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For a European food group, the agricultural products it buys are its “Scope 3” emissions, so a question about greenhouse gases per tonne of product will sooner or later reach the desk of a Vietnamese supplier, through a questionnaire or a contract clause. In 2026 the EU sharply narrowed the scope of the CSRD and the CSDDD and introduced a “value-chain cap” to protect smaller suppliers, but buyers’ climate commitments and a new accounting standard for agriculture keep that question on the table.
Key points
- Under the GHG Protocol, Scope 3 covers all indirect emissions in the value chain, divided into 15 categories. The Scope 1 and 2 emissions of a Vietnamese plant or growing area become part of the buyer’s Scope 3.
- Directive (EU) 2026/470 of 24 February 2026 narrows the CSRD to companies with more than 1,000 employees and more than EUR 450 million in turnover, and the CSDDD to more than 5,000 employees and more than EUR 1.5 billion, applying from 26 July 2029.
- Companies in the value chain with no more than 1,000 employees may refuse to provide information beyond the voluntary standard, but this right applies only to sustainability reporting under EU law.
- In Vietnam, Decision 42/2026/QD-TTg, in force since 25 September 2026, updates the list of facilities that must carry out greenhouse gas inventories; the thresholds are 3,000 tonnes of CO₂ equivalent or 1,000 TOE per year.
Scopes 1, 2 and 3: where a supplier’s emissions sit in the buyer’s accounts
The Corporate Value Chain (Scope 3) Accounting and Reporting Standard, published by the GHG Protocol in 2011, divides Scope 3 emissions into 15 categories, both upstream and downstream. For food processors and food retailers, purchased agricultural products and ingredients fall under category 1 (purchased goods and services), and transport paid for by the buyer falls under category 4. In other words, when buyers calculate Scope 3, they need the very figures that suppliers calculate for their own Scope 1 and 2, plus the emissions at the growing area.
| Scope | Content | Examples at agri-food plants and growing areas |
|---|---|---|
| 1 | Direct emissions from sources the company owns or controls | Boilers burning coal, oil or firewood; diesel forklifts and tractors; refrigerant leaks; nitrogen fertiliser applied on growing areas the company manages itself |
| 2 | Indirect emissions from purchased energy | Grid electricity for cold stores, evaporators and dryers; steam bought from outside |
| 3 | All other indirect emissions in the value chain | Produce bought from smallholders, inputs, packaging, outsourced transport, waste treatment |
According to the GHG Protocol, agriculture and land-use change account for roughly a quarter of global emissions. That is why most questions buyers send to agricultural suppliers revolve around the growing area: where the product is grown, whether it encroaches on forest, how much fertiliser is applied, and how much fuel and electricity go into each tonne of finished product.
EU law after the 2026 Omnibus: who still reports, and who still gets asked
Directive (EU) 2026/470 of the European Parliament and of the Council, signed on 24 February 2026 and published in the Official Journal on 26 February 2026, amends both the Accounting Directive 2013/34/EU (which contains the CSRD provisions) and the Corporate Sustainability Due Diligence Directive (EU) 2024/1760 (CSDDD). The consolidated version of Directive 2013/34/EU dated 18 March 2026 incorporates these changes.
| Item | Current rules |
|---|---|
| CSRD: EU companies that must report | Net turnover above EUR 450 million and more than 1,000 employees on average; the new thresholds apply to financial years starting on or after 1 January 2027 |
| CSRD: non-EU groups | EU turnover above EUR 450 million for two consecutive years, and an EU subsidiary or branch with net turnover above EUR 200 million |
| Value-chain cap | A “protected undertaking” is a company in the value chain with no more than 1,000 employees on average; the reporting company may not demand information beyond the voluntary standard (Article 29ca) |
| CSDDD: scope | More than 5,000 employees and more than EUR 1.5 billion worldwide turnover; non-EU companies: more than EUR 1.5 billion turnover in the EU |
| CSDDD: timeline | Member States transpose by 26 July 2028; application from 26 July 2029 |
The value-chain cap has three limits worth reading closely. The reporting company may rely on the supplier’s self-declared size, and when it asks for more than the voluntary standard it must state which part goes beyond it and that the supplier has the right to decline. The cap does not prohibit voluntary information sharing, does not remove obligations already in a contract, and does not apply to information gathered for other purposes such as supply-chain due diligence or risk management. During the first three years, if value-chain data are missing, the reporting company must explain the efforts it has made; after that it uses data obtained directly from suppliers or estimates.
The ESRS reporting standards are also being slimmed down. On 3 July 2026 the European Commission adopted revised ESRS, cutting mandatory datapoints by more than 60%, together with a voluntary standard for companies outside the CSRD scope. Both acts are still under scrutiny by the Parliament and the Council and are not in force until published in the Official Journal.
Beyond the law: SBTi FLAG targets and the GHG Protocol’s new land standard
EU law is only one source of these questions. The second is buyers’ voluntary climate commitments. Under the SBTi FLAG (forest, land and agriculture) guidance, companies in food production, food and beverage processing, food and staples retailing, and tobacco must set FLAG targets; companies in other sectors must also do so if FLAG emissions exceed 20% of their total Scope 1, 2 and 3. A no-deforestation commitment is mandatory, with a cut-off date of 2020 or earlier; the long-term target is to cut FLAG emissions by at least 72% no later than 2050. SBTi published version 1.2 of the FLAG guidance in March 2026.
