An IKEA supplier in Panipat receives a new ESG questionnaire. The previous version asked for Scope 1 and Scope 2 emissions — that section was manageable. Incomplete, consultant-estimated, but manageable.
The new version has a third column: Scope 3.
The compliance consultant is not sure how to answer it. The factory manager escalates to the CFO. The CFO calls the consultant group manager. Three weeks later, the response section has been marked “data not currently available.” The buyer accepts it — this time.
The next questionnaire cycle is six months away. The buyer’s internal ESG procurement score, which no one explained to the manufacturer, now has a notation.
This is the Scope 3 situation for Indian textile and manufacturing exporters in 2026. Not crisis yet. But the gap is accumulating.
What Scope 3 Actually Is — and Why It Is Arriving Now
Scope 3 emissions are all indirect greenhouse gas emissions in a company’s value chain that are not covered by Scope 1 (direct emissions from operations) or Scope 2 (purchased energy). The GHG Protocol defines 15 Scope 3 categories, split between:
- Upstream (Categories 1–8): Emissions from the supply chain coming into your operations
- Downstream (Categories 9–15): Emissions from your products going out into the world
The reason Scope 3 is arriving in Indian manufacturer questionnaires now — rather than five years ago — is the EU’s Corporate Sustainability Reporting Directive (CSRD).
CSRD requires large European companies (revenue >€150M, or listed) to disclose their Scope 3 emissions. Their Scope 3 includes Category 1: Purchased Goods & Services — which means the emissions embedded in everything they buy from their supply chain. An IKEA supplier in Panipat producing home furnishings is embedded in IKEA’s Category 1 Scope 3.
IKEA cannot satisfy its CSRD obligation without data from Indian suppliers. The questionnaire is the mechanism. “Data not available” is an acceptable answer in 2025. By 2027, it will not be.
The 15 Scope 3 Categories — Which Actually Apply
Not all 15 categories are equally relevant for a typical Indian textile or general manufacturing exporter. Here is the practical breakdown:
High Priority — EU Buyers Are Already Asking
Category 1: Purchased Goods & Services The carbon intensity of the raw materials and inputs you buy. For textile manufacturers: cotton, yarn, synthetic fibres, dyes, and chemicals. For general manufacturers: steel, components, packaging.
This is the category EU buyers most frequently request. The calculation method can be either:
- Spend-based: spend × ₹/tCO₂e industry average factor (lower accuracy, faster to implement)
- Activity-based: kg of input × tCO₂e per kg factor from supplier or database (higher accuracy)
Category 4: Upstream Transportation and Distribution Emissions from transporting goods and materials to your facility — from supplier to your gate. For most Indian manufacturers, this means domestic logistics (road, rail) and sometimes international imports.
The calculation is straightforward: distance × weight × transport mode emission factor (from IPCC or Defra factors).
Category 12: End-of-Life Treatment of Sold Products How are your products disposed of at end of life? For textile exporters, this has become an explicit question as EU buyers respond to Extended Producer Responsibility under EU textile regulations.
Medium Priority — Asked by More Sophisticated Buyers
Category 3: Fuel- and Energy-Related Activities Upstream extraction, production, and transmission losses for the fuels and electricity you use. This adds approximately 15–20% to Scope 1 & 2 for most manufacturers. Some buyers include it in their supply chain carbon intensity calculations.
Category 5: Waste Generated in Operations Emissions from the waste your operations generate — what disposal method, what landfill gas, what recycling. For process-heavy manufacturers (dyeing, finishing), this can be material.
Category 6: Business Travel Flights, hotel stays, local travel for business purposes. Typically low materiality for manufacturing exporters, but appears on buyer questionnaires as a completeness check.
Category 7: Employee Commuting Average commute distance and mode for your workforce. Standard in comprehensive ESG questionnaires. Calculation: employees × average commute distance × mode split × emission factor.
Lower Priority — Most Indian Exporters Can Defer
Categories 8 (Upstream Leased Assets), 9 (Downstream Transportation), 10 (Processing of Sold Products), 13 (Downstream Leased Assets), 14 (Franchises), and 15 (Investments) are rarely relevant for Indian manufacturing exporters in the current questionnaire cycle. Document them as “not applicable” with a one-line rationale.
