporting? Yes

There is value for money in NHS health boards reporting Category 11 – Use of sold products inhaler propellant emissions as they have a large GHG impact, and NHS Scotland has a moderate level of influence to reduce the emissions.

Timescales for reporting: Short term

Given that some NHS boards already report the emissions from inhaler propellants, it is likely that this could be reported by more NHS boards in the short term.

B.2.2 Selling of timber

Note: This analysis focuses on public bodies that sell timber on a large scale, and the evidence is primarily based on information provided by Forestry and Land Scotland. For other public bodies selling timber, the impact, influence and value for money in reporting these emissions will vary depending on the scale of timber sold and should be based on an individual materiality assessment.

Impact: 5 (depending on the scale of timber production)

Forestry and Land Scotland (FLS) manage 8% of Scotland’s total land area and grow around 24 million trees per year.^[37] They are major suppliers to the wood-panel, pulp and paper and saw-milling industries with sawlogs, round fencing, firewood, hardwood and softwood available for sale.^[38] Annually, Forestry and Land Scotland produce around 3.2 million cubic metres of timber.^[39] The emissions from the downstream transportation of timber (Category 9), processing (Category 10), and combustion of any firewood (Category 11), will therefore be significant due to the scale of timber produced annually.

Emissions from Category 12 End-of-life treatment of sold products would also occur for any timber products that are sent to landfill, processed in a waste incinerator, recycled or composted at the end-of-life. Among these waste management options, the most significant emissions would occur if the timber were sent to landfill. It is noted that timber products are considered unlikely to end up in landfill in future due to waste legislation changes in Scotland such as the ban on landfilling biodegradable municipal waste from the 31 December 2025.^[40] However, although the ban has technically come into force, enforcement has been deferred until 1 January 2028 through successive six-month exemptions.^[41] As a result, landfill should continue to be considered as a potential end-of-life treatment route.

The potentially large scale of GHG emissions from the above sources has been confirmed via high-level calculations undertaken internally by the Aether team. Indicative pathways for timber products were developed to derive an estimate of the likely lower and upper bound of emissions. Results were then compared to the total emissions already reported by FLS in their PBCCDR.

Influence: 1

Based on stakeholder feedback obtained during interview, it is understood that Forestry and Land Scotland have very little influence over downstream emissions once the timber is sold through long-term contracts and through the open market.

Calculation effort: Medium to High

The calculation approaches for the downstream emissions from sale of timber are outlined below.

Category	Calculation approach	Effort
Category 9 – Downstream distribution and transportation	Mass of timber × estimated km transported × emission factor (EF)Calculation to be repeated for each method used to transport timber (e.g. vehicle types, shipping, air freight)	High
Category 10 – Processing of sold products	Mass of timber × cradle-to-gate EF for type of timberCalculation to be repeated for each type of productCan be estimated based on timber quality (medium effort) or more detailed information about what products are made (high effort)	Medium to High
Category 11 – Use of sold products	Mass of timber known to be sold as fuel to be burnt × EF for biomass fuel	Medium
Category 12 – End-of-life treatment of sold products	Mass of timber x EF for disposal methodCalculation to be repeated for each disposal method	High

Forestry and Land Scotland have advised that they hold good data on the mass of timber sold and an indication of the type of timber or end-product of the timber. However, data on the distance that timber is transported (Category 9)^[42], the type of vehicle used to transport timber (Category 9), and the disposal method for the end-of-life-treatment of timber (Category 12) will be harder to obtain and may need to rely on assumptions. Furthermore, for Category 12, the DESNZ conversion factors for company reporting only include an estimate of transportation to the waste processing facility for closed loop recycling and combustion of wood, not the emissions that occur from the recycling or combustion processes.

Note that the approach to reporting GHG emissions from the forestry and land sector differs from some other sectors. The biogenic carbon sequestered by timber, and the emissions that occur when it is re-released to the atmosphere, are not accounted for within Scopes 1, 2 or 3 under the GHG Protocol. Some further information is below; please refer to Appendix B of the GHG Protocol Corporate Standard for more details. Also note that the GHG Protocol has published a Land Sector and Removals Standard^[43] and associated Guidance^[44] which, although not specific to forestry activities, should be referred to as they address GHG accounting procedures for biogenic products.

