BEGES-R fact sheet
Regulatory method for carrying out greenhouse gas emission assessments
Type: National regulatory standard
Date: Latest version in July 2022
Author: Ministry of Ecological Transition Target: Organisations
With the Grenelle 2 Act of 12 July 2010 and the creation of Article L229-25 of the Environmental Code, the French government generalised the obligation to carry out a greenhouse gas emission assessment (BEGES-R). Article R.229-48 of the Environmental Code provides that the Ministry responsible for the environment organises the publication of the methodological information necessary for compliance with the law. A general method is thus available on the website of the Ministry of Ecological Transition and ADEME.
The regulatory method was developed within the framework of the work of the national coordination body on greenhouse gas emission assessments, created by Article R. 229-49 of the Environmental Code. The BEGES-R method is strongly inspired by existing reference frameworks, in particular those defined at the international level such as ISO 14064-1, and its latest iteration was published in July 2022.
What are the objectives of the approach?
The BEGES-R method aims to enable French organisations, public or private, to quantify their GHG emissions in order to identify and mobilise levers for action to reduce their impact on the climate. By requiring the publication of these assessments on the ADEME Bilan GES website, the French regulation encourages transparency and pooling.
The latest version of the BEGES-R methodology accompanies Decree No. 2022-982 of 1 July 2022, which accompanies an extension of the scope of BEGES-R for organisations subject to regulatory obligations to include significant indirect emissions to promote more global and relevant action.
The BEGES-R methodology frames the following steps for organisations:
Scoping: definition of the organisation's organisational boundary
Identification of sources and emissions: definition of the operational boundary and the declaration boundary
Data collection: general principles for assessing GHG emissions
Assessment calculation and analysis: Detailed presentation of emission categories
Transition plan: definition of a pathway, formalisation of the transition plan and monitoring of past actions
Publication of results: definition of the reporting format
What is (are) the target(s) of the approach?
The BEGES-R methodology was developed to support all organisations concerned by French regulation in measuring and reducing their GHG emissions. While any type of organisation can use this method to launch a carbon accounting approach, the French organisations concerned, according to Decree No. 2022-982 of 1 July 2022, are as follows:
Legal entities employing more than 500 employees in an accounting period
For legal entities in overseas regions and departments, the regulatory obligation threshold is 250 employees
-> Obligation to publish a BEGES-R every 4 years minimum
Public bodies with more than 250 employees
-> Obligation to publish a BEGES-R every 3 years minimum
All State Services are concerned
-> Obligation to publish a BEGES-R every 3 years minimum
Regions, departments, urban