Category 11 (Use of Sold Products) is relevant for appliance manufacturers (the product uses energy when the consumer operates it), but typically not applicable for textiles, furniture, or non-energy products.
What Your Buyer Is Actually Asking For
Real Scope 3 questions from EU buyer ESG questionnaires in 2025–26 follow a pattern that, once you understand it, becomes manageable:
“What is the carbon intensity of your primary raw materials?” This is Category 1. They want either a kg CO₂e per kg of product figure, or a methodology statement explaining how you have categorised your raw material inputs. A spend-based estimate with a clear methodology note is acceptable at this stage for most buyers.
“What emissions are generated in transporting goods to our distribution centres?” This is Category 9 (Downstream Transportation) — but buyers often conflate it with Category 4. They want a tCO₂e per tonne-kilometre figure for your primary shipping mode (sea, road, air). Shipping emission factors are well-established and this calculation is straightforward once you know the weight and distance per shipment.
“Do you track the end-of-life emissions of your products?” Category 12. Most Indian exporters currently answer “no, not tracked.” The sophisticated answer is: we use industry average disposal rates for the relevant product category in the destination market. Some EU buyers (especially in fashion and home goods) now provide their own end-of-life assumption tables to suppliers.
“What is your total value chain emission intensity per unit shipped?” This is the comprehensive request — Scope 1 + Scope 2 + relevant Scope 3 categories combined, per tonne, per unit, per ₹ value. It requires having all three scopes at least approximately calculated. This is increasingly the direction of travel for tier-one EU buyers.
The Practical Sequence — Where to Start
The correct sequencing prevents wasted effort:
Step 1: Get Scope 1 & Scope 2 right first. Every Scope 3 calculation requires a credible Scope 1 & 2 foundation. Category 3 is calculated from your Scope 1 & 2 data. Your total value chain intensity starts with Scope 1 & 2. Buyers requesting Scope 3 data will also scrutinise whether your Scope 1 & 2 methodology is credible. Start with Scope 1 and Scope 2 before touching Scope 3.
Step 2: Category 1 — primary raw materials. For most Indian textile exporters, this means cotton, yarn, and synthetic fibres as the dominant material inputs. Use a spend-based calculation for the first cycle:
- Annual spend (₹) × ₹/tCO₂e factor for the material category
- Source: Defra UK Scope 3 factors (textile industry averages), or IPCC demand-side factors
Document the methodology clearly. Buyers are not expecting perfect accuracy in 2026 — they are expecting documented methodology and transparency about assumptions.
Step 3: Category 4 — upstream logistics. Collect annual inbound freight data: total tonnes per shipping mode (road, rail), distance per major supplier cluster. Apply IPCC or Defra transport emission factors. This takes one afternoon with the logistics team.
Step 4: Product and buyer questionnaire export. Export the data in the format the buyer requests — whether a spreadsheet template, a CDP questionnaire portal response, or a CSRD-aligned supplier disclosure form.
How This Connects to BRSR
BRSR Principle 6 currently requires Scope 3 emissions disclosure only if the company determines it is “material.” Most manufacturers claim non-materiality and skip Scope 3.
This position is becoming harder to sustain as buyer pressure increases. When your largest customer requires Scope 3 data for their own mandatory CSRD filing, materiality is no longer a self-assessed question — it is determined by the commercial relationship. The manufacturer who has pre-built their Scope 3 calculation can respond to both the BRSR requirement and the buyer requirement from the same data source.
Getting ahead of the buyer cycle is a competitive position, not just a compliance act. Manufacturers who can respond to ESG questionnaires in 48 hours with defensible, documented data are differentiated from those who take three weeks with an estimate. That differentiation shows up in sourcing decisions — quietly, without announcement.
The first Scope 3 step is getting Scope 1 & 2 right. Sustaineve’s data collection and measurement modules build the verified foundation — and the Scope 3 extension modules connect when you are ready. The multi-framework reporting module then exports to BRSR, GRI 305, and CSRD supplier formats from the same verified dataset.
Download the EU Buyer ESG Questionnaire Handbook → — a practical guide to what EU buyers are asking and how to prepare.