Biogenic carbon

As trees grow, they obtain energy through photosynthesis where carbon dioxide is broken down to create energy. The carbon is stored in the wood, so when the wood is harvested and converted into timber, the carbon store can remain for a long time. When the wood eventually breaks down through combustion or decay, the carbon is released back to the atmosphere as CO₂. As the biogenic carbon removed from and then released to the atmosphere effectively cancel each other out, only non-CO₂ emissions from the combustion and decay, or end-of-life treatment of timber are considered here.

Time boundary for reporting downstream emissions

Although the carbon store could theoretically be estimated and considered in the downstream Scope 3 categories, the GHG Protocol Land Sector and Removals Standard and Guidance defines the time boundary for biogenic product emissions based on the life cycle GHG emissions associated with the relevant activities of the reporting company in the reporting year.^[45] This means that a company selling timber in 2025 would potentially need to account for all the downstream lifecycle emissions related to the processing, use (combustion), and end-of-life of that material in 2025, even if the emissions occur in future years. Note that this provides less of an incentive to avoid the combustion of timber such as through use in furniture and construction where carbon can be stored for decades before end-of-life treatment.

‘Value for money’ in reporting? Possibly

It is recommended that public bodies assess the downstream emissions from the selling of timber as part of a wider materiality assessment. If public bodies sell a very large volume of timber, the emissions may be significant compared to their other Scope 1, 2 and 3 emissions. However, public bodies will likely have a low level of influence over the downstream emissions from the selling of timber. Furthermore, estimating and reporting these emissions may require considerable effort due to limited data availability, particularly for Categories 9 and 12.

It is also important to evaluate the reporting options in more detail because timber sequesters carbon, recognising that public bodies may wish to use permanent woodland as a means of offsetting other organisations’ GHG emissions, or ‘insetting’ their own (i.e. claiming credit for GHG removals on the public estate).^[46]

However, the reporting of downstream emissions from timber should also be considered from a wider, systems thinking perspective. For example, the transportation emissions from timber produced in Scotland will be lower than timber imported from elsewhere. If reporting downstream emissions from timber were to incentivise public bodies to reduce their timber production, this may result in higher GHG emissions overall due to the need to import timber, a phenomenon known as ‘carbon leakage’. It is important to consider this issue when identifying mitigation actions that would affect the reported GHG emissions from a single organisation.

Timescales for reporting: Phased approach where material

Where the downstream emissions from the selling of timber are found to be material for a particular public body, a phased approach to reporting is recommended.

• It is recommended to start with estimating emissions from Category 10 – Processing of sold products and Category 11 – Use of sold products as there may be sufficient data available for these categories to support an initial high-level quantification.
• For Category 9 – Downstream transportation and distribution and Category 12 – End-of-life treatment of sold products, engagement with long term contracts could begin to assess if any activity data from these categories could be identified. For example, for Category 9 – Downstream transportation and distribution, the transportation for intermediate products can be assessed first.
• Another option would be to do a more detailed estimate for Category 9 – Downstream transportation and distribution every ~5 years to generate easy-to-use conversion factors for annual reporting.

B.2.3 Student relocation travel, commuting and externally managed student accommodation

Note: It is debatable whether these activities should technically be classified under Scope 3 Group 3, but because that is the approach taken by EAUC, they have been included here.

Impact: Student relocation and commuting - 3; Externally managed student accommodation – 2

Around 20 educational institutions are currently reporting student relocation travel and or student commuting in their 2024-25 PBCCDR, and in some cases the associated emissions are relatively large. For example, in the 2024-25 PBCCDR for the University of Strathclyde, student commuting and student relocation travel represented 7% and 16% of the total reported emissions respectively.

It is unclear how many educational institutions are reporting emissions from student accommodation and halls of residence that are on-site but owned or managed by an external organisation, as this is not necessarily noted in the PBCCDRs. An estimate of the impact has not been undertaken but it is assumed to be relatively low or moderate.

Influence: 2

Student relocation travel, commuting and externally managed accommodation have been ranked as low influence for the following reasons:

• Educational institutions have low influence over student relocation travel, especially as many international students will be flying from outside of Europe.
• Educational institutions have some indirect influence over student commuting as they can engage with students on commuting modes and consider where accommodation is offered for students in relation to the campus. However, in practice, commuting methods are assumed to primarily be driven by practicality and cost considerations.
• Educational institutions have low influence over student accommodation and halls of residence that are on-site but owned or managed by an external organisation, as they can engage with the accommodation providers.

