Double claiming of agricultural carbon credits: time to stop worrying

Unofficial AI-generated summary based on the public title and abstract. Not an official translation.

🔬研究者:A critical analysis of double-claiming rules in scope 3 accounting, revealing fundamental inconsistencies in GHGP/SBTi guidance and offering a clearer conceptual framework for attribution. Valuable for scholars studying carbon accounting, carbon markets, and climate disclosure.

🏢実務担当者:If your company sources agricultural products and faces scope 3 reporting challenges, this paper provides arguments and regulatory recommendations to avoid adjusting inventory for supplier-sold credits, potentially simplifying supply chain decarbonization finance.

🏛政策担当者:Policymakers working on carbon credit regulations (e.g., CRCF, J-クレジット) should note the distinction between active and passive claims; the paper recommends explicit clarification in ESRS and CRCF to avoid double-standard and unlock agricultural climate finance.

In France, after seven years of the French “Low Carbon Label” (le Label bas carbone, LBC) certification scheme, there remainsa systemic lack of funding for agricultural projects. The agri-food companies that would naturally be well placed to fund low-carbon agriculturalprojects are turning away from them and even discouraging their own suppliers from taking part in the LBC scheme.Among the reasons mentioned by the agri-food industries is the fear of “double claiming”. Agri-food companies fear being unableto account, in their scope 3 GHG inventory, for the emissions reductions and carbon removals achieved by their suppliers, once these are soldto a third party in the form of carbon credits.The GHG Protocol (GHGP) and the Science Based Targets initiative (SBTi) — two leading frameworks for private-sector decarbonisation —both restrict this “double claiming” in principle.Both frameworks require climate mitigation claims to be exclusive: the same emission reduction or carbon removal cannot beclaimed simultaneously by the third party that purchases the carbon credit and by the agri-food company that records it in its scope 3inventory to track progress towards its climate tar-gets.I4CE demonstrates that the prohibition of double claiming is, most often, neither justified nor operational. It is indeed men-tioned in the texts of the GHGP and the Sbti. But it goes against the very logic of scope 3account-ing. And the conditions required to trigger an ac-counting adjustment are rarely met.• A rule structurally ill-suited to scope 3. Scope 3 is by nature “the realm of double counting”: a reduction or removal achieved bya farmer mechanically appears in the scope 3 of all its downstream customers. It is a fundamental property of this kind of accounting,explicitly recognised by the GHGP itself, not an anomaly. Financing a reduction does not imply monopolizing its accounting effects. Theprohibition of double claiming confuses the “active” claim made by a funder, who asserts to have made an emissions reductionor carbon removal possible, with the “passive” claim of a GHG inventory, which merely takes a snapshot ofphysical GHG flows.• Tracking progress towards corporate targets is a borderline case. When a company sets a mitigation target and tracks progress viaits GHG inventory, the GHGP prohibits it from counting an emissions reduction or carbon removal if the corresponding carbon credits have been sold to a third party. This is understandable.But the same logic should equally exclude reductions and removals attributable to climate change or to a supplier's autonomous initiative,both pervasive in scope 3. I4CE favours the opposite approach: measuring progress based onphysical GHG inventory, regardless of who funded the reductions or removals. This approach isimperfect in attributional terms but is both consistent and operational.• An unworkable rule that even the standards themselves apply only under rarely met conditions. To avoid double claiming,a company should theoretically reintegrate into its GHG inventory the emissions corresponding to the credits sold. But this adjustment isonly required when the company has precise enough data to "see" the reduction at the farmlevel, which is rarely the case, since agri-food inventories rely on statistical averages. Moreover, this rule is unverifiable, given the lack ofphysical traceability and the absence of cross-verification between credit registries and scope 3 inventories.• A self-defeating rule penalizing farmers. As a precaution, some agrifood companies dissuade their farmers from joiningthird-party carbon certification projects or impose exclusivity clauses that prevent themfrom accessing climate finance, without any solid legal or moral justification.A blockage that can be overcome without delay. No legal obligation under French law requires the exclusivity of carbon claims between ascope 3 inventory and the sale of credits outside the value chain. Existing frameworks are sufficient:4 June 2026 French regulatory GHG inventories, as well as the CSRD, already separate the GHG inventory from the disclosure of credits and project financing. I4CE recommends that European regulations (ESRS and CRCF) clarify that an emissions reduction or a carbon removal thathas generated a carbon credit may legitimately appear in the scope 3 inventory that an agri-food company publishes under theCSRD, regardless of who funded that credit. This falls under the “passive” claim, the mere observation of physical flows, and not under the“active” claim of the funder. The sale of a credit by a supplier therefore does not require its downstream customers to adjust their scope 3 inventory, andthe obstacle is lifted without undermining the integrity of reporting.

• openalex https://hal.inrae.fr/hal-05680867first seen 2026-07-13 06:03:25