If you're a sustainability manager at a manufacturer with 500–5,000 employees and you're facing your first mandatory ESG disclosure deadline, the volume of guidance available is not the problem. The problem is that most guidance is written for companies with dedicated ESG teams of six or more people, external sustainability consultants on retainer, and years of voluntary reporting experience to draw from.
This checklist is for the person who is probably also handling environmental compliance, vendor due diligence, and three other functions simultaneously — and needs to know, practically, what to do in what order to get to a defensible first disclosure. It's organized around the CSRD / ESRS E1 climate disclosure track, which is what most mid-market manufacturers will encounter first through EU customer pressure or direct in-scope obligations. The SEC climate disclosure requirements, where applicable, follow a similar data logic but different procedural requirements.
This is not a complete ESRS coverage guide — ESRS has 12 topical standards beyond E1 covering biodiversity, social, governance, and more. This checklist covers the climate track, specifically the GHG emissions data work that underpins any credible climate disclosure.
Before You Calculate Anything: Foundation Steps
1. Confirm whether you are directly in scope for CSRD or responding to customer pressure. CSRD directly applies to large EU companies (250+ employees, €40M+ revenue, or €20M+ assets) and EU-listed companies. Mid-market US manufacturers are currently in scope only if they are subsidiaries of EU-listed parents, or if they have EU-listed shares. However, many mid-market manufacturers are in scope indirectly — their EU customers are subject to CSRD and request Scope 3 Category 1 and 4 data from their supply chain. Know which situation you're in before deciding how comprehensive your first disclosure needs to be.
2. Define your organizational boundary and document it. Operational control is the standard choice for most manufacturers: include all facilities over which you have operational authority. Write a one-paragraph boundary statement listing which legal entities and facilities are included and noting any exclusions. This document becomes the front matter of your methodology disclosure. Do this before calculating anything — the boundary defines what goes into your calculations.
3. Establish a base year. Your base year is the reference point for future emissions reduction tracking. Choose the most recent year for which you can assemble complete and verifiable source data. For most manufacturers doing this in 2024, that means 2022 or 2023 depending on when your data archive becomes complete. Document the rationale for your base year choice.
4. Identify your data custodians. Before you can calculate anything, you need access to: utility invoices (typically in accounts payable), fuel purchase records (fleet department or operations), refrigerant service records (facilities/maintenance), freight manifests or TMS data (logistics or supply chain), and procurement spend data by category (purchasing). These data sets live in different departments. Getting access is a stakeholder management task, not a technical one. Start early.
Scope 1: Direct Emissions from Your Operations
5. Pull all natural gas invoices for all facilities, last two full calendar years. Check that every account number is present and that you have 12 invoices (or equivalent) per account. Missing months are a common problem. Therms or MCF convert to MMBtu using the invoice conversion factor if stated, or EPA Table C-1 standard factors.
6. Pull diesel and gasoline fuel records for company-owned vehicles and mobile equipment. This includes forklifts, company cars, delivery vans, and any on-site heavy equipment running diesel or gasoline. If you operate a significant vehicle fleet, EPA Table C-1 mobile combustion factors by fuel type are the standard reference.
7. Compile refrigerant purchase and recharge logs. HFC refrigerants used in HVAC and refrigeration systems have very high global warming potentials — R-410A is 2,088 CO2e per kg; R-22 is 1,810. A single refrigerant top-off can be a significant Scope 1 emission event. Your facilities or maintenance team should have service records. Missing refrigerant data is one of the most common Scope 1 gaps we see.
8. Check for process emissions. If your manufacturing processes involve chemical reactions that release CO2 or other GHGs directly (e.g., metal smelting, cement processes, chemical production), these are Scope 1 process emissions separate from combustion. Most discrete manufacturers do not have significant process emissions; verify rather than assume.
Scope 2: Purchased Electricity and Heat
9. Pull all electricity invoices for all facilities. Same completeness check as natural gas. Confirm that each account maps to a specific facility with a known zip code for eGRID subregion assignment.
10. Look up the eGRID subregion for each facility. EPA's eGRID website allows you to look up the subregion by zip code or utility service territory. Record the subregion code (e.g., MROE for Midwest Reliability Organization East) and the most recent annual emission factor from the published eGRID table. Use the year-appropriate factor — eGRID emission factors change annually as the grid mix changes.
11. Determine your market-based factor. If your company has purchased Renewable Energy Certificates or has a Green Power purchase agreement with your utility, you need the contractual emission factor for the REC or agreement. If you have no renewable contracts, your market-based factor is the residual mix factor for your utility territory, published by Green-e or the relevant regional renewable energy tracking system (NEPOOL-GIS, M-RETS, WREGIS, etc.).
12. Check for purchased steam or chilled water. Uncommon for standalone manufacturers but relevant for facilities in shared industrial parks or connected to a district energy system. If present, the emission factor comes from the energy provider's disclosure.
Scope 3: Value Chain Emissions
13. Complete a materiality assessment before calculating any category. The GHG Protocol Scope 3 Standard provides a qualitative screening methodology. Assess each of the 15 categories as high/medium/low materiality based on: your spend in that category, typical emission intensity for your industry, and the availability of data. Document your assessment with a rationale for each category. This document justifies what you calculated and what you excluded.
14. For Category 1 (purchased goods and services), start with your top 10 suppliers by spend. Request Scope 1 + Scope 2 data from each, or look up their CDP disclosure if they are a public company. For suppliers without self-reported data, apply ecoinvent or EPA USEEIO emission factors by material category. Note in your methodology which suppliers are supplier-specific versus estimated.
15. For Categories 4 and 9 (freight), pull TMS or carrier invoice data. You need shipment weight, origin, destination, and mode. Calculate tonne-kilometers and apply mode-specific emission factors. If carrier EDI data is available, use it; if not, parse invoice data.
16. For Category 5 (waste), pull waste manifests. Your facilities team should have these. You need waste type (solid, hazardous, wastewater), weight by type, and disposal method (landfill, incineration, recycling). EPA emission factors for solid waste by disposal method are published in the GHG Reporting Program technical guidance.
17. For Category 6 (business travel) and Category 7 (employee commuting): These are often lower materiality for manufacturers but straightforward to estimate. Business travel: pull company credit card or travel management data for air travel (miles × emission factor) and rental car/hotel. Employee commuting: survey-based or commuting zone average approach.
Documentation and Disclosure Readiness
18. Write your methodology statement. One to two pages covering: organizational boundary, base year, scope definitions, emission factors used by category (source and version), and calculation approach. This is what your verifier reads first and what your auditor will reference for any questions about your disclosed figures.
19. Build a data quality disclosure. For each Scope 3 category you've calculated, note whether the data is supplier-specific, activity-based, or spend-based. Note where estimates were used and the confidence level. ESRS E1 and GHG Protocol both expect transparency about data quality, not perfection.
20. Establish data retention protocols. Every source document used in your calculations — invoices, manifests, questionnaire responses — needs to be retained and accessible for at least five years. Your disclosure year's data needs to be retrievable if your verifier comes back with questions 18 months after filing.
A note on what this checklist doesn't cover: the "E" in ESG is only one dimension. Social disclosures (workforce data, health and safety metrics, supply chain labor) and Governance disclosures (board oversight, risk management) are required under ESRS S and G standards for CSRD-scope filers. We've focused on GHG and climate here because that's where the data infrastructure work is most intensive and where first-time reporters consistently hit the most friction. The social and governance data is typically more accessible — it exists in HR systems and board minutes — but it needs its own systematic review.
— Natasha Rivera, CEO & Co-Founder, Circulyft