Calculation effort: Student relocation and commuting - Medium; Externally managed student accommodation – Medium to High

Calculation methodologies for student relocation and commuting are suggested in the EAUC SCEF and includes the domestic and international student relocation travel emissions calculator.^[47] This involves collecting information from each department about the number of students domiciled in different countries. The data can then be entered into the EAUC calculator tool which avoids the need to separately obtain the distances between each individual country and uses assumptions to calculate the likely number of trips per year. The calculation effort is assumed to be medium, mostly due to the need to collate the student data.

For student accommodation and halls of residence that are on-site but owned or managed by an external organisation, SCEF suggests using the CIBSE energy benchmarking tool to estimate energy use, then applying relevant EFs per fuel type.^[48] CIBSE benchmarks are based on the amount of energy used per unit of floor area (kWh/m²), so a potential challenge in collecting data would arise due to lack of available information on floor areas. This could be estimated from average figures (m² /student) or obtained from building managers. The effort level is assumed to be medium (if using rough assumptions) to high (if seeking to obtain more detailed floor area or energy information).

Value for money in reporting: Student relocation and commuting - Yes; Externally managed student accommodation - No

Some educational institutions are already reporting student relocation travel and or student commuting in their PBCCDRs. Although they will not be relevant to all educational institutions, they may be significant in some cases, so it is recommended that they are assessed and reported.

For student accommodation and halls of residence that are on-site but owned or managed by an external organisation, it is recommended that educational institutions assess how much accommodation may be on-site but owned or managed by an external organisation and whether emissions from this would be significant compared to total emissions.

Suggested timescales for reporting: Student relocation and commuting – Short term; Externally managed student accommodation – N/a

Many educational institutions are already reporting student relocation travel or student commuting, as discussed above. Medium-effort calculation approaches using existing tools are available that could be used to derive initial estimates of the impact in the short term. Higher-effort approaches could be adopted on a voluntary basis as reporting organisations gather better data.

B.2.4 Selling of food that is generally eaten on site

This activity refers to food sold in cafes and canteens that is usually eaten and disposed of onsite, but in principle could be brought home for consumption and disposal. This is assumed to be a small proportion of the total food sold from those venues, based on discussions with stakeholders.

Impact: 1

Emissions associated with reheating food after purchase and the off-site disposal of food waste and packaging are expected to be very small. As an illustration, contractor-managed waste accounts for less than 0.1% of the total GHG emissions reported by National Museums Scotland in their 2024-25 PBCCDR. On this basis, emissions from these activities are expected to represent a negligible proportion of a public body's overall greenhouse gas emissions.

Influence: 1

Public bodies have very limited direct influence over emissions associated with sold food and packaging once the products leave their premises. Customer behaviour relating to food preparation, disposal and recycling generally falls outside their operational control.

However, public bodies do have indirect influence over Category 12 related emissions through procurement and supplier engagement around packaging. For example, a Scottish public body could require café operators to use recyclable or compostable packaging, or introduce reusable cup and container schemes as part of catering service contracts. While these measures do not control how customers dispose of packaging once it leaves the premises, they can reduce emissions from end-of-life treatment by increasing the likelihood that materials can be reused, recycled or composted.

More broadly, the Circular Economy (Scotland) Act 2024^[49], Circular Economy Strategy^[50] and Zero Waste Scotland^[51] are working together to drive emissions reductions associated with food product and packaging waste disposal. Through the Circular Economy and Waste Route Map to 2030, the Scottish Government identifies Scotland’s food waste as a priority action and has set a target in line with the UN Sustainable Development Goal 12.3 to halve food waste and reduce food loss by 2030.^[52] Further, this policy system helps to delivers improved recycling and diversion of food waste from landfill, as well as behaviour change programmes that encourage households to reduce food waste and correctly separate food and packaging for collection and recycling. These interventions are expected to reduce the Category 12 emissions even further over time.

Calculation effort: Low

The calculation approaches for the downstream emissions from the selling of food products generally eaten on site are outlined below.

