The Voluntary Carbon Markets Integrity Initiative (VCMI) has introduced a new code to guide how companies can handle Scope 3 emissions—the indirect emissions from a company’s value chain. Called the Scope 3 Action Code of Practice, the proposal allows companies to use high-quality carbon credits to help address gaps in their Scope 3 targets.
This new approach is attracting both strong support and sharp criticism. While some welcome the extra flexibility, others warn it could delay real climate action. This article explains what the new guidance means, why it matters, and how different stakeholders are responding.
Understanding Scope 3 Emissions
Scope 3 emissions are all the indirect emissions that happen in a company’s supply chain and product use—such as emissions from suppliers, product transportation, or even customer use of a product. For most companies, Scope 3 emissions make up the largest part of their total carbon footprint.
Yet, these emissions are the hardest to control because they come from sources outside the company’s direct operations.
According to the VCMI, the global Scope 3 emissions gap—the difference between actual emissions and what they should be to stay on track with climate targets—is already about 1.4 billion tons of carbon dioxide equivalent.
- That is roughly equal to the combined 2023 emissions of Germany, the United Kingdom, and Italy. This gap could grow 5x by 2030.
What the VCMI’s Scope 3 Code Proposes
The VCMI’s new Scope 3 code sets clear rules for how companies can use carbon credits to address this emissions gap. Like other frameworks, such as the Science Based Targets initiative (SBTi), the VCMI insists companies must first set science-based targets and prioritize cutting their own emissions. But VCMI goes further by allowing companies to use carbon credits sooner and in larger amounts than SBTi currently allows.

Under the code, companies must:
- Disclose their Scope 3 emissions gap and the steps they are taking to close it.
- Explain the barriers they face in reducing Scope 3 emissions, describe their strategies to overcome them, and set a clear timeline to close the gap by no later than 2040.
- Retire (cancel) high-quality carbon credits in an amount equal to their entire emissions gap.
- Limit their use of credits to no more than 25% of their total Scope 3 emissions in any given year.
The credits used must come from high-quality projects, such as select reforestation initiatives that meet strict standards. The following figure shows the steps companies must follow to comply with the new code.

Why Some Support the Code
Groups like the Environmental Defense Fund, the We Mean Business Coalition, and the U.K. government have backed the VCMI’s approach. They argue that Scope 3 emissions are so hard to reduce that companies need more flexible tools to stay on track with climate goals.
For many businesses, making deep cuts in Scope 3 emissions requires cooperation across global supply chains, which can take time. Supporters say using carbon credits can help companies show progress while they continue working on direct reductions.
In March 2025, even the Science Based Targets initiative suggested it might recognize the use of carbon credits to address ongoing emissions—although it has not finalized this proposal yet. The VCMI code could give companies clarity and a consistent framework to follow.
Why Others Are Worried
Not everyone is convinced. Many environmental groups and experts warn that allowing carbon credits to cover Scope 3 gaps could weaken corporate climate ambition and slow real emissions cuts.
Lindsay Otis Nilles, a global carbon markets expert at Carbon Market Watch, says:
“VCMI risks undermining its own credibility by allowing companies to present themselves as climate leaders while, in reality, falling behind on their commitments.”
Critics argue that allowing companies to rely on credits until 2040—a date without a clear scientific basis—could disadvantage firms that are already making tough changes to lower their emissions. If both leaders and laggards can make similar claims, it becomes harder for investors, consumers, and regulators to tell which companies are truly reducing emissions.
Thomas Day from the NewClimate Institute agrees:
“The Scope 3 Claim could mislead investors and regulators, allowing companies with ambitious-sounding targets to continue increasing their emissions in the short term.”
Others point out that carbon credits do not remove the need for direct cuts. According to Thea Lyngseth from the Environmental Coalition on Standards (ECOS),
“Investing in carbon credits for Scope 3 instead of reducing emissions at their source only delays real climate action.”
Balancing Flexibility and Integrity
The VCMI says its goal is not to undermine existing standards but to offer a practical tool that reflects real-world challenges. In response to concerns, the initiative stated:
“The intention is not to create divergence, but to offer a pragmatic, high-integrity solution to the difficulty many companies face in reducing Scope 3 emissions at the required pace.”
The VCMI also recommends that target-setting groups like the SBTi adopt a similar approach. However, with no unified global standard yet, companies could face confusion about which rules to follow.
What Comes Next?
The debate over VCMI’s Scope 3 code highlights a bigger question in corporate climate action: How can companies balance the need for fast, deep emissions cuts with the challenges of managing complex global value chains?
For now, companies interested in using the VCMI framework will need to:
- Carefully document their Scope 3 emissions and reduction plans.
- Make sure any credits used meet the highest quality standards.
- Be transparent about how credits are used and how they plan to phase them out over time.
The VCMI’s new Scope 3 guidance adds an important option for companies grappling with indirect emissions. Whether it speeds up or slows down real climate action will depend on how it is used—and how closely its users are held accountable.
The post VCMI’s New Scope 3 Code: Flexibility or Risk in Carbon Credit Use? appeared first on Carbon Credits.
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Most businesses that decide to act on their net-zero targets reach the same point of friction. Buying carbon credits has meant tracking down brokers, sitting through sales calls, and requesting a quote just to learn a price, sometimes with limited proof of what you are buying.