The third source is accounting standards. On 30 January 2026 the GHG Protocol released the Land Sector and Removals Standard, effective from 1 January 2027. It applies to companies that produce, buy or sell agricultural products at any point in the chain, and it is the first GHG Protocol standard with traceability requirements for Scope 3 emissions: only companies that know where their products are grown can account for climate benefits at farm level. This version does not cover forestry.
Vietnam: domestic inventory obligations are the foundation
Under Article 6(1) of Decree 06/2022/ND-CP (consolidated text 40/VBHN-BNNMT of 27 March 2026, incorporating the amendments of Decree 119/2025/ND-CP and Decree 83/2026/ND-CP), facilities that must carry out greenhouse gas inventories are those emitting 3,000 tonnes of CO₂ equivalent or more per year, or industrial facilities consuming 1,000 tonnes of oil equivalent (TOE) of energy or more per year, along with certain other types of facility. Listed facilities carry out an inventory every two years for 2024 onwards and submit the report to the provincial People’s Committee before 31 March (Article 11(4)).
Decision 42/2026/QD-TTg, signed on 10 August 2026 and in force since 25 September 2026, replaces Decision 13/2024/QD-TTg. According to a summary by the Vietnam Cleaner Production Centre (VNCPC), the new list contains 2,441 facilities, of which 1,916 fall under the industry and trade sector. Facilities on the 2024 list that no longer appear on the new list are exempt from submitting inventory reports from 2027, that is, for 2026 data.
A facility-level inventory report answers how much the plant emits. Foreign buyers usually need a different figure: emissions allocated to each tonne of product they buy, plus the emissions at the growing area. Both sets of figures draw on the same activity data, such as electricity, fuel and output, so a company that already carries out inventories under Decree 06 has a base from which to respond faster.
What companies should do
The following are AgrifoodV’s recommendations.
- Record activity data monthly: electricity (kWh), boiler fuel, refrigerant top-ups and finished output. From these, calculate Scope 1 and 2 and divide by tonnes of product, because this is the first figure buyers ask for.
- Build a growing-area file: coordinates, area of each block, fertiliser and fuel use, and evidence that the land has not been converted from forest after the cut-off date the buyer requires. These data are also the foundation of a traceability system linking growing areas to the processing plant.
- When you receive a questionnaire, ask the buyer what the data will be used for. A company with no more than 1,000 employees may limit its answers to the voluntary standard if the purpose is CSRD reporting; even so, without its own figures the buyer will use average estimates, and a supplier that performs well loses the chance to prove it.
- Check whether your facility is named in the annexes to Decision 42/2026/QD-TTg; if it is, prepare the inventory report for submission to the provincial People’s Committee before 31 March.
AgrifoodV helps companies design processing plants and operating data systems that meet international buyers’ requirements. How to record costs and inputs by block is also discussed in the article on budget versus actual by block.
References
- GHG Protocol (WRI, WBCSD). Corporate Value Chain (Scope 3) Accounting and Reporting Standard, 2011. ghgprotocol.org.
- GHG Protocol. GHG Protocol launches its first-ever global standard for corporate accounting in the land sector, 30 January 2026; Land Sector and Removals Standard v1.1, 30 June 2026. ghgprotocol.org.
- European Union. Directive (EU) 2026/470 of 24 February 2026 amending Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760, OJ L 26 February 2026. eur-lex.europa.eu.
- European Union. Directive 2013/34/EU, consolidated version of 18 March 2026 (CELEX 02013L0034-20260318), Articles 19a, 29a, 29ca, 40a. eur-lex.europa.eu.
- European Commission. Commission adopts revised sustainability reporting standards, 3 July 2026. finance.ec.europa.eu.
- Science Based Targets initiative. Forest, Land and Agriculture (FLAG), FLAG Guidance Version 1.2, March 2026. sciencebasedtargets.org.
- Ministry of Agriculture and Environment. Văn bản hợp nhất số 40/VBHN-BNNMT ngày 27/3/2026, Nghị định quy định giảm nhẹ phát thải khí nhà kính và bảo vệ tầng ô-dôn [Consolidated text 40/VBHN-BNNMT of 27 March 2026, Decree on greenhouse gas mitigation and ozone layer protection], Articles 6 and 11 (copy published by the Nghe An Provincial People’s Committee). nghean.gov.vn.
- Prime Minister of Vietnam. Quyết định số 42/2026/QĐ-TTg ngày 10/8/2026 ban hành Danh mục lĩnh vực, cơ sở phát thải khí nhà kính phải thực hiện kiểm kê khí nhà kính (cập nhật) [Decision 42/2026/QD-TTg of 10 August 2026 on the updated list of sectors and facilities required to carry out greenhouse gas inventories], Articles 1–3 (PDF posted by VASEP). vasep.com.vn.
- Vietnam Cleaner Production Centre (VNCPC). 2.441 cơ sở phải kiểm kê khí nhà kính: Doanh nghiệp cần lưu ý gì? [2,441 facilities must carry out greenhouse gas inventories: what should companies note?] vncpc.org.
Article by AgrifoodV, compiled from the sources above (accessed 29 October 2026). The number of facilities by sector on the Decision 42/2026/QD-TTg list follows the VNCPC summary and has not been recounted from the original annexes. The recommendations are AgrifoodV’s assessment. This content is not a substitute for legal advice. Cover image: Quang Nguyen Vinh / Pexels.
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