Calculation approach	Effort
(Total food sold x Proportion of food expected to be disposed of off-site) x EF for disposal method	Low

Calculation of Category 12 emissions requires data on food products sold, together with assumptions about customer behaviour after purchase. This includes estimating the proportion of food disposed of off-site, and the disposal routes for food waste and packaging. Data are available for total food waste and food products sold, along with emission factors for disposal, making it straightforward and low effort to calculate these emissions. However, as data is not typically available for customer behaviour-related disposal, the resulting estimates would be based on high-level assumptions and subject to significant uncertainty.

Estimating Category 11 indirect emissions for reheating sold food products, would require assumptions about the subsequent preparation methods and energy consumption, resulting in highly uncertain estimates for an emissions source expected to be immaterial. For this reason, no calculation approach has been proposed.

Value for money in reporting? No

Reporting downstream emissions associated with sold food products generally eaten on site is unlikely to represent value for money for most public bodies. These emissions are expected to be very small relative to an organisation's overall greenhouse gas emissions, while the effort required to estimate downstream food preparation and household waste disposal is disproportionate to their materiality.

Local Authorities will already be reporting area-wide waste and have an influence in their remit as waste management authorities, but reporting this waste stream separately would potentially introduce double-counting.

Greater emissions reductions are likely to be achieved by focusing resources on higher-impact interventions within a public body's control, such as sustainable procurement, reducing packaging, minimising food waste at source and promoting on-site behaviour change. Furthermore, household food and packaging disposal is already influenced by national policies and programmes, including Scotland's circular economy measures and food waste reduction initiatives. An exception may apply where a public body operates a large catering estate with significant food sales, in which case the materiality of these emissions should be assessed on a case-by-case basis.

B.2.5 Selling of waste to be reprocessed into new products

Impact: 3

Emissions associated with the downstream transportation (Category 9), reprocessing (Category 10) and end-of-life treatment (Category 12) of waste sold by local authorities could have a moderate overall impact.

Whilst transportation contributes to Category 9 emissions, the majority of emissions are likely to arise from Category 10 intermediate processing. For plastics, intermediate reprocessing typically includes energy and resource intensive stages such as sorting, washing, shredding, extrusion, pelletising, and remanufacture^[53]. The emissions intensity of these processes varies depending on polymer type, contamination levels, and whether mechanical or chemical recycling routes are used^[54]. Initial processing steps such as sorting and shredding are relatively low-emissions activities, with impacts primarily driven by electricity use in automated separation systems. In contrast, later-stage processes, including washing, extrusion, pelletising and remanufacture, represent the most emissions-intensive components of Category 10. The electricity used by moulding and extruding facilities accounts for an estimated 17%–30% of cradle-to-grave plastic emissions^[55]. These stages require significant thermal and electrical energy inputs to create usable secondary products.

Reprocessing generally has a lower lifecycle carbon footprint than producing equivalent materials from virgin resources. For example, virgin high-density polyethylene (HDPE) has an embodied carbon footprint of approximately 1.9 CO₂e/kg compared to recycled HDPE which has an embodied carbon footprint of approximately 0.6 CO₂e/kg^[56]. Nevertheless, these activities can still generate significant emissions, particularly where large volumes of materials such as plastics are processed. The magnitude of these emissions is difficult to quantify due to limited visibility of downstream processing routes and a lack of standardised emission factors.

Despite the moderate Category 10 emissions from intermediate reprocessing, recycling consistently results in lower lifecycle emissions than virgin material production^[57]. This highlights the importance of increased material recovery despite the residual processing burden.

Emissions that fall under Category 12 End-of-life treatment of sold products, are likely to be minor in comparison to the emissions from Category 10, and more uncertain as the local authority will not have sight over the products made from recycled waste materials or their end destinations.

Influence: 2

Local authorities have some influence over the processing of the waste product sold (Category 10). They can review contractual arrangements with the waste processing facility they sell the plastics to. By specifying requirements within contracts, local authorities can influence the quality of materials supplied for reprocessing, encourage high-quality source segregation to reduce contamination, and indicate preferred recovery routes or preferred end uses for recovered materials. They may also encourage contractors to adopt more resource-efficient processing practices or demonstrate environmental performance, although they have limited control over the technologies, energy sources and operational processes ultimately used within reprocessing facilities.