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Carbon Footprint
Climate-Linked Supply Chain Risk Is Already in Your P&L
The earnings calls that quietly reframed climate from sustainability question to operating risk.
Three earnings calls in the last 18 months tell the story without any help from a press release.
Hershey, May 2024: cocoa price exposure compresses margin, and the company attributes part of the cost shock to West African weather. Olam, July 2024: coffee climate exposure quantified in the annual report. JBS, January 2025: supply chain climate disclosures expanded materially in response to investor pressure and regulatory expectation. None of these companies issued the announcement as climate news. They issued it as financial news. The climate-linked supply chain risk did not arrive with a sustainability framing; it arrived as a P&L line.
You are probably reading this article because you suspect the same thing is happening to your business. This piece walks through what is showing up on which earnings calls, how procurement and finance leaders are quantifying the exposure, and what serious corporates are doing about it before the regulator asks.
Where climate risk has already appeared in earnings
The pattern is consistent across resource-intensive sectors. A weather event compresses supply, the price spikes, the cost flows through the income statement, and the analyst on the call asks whether the event is anomalous or structural. Increasingly, the honest answer is the second one.
Cocoa is the cleanest example. The 2023 to 2024 West African harvest fell sharply on the back of erratic rainfall and disease. Cocoa futures more than tripled. Companies with concentrated West African sourcing absorbed the cost; companies with diversified sourcing absorbed less. The exposure was not climate as ESG topic. It was climate as cost of goods.
Coffee follows the same pattern. Brazilian and Vietnamese harvests have moved on weather more sharply across the last several seasons. Roasters with long-tenor supplier relationships and origin diversification have managed the volatility; roasters with spot-market exposure have not. Wheat, sugar, palm oil, beef: the same dynamic in different commodities, a pattern the IPCC AR6 Working Group II report projects will intensify across agricultural systems through mid-century.
What this means: climate risk is no longer a footnote in the 10-K. It is a line item the CFO has to explain on the call.
The three commodity exposures that hit margin first
For most companies with material Scope 3 exposure, three exposures dominate the near-term P&L risk.
- Concentrated single-origin sourcing in a climate-vulnerable region. If your tier-one supply for any material commodity sits in one geography, you have a concentration risk that climate amplifies. Diversification across origins is the obvious hedge, but it takes years to build and requires relationships you cannot acquire by tender.
- Supplier financial fragility under climate stress. Smallholder farmers, who supply a large share of the global cocoa, coffee, and palm oil market, do not carry the balance sheets to absorb yield shocks. When yields collapse, they exit. When they exit, your supply base shrinks, and the surviving suppliers raise prices. The risk is structural, not cyclical.
- Logistics and storage exposure to extreme weather. Hurricane disruptions to Gulf shipping, drought-driven Panama Canal restrictions, flooding in European inland waterways: each of these has moved input costs in the last three years, a pattern documented in Munich Re’s natural catastrophe data. The exposure shows up as a one-quarter event in the financial press but accumulates over time on the cost line.
TCFD and ISSB disclosure changes
The disclosure architecture has now caught up with the risk. The Task Force on Climate-related Financial Disclosures, whose recommendations are now embedded in the ISSB’s IFRS S2 climate standard, requires companies to disclose climate-related risks across physical and transition categories, with quantification where possible.
For physical risk specifically (the climate-linked supply chain risk you are reading about), the disclosure must address both acute exposures (extreme weather events) and chronic exposures (gradual changes in temperature, precipitation, and growing seasons). The disclosure must address the time horizon over which the risk is material, the parts of the value chain exposed, and the financial impact under different scenarios.
The CSRD imposes similar requirements under European law, with double materiality (both financial and impact materiality) embedded in the assessment. The practical effect: your auditors and your investor relations team now need a defensible answer to the climate-linked supply chain risk question, and the answer needs to be quantified.
What procurement and finance can do now
Three actions matter near-term.
Map your exposure. Most companies do not have a clear view of which tier-one and tier-two suppliers sit in which climate-vulnerable geographies. Without the map, you cannot quantify the risk, and without the quantification, you cannot disclose it credibly. The map is the foundation, and World Resources Institute climate risk research provides useful public tooling to start.
Diversify and deepen, in that order. Diversification across origins reduces concentration risk, but the deeper move is to invest in the resilience of the suppliers you already have. Regenerative practices, agroforestry, soil health interventions: these reduce yield volatility under climate stress and protect your input cost trajectory.
Embed the climate spend inside procurement, not outside it. Treating climate risk as a sustainability cost line subordinates it to the ESG budget. Treating it as a procurement and resilience investment puts it in the budget that matters, which is the cost-of-goods budget that the CFO defends quarterly.
Nature-based supply chain investments are the asset class designed for exactly this purpose. They sit inside the value chain, they reduce climate-linked supply risk, they generate verifiable Scope 3 reductions, and they produce the documentation an auditor and a regulator can both test.
If you are quantifying climate-linked supply chain risk in advance of the next earnings cycle or the next disclosure period, the carbon and sustainability experts at Carbon Credit Capital can help you map your exposure and structure a Dual-Value Model response that addresses reduction, resilience, and disclosure-readiness in a single program. Schedule a consultation.
Carbon Footprint
Where should an SME start with a carbon action plan?
More and more small and medium-sized businesses are hearing the same question from their larger customers: What is your carbon footprint? That question now travels down entire supply chains, and it arrives next to tender requirements, certification criteria, and rising customer expectations.
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