Managing the Change in SpendBased Emission Factors
What Companies Need to Know
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October 29, 2026
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Companies that rely on spend-based methods to calculate Scope 3 emissions may soon face a meaningful change in how those emissions are measured.
USEEIO and CEDA, two datasets that underpin a significant share of corporate Scope 3 calculations, have been combined into a single global, multiregional model. This is more than a routine update to emission factors. For some companies, the shift could materially change reported Scope 3 emissions even when their underlying operations and supplier base have not changed.
That creates more than a carbon-accounting issue. Changes in reported emissions could affect progress against Scope 3 targets, product footprints, customer disclosures, contractual representations and sustainability claims. Depending on the magnitude of the change, companies may also need to revisit previously reported emissions or recalculate historical inventories.
Who Could Be Most Affected?
The impact will vary significantly by company.
Organizations may face greater exposure if they:
- Rely heavily on spend-based estimates for their Scope 3 inventory
- Source significant volumes internationally
- Purchase from sectors where emissions intensity varies considerably by geography
For some companies, the effect may be limited. For others, a methodological change could result in a meaningful shift in reported emissions without any corresponding change in actual business activity.
That distinction will matter when companies explain changes in performance to boards, investors, customers, regulators and other stakeholders.
Why Companies Should Prepare Now
This transition comes as companies are already navigating an evolving emissions reporting landscape.
California’s SB 253 is bringing Scope 3 emissions into the reporting cycle. SBTi’s Corporate Net-Zero Standard V2.0 takes effect in 2027, and proposed revisions to the GHG Protocol Scope 3 Standard would bring greater visibility to the use of spend-based calculations.
Together, these developments could place greater scrutiny on the methodologies, emission factors, assumptions and data companies use to calculate and report emissions.
Companies can take several steps now to prepare.
Quantify your exposure. Determine how much of your Scope 3 inventory relies on spend-based factors, where international sourcing is concentrated and which categories or sectors could be most sensitive to a methodology change. This will help companies understand the potential magnitude of changes to their GHG inventories.
Strengthen governance and controls. Review base-year recalculation policies, including significance thresholds and how changes to third-party emission factors are treated. Companies should also establish clear processes for documenting methodologies, assumptions, judgments and approvals associated with any recalculation.
Prepare for potential restatement and communication. A methodology change can make reported emissions appear to rise or fall even when actual business operations have not changed. Companies should be prepared to explain the difference between a measurement change and a change in operational performance, and consider how revised figures could affect targets, transition plans, product footprints, customer disclosures and other external claims.
Better measurement should ultimately strengthen corporate carbon accounting. But without preparation, better measurement can look like worse performance.
Companies that understand their exposure early will be better positioned to manage any recalculation, explain changes clearly and maintain confidence in their reporting.
Read the Full Whitepaper
Our whitepaper, Managing the Change in Spend-Based Emission Factors: What Companies Need to Know, takes a deeper look at the expected USEEIO-CEDA transition, how changes to emission factors could affect greenhouse gas inventories and Scope 3 targets, when recalculation may be required and practical steps companies can take to prepare internally and externally.
Have questions about how this transition could affect your inventory, targets or product footprints? Connect with our team to discuss how we can help.
The views expressed herein are those of the author(s) and not necessarily the views of FTI Consulting, Inc., its management, its subsidiaries, its affiliates, or its other professionals.
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Published
October 29, 2026
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