However, they have limited influence over Category 9 transportation emissions, as downstream transportation is typically arranged and managed by the purchaser or waste contractor. Local authorities have little control over transport distances, logistics or vehicle types once materials have been sold. For Category 12, there is low influence as the end-of-life treatment of products made from reprocessed materials depends on the behaviour of subsequent users and wider waste management systems, although they have indirect influence in their role as waste management authorities.

Calculations effort: High

The calculation approaches for the downstream emissions from the selling of waste to reprocessed into new products are outlined below.

Category	Calculation approach	Effort
Category 9 - Downstream distribution and transportation	Tonnes of waste x distance travelled x EF per vehicle type	Medium
Category 10 - Processing of sold products	Mass of plastics sent for treatment x cradle to gate EF for different types of plastic	High
Category 12 - End-of-life treatment of sold products	Total waste sold x Proportion of plastics expected to be disposed of off-site x EF for disposal method	High

Local authorities are likely to have good data on total waste sold and an indication of the types of waste such as plastics, and the type of vehicle used to transport waste (Category 9). However, data on the emissions from processing of waste into new products (Category 10), and the disposal method for the end products (Category 12) will be harder to obtain and will likely need to rely on assumptions.

A note on the DESNZ Conversion Factors for Waste

With the exception of conversion factors for landfill, the other conversion factors for waste treatment that are published by DESNZ only account for bringing it to the waste management facility. So, for example, it would include the diesel used in a lorry but exclude the emissions from incineration. This means that reporting Category 12 emissions provides limited insight into the relative benefits of end-of-life treatment options other than diversion.

From a decision-making standpoint, this potentially reduces the usefulness of reporting Category 12 because it would not (for example) show the benefit of continuing to recycle the product as opposed to incinerating it.

Given this, and recognising the difficulty of estimating waste quantities and treatment methods in the first place, routine reporting of Category 12 is unlikely to offer value for money at present. However, this should be sense-checked by individual organisations on a case-by-case basis and reviewed in light of potential future changes to the GHG Protocol and DESNZ Conversion Factors.

For Category 10 Processing of sold products, the emission factor used needs to be assessed to ensure it captures the processing activities and not activities such as the transportation to waste facilities.

‘Value for money’ in reporting: No

Although emissions from downstream reprocessing may be moderate, current reporting would rely on extensive assumptions due to limited data on downstream processing and the absence of standardised DESNZ conversion factors for intermediate reprocessing activities. As a result, estimates would be highly uncertain and unlikely to represent value for money. In the meantime, public bodies are likely to achieve greater benefit by using this information to inform procurement and engagement with waste contractors.

However, reporting may become increasingly relevant as local authorities expand the sale of recyclable materials to support Scotland's transition to a circular economy and its net zero by 2045 target. As these activities become more prevalent and reporting methodologies mature, a phased introduction of Category 10 reporting could be considered.

Timescales for reporting: N/a at present, to be reviewed in future

Reporting could be introduced if and when improvements to the DESNZ conversion factors for materials and waste are implemented and clearer guidance on organisational boundary setting relevant to circular economy activities develops within the Greenhouse Gas Protocol.^[58]

B.2.6 Selling of products in gift shops

Impact: 2

Category 9 emissions from public body gift shop sales are likely to be low impact. Whilst impact is highly variable and directly influenced by factors such as delivery distance (local, UK, international), order volumes, parcel weight and composition (e.g. books, ceramics, textiles), courier efficiency and transport mode, overall volumes are assumed to be limited for most public bodies. Nevertheless, the upper bound of Category 9 emissions could theoretically be higher despite low overall sales volumes. This is due to the potential emissions intensity of certain delivery pathways, particularly international and long-distance shipments, which may involve air freight or express courier services, or the sale of heavy products. The exception would therefore be if a public body sold a large volume of products or if these products were heavy or being shipped long distances.

Category 12 emissions are also assumed to be relatively low unless there are high volumes of product being sold. The impacts would vary depending on material type, product longevity and disposal route; for example, reuse, recycling, energy recovery or landfill.

Influence: 3

The main way that public bodies could potentially influence downstream Scope 3 emissions would be by making different decisions about which products to sell. They could also potentially apply geographical limits to sales deliveries, for example by restricting shipping to local or domestic markets to reduce Category 9 emissions. Beyond that, public bodies have limited direct influence over Category 9 emissions arising from gift shop sales, as these are driven primarily by customer purchasing decisions and third-party logistics arrangements once a product is sold online.

Whilst public bodies may encourage click-and-collect or consolidated deliveries to actively reduce emissions, the structure of delivery contracts is often governed by external courier services or fulfilment partners operating at scale. For example, couriers such as Royal Mail already implement system-wide decarbonisation measures, including fleet electrification and route optimisation^[59], which reduce emissions across multiple clients irrespective of individual public body influence.

In addition, operational practices such as split shipments (e.g. where orders are dispatched separately depending on stock availability, as used by organisations such as National Galleries Scotland) are determined by fulfilment systems rather than public body control. Consequently, whilst there is some opportunity to encourage lower-carbon customer choices, overall influence over Category 9 emissions remains limited due to reliance on third-party logistics infrastructure and established delivery networks.

Influence over Category 12 emissions is also relatively limited, aside from deciding what to sell in the first place. Although public bodies can influence upstream design choices through procurement, such as selecting durable, recyclable or low-packaging products, the eventual disposal route is determined by consumer behaviour and wider municipal waste systems.

Calculations efforts: High

The calculation approaches for the selling of products from gift shops are outlined below.

Category	Calculation approach	Effort
Category 9 – Downstream distribution and transportation	Distance transported x tonnes of product sold x EF per type of transportation (e.g. vehicle, shipping or air freight)	High
Category 12 – End-of-life treatment of sold products	Quantity of waste produced (kg or tonnes) x EF for disposal method	High

To calculate Category 9 emissions, public bodies can access order volumes and product sales data through EPOS and online fulfilment systems, and may be able to derive proxy estimates for shipment frequency, parcel weight and delivery distance using courier or logistics provider information. However, granular data on transport mode and actual delivery pathways is generally held by third-party logistics providers and may not be consistently available without supplier engagement.

For Category 12, data availability is low. Public bodies have no direct visibility of how customers dispose of products or packaging once they leave the organisation.

In both cases, the key challenge would be in determining the weight of the products transported. This would involve calculating the weight of each individual product (including packaging) and multiplying it by the number of units. Depending on how records are held, that might be a significant undertaking. Available EPOS and online sales data can be mapped to identify total order volumes, product categories, and indicative shipment profiles along with some high-level assumptions on average parcel weight.

‘Value for money’ in reporting: Subject to individual materiality assessment

Emissions associated with the downstream transport and distribution of sold goods could potentially be material for online sales, particularly where products are shipped over long distances, involve high parcel weights, or are fulfilled through third-party logistics networks. This would need to be evaluated through a materiality assessment.

Compared to other Scope 3 sources, data collection for Category 9 is potentially more feasible, as improved EPOS and fulfilment systems can increasingly capture order volumes, product types and delivery characteristics (e.g. distance and shipment frequency), enabling progressively more robust estimation over time. There is also some scope for influence through procurement and operational choices, such as encouraging click-and-collect, consolidating shipments, and engaging logistics providers on lower-carbon delivery options (including EV delivery fleets).

In contrast, Category 12 emissions are not recommended for routine reporting, as public bodies have very limited influence over end-of-life treatment of sold products and packaging once they are in the hands of customers. Given the limited control over disposal routes and the diffuse nature of emissions, reporting Category 12 is unlikely to represent value for money.

Timescales for reporting: Subject to individual materiality assessment

As part of a materiality assessment for organisations selling large volumes of products.

B.2.7 Medical equipment

Impact: 2

Emissions in Category 9 Downstream transportation and distribution from medical equipment are unlikely to be relevant in most cases. Impact is assumed to be low, due to the rare cases in which emissions do fall into this category.

Emissions associated with Category 11 are likely to be minor in comparison to the magnitude of emissions elsewhere in the supply chain for medical equipment, especially considering embodied emissions. There may be high daily usage of equipment in some cases, such as from electric hospital beds, monitoring equipment, and feed pumps. However, the emissions from the electricity use of medical equipment are assumed to be much lower than the embodied emissions from the metal and other material from which they are made. Additionally, the impact of emissions from electricity use in future would be predicted to be lower under a decarbonised grid, as is planned for Scotland. The only case where Category 11 emissions would not reduce over time is battery use, where emissions will be generated from the production of batteries for the use of medical equipment that requires batteries. However, this is still expected to have a low impact, as the magnitude of emissions from batteries used by equipment is likely to be much smaller than that from the production of metal within the rest of the product.

Emissions that fall under Category 12, End-of-life treatment, are also assumed to be minor in comparison to the emissions elsewhere in the supply chain for medical equipment. Category 12 emissions are likely to be more substantial than Category 11 emissions, especially when accounting for emissions from medical equipment with a short lifespan, such as medical waste. Some emissions under Category 12 are likely to be more uncertain in cases where there is a long lifespan (+20 years), such as for crutches and walkers.

Influence: 2

Influence over the emissions from medical equipment will vary by category. For Category 9 there is low influence over emissions due to the fact the emissions within this category are unlikely to occur. For Category 11, there is low influence over emissions as the need for electric or battery powered medical equipment and the amount it is used is not appropriate to be reduced. For Category 12 emissions from medical equipment, there is some influence over disposal methods at the end of life in cases where equipment has a short lifespan. For instance, recycling schemes, take back schemes and waste management can be managed by NHS trusts for the equipment they distribute.

Calculation effort: High

Approaches for potential calculations are outlined below:

Category	Calculation approach	Effort
Category 9 - Downstream distribution and transportation	Equipment transported (tonnes) x Distance travelled (km) x EF per vehicle type	High
Category 9 - Downstream distribution and transportation	Quantity (L) x EF per fuel type	High
Category 11 - Use of sold products	Hours of appliance use across lifetime (hours) x quantity distributed (L) x electricity consumed per hour (kWh/hour) x EF for electricity	High
Category 12 – End-of-life treatment of sold products	Waste (tonnes) x EF for disposal method	High

For all calculation approaches the effort required to calculate emissions has been ranked as high. This is as it is thought that the data required to conduct different calculations is not readily available, and would require significant effort for NHS boards to collect, e.g.:

• For Category 11 to be calculated, data would need to be collected on the different types of electrical equipment distributed, battery equipment distributed, the quantity distributed, expected hours of use across the equipment’s lifetime, and average electricity consumption for each equipment type per hour. There would therefore be high resource demand to obtain data required to calculate emissions under Category 11.
• For Category 12, data on the tonnage of waste of equipment would need to be obtained. This would involve determining the average mass per product and multiplying this by the number of products of that type. It is expected that it will be high effort to obtain the data required to perform this calculation, although information may be available from purchase records.

However, in future, if data on upstream Scope 3 emissions is collected, some of the required information might become available, e.g. from purchase records. An initial rough estimate or hotspot analysis could then be used to evaluate whether the downstream emissions are likely to be large enough to offer value for money in reporting. If the emissions are deemed to be material, but the calculation effort is still too high, an option could be to report emissions as a one-off or at intervals, and instead either hold emissions constant until a new estimate can be made, or scale, or pro-rate them (e.g. using total purchase amounts or total numbers or volumes where easily obtainable) to derive estimates for subsequent years.

Value for money: No

At present, there is low value for money for reporting downstream emissions from medical equipment distributed. The justification for each category being low value for money for reporting are summarised as follows:

• Category 9: It has been evaluated that emissions from medical equipment distribution that fall under this category are considered unlikely to occur.
• Category 11: It has been evaluated that emissions from medical equipment distribution that fall under Category 11 are of low impact and influence. Additionally, there is likely to be a high reporting effort, due to data that would be needed to be collected on the different types of medical equipment distributed that use electricity or require batteries, as well as their associated electricity or battery use across the equipment’s lifetime.
• Category 12: Emissions from end-of-life treatment of distributed medical equipment are likely to mostly be of low impact and low or medium influence, especially in the case of equipment with a long lifespan. For equipment with a shorter lifespan, there is thought to be higher influence over emissions in Category 12 than for equipment with a longer lifespan. There is however low value for money in reporting emissions from Category 12, due to the high calculation effort and limitations of the DESNZ conversion factors for waste (see Section B.2.2).

Timescales for reporting: N/A

It recommended that for medical equipment most emissions that fall under Scope 3 Group 3 categories are not reported due to their low value for money.

It is instead suggested that a qualitative approach is taken, where the different types of equipment distributed are identified, and the different end of life treatments and take back options assessed that could reduce emissions. This approach is expected to offer a better value for money, as it will address emission reductions under Category 12 whilst avoiding the intensive data collection requirements for calculation and reporting. If or when data becomes available in the future, such as on quantities of equipment purchase, from investigation into upstream scope 3 emissions, reporting for Category 12 should be reconsidered.

B.2.8 Hybrid learning and online courses

Impact: 1

The impact of emissions from hybrid learning and online courses is expected to be low, based on the stakeholder interview with Forth Valley College and rough estimates using data provided by the College following the interview.^[60]

The assessment of the impact of emissions could increase for specific educational bodies in cases where the majority of learning is provided online or longer online courses are facilitated. However, as discussed in Section B.2.7 for medical equipment, impact associated with in use emissions under Category 11 are expected to become less impactful over time due to grid decarbonisation. Additionally, emissions under upstream online platform providers and the selection of these is likely to be more impactful than the downstream emissions.

Influence: 2

Influence over emissions from hybrid learning has been evaluated to be in the low to medium range. There is some influence by public bodies reporting emissions over the proportion of learning that is provided in a hybrid setting rather than only in person. However, provision of hybrid learning and online courses through educational bodies to some extent is important to maintain for accessibility to educational materials.^[61]

Calculation effort: Low to medium

The calculation approaches proposed for emissions from Category 11 from hybrid learning and online courses are summarised below:

Calculation approach	Effort
[Total time of participation (hours) based on average time per student] x EF for office equipment use	Low
[Total time of participation (hours) based on more detailed analysis of online learning time for different courses] x EF for office equipment use	Medium
[Total time of participation (hours)] x Typical electricity consumption of laptops (kWh/hour) x EF for electricity	Medium

The main effort in calculation would be estimating the total time of participation in online courses, which would be low effort if based on assumptions about the average hours per student. Optionally, it would be possible to undertake a more detailed estimate either by refining the estimated number of hours or integrating assumptions about typical laptop energy use, both of which would be medium effort.

Value for money? No, except for institutions offering a large component of online courses, subject to a materiality assessment

Due to the low impact and influence, in most cases the value for money of reporting emissions from hybrid learning and online courses has been evaluated to be low. An exception to this may be educational bodies which provide a large online component of courses or longer online courses. Although, the impact of any emissions from hybrid learning and online courses that fall under Category 11 are expected to decrease due to grid decarbonisation, as highlighted in Section 5.5.7. Public bodies that provide a large enough online component of courses should review whether the emissions from electricity use are significant as part of their materiality assessment.

Timescales for reporting: Subject to individual materiality assessment

If there is a large online component, this should be explored as part of an individual materiality assessment. If the emissions are found to be material, then reporting should commence in the short term with a low-effort calculation approach. Optionally, the level of detail could increase over time subject to resource availability, but due to grid decarbonisation this is unlikely to be a good use of resources which would arguably be better spent on GHG mitigation efforts.

B.2.9 Other Products

Impact: Not rated

The impact of emissions from other products is likely to be highly dependent on the activity and product being sold.

Influence: Not rated

It has been assumed that public bodies generally have low influence over the downstream emissions of other products sold. For instance, it is unlikely that they will have influence over emissions from downstream transportation that would fall under Category 9. Additionally, emissions from the end-of-life treatment of products may be uncertain given long life-span of some products such as garden furniture, or be in the hands of the consumer, as with theatre brochures.

Value for money: Subject to individual materiality assessment

The materiality of emissions associated with other products distributed and sold by public bodies has not been possible to evaluate as part of this research. This is due to the individual nature of other products being sold by public bodies, high reporting effort, and expected low impact and influence over these emissions. However, this would need to be evaluated on a case-by-case basis by each public body as part of its own materiality assessment.

Timescales for reporting: Subject to individual materiality assessment

It is recommended that in the occasional instances where public bodies do sell other products than those specified in the activities listed in this research, a materiality assessment is conducted by that public body. This materiality assessment can then guide whether reporting emissions from these products under Scope 3 Group 3 categories should be reported, based on the estimated impact of the emissions from the sold product and influence over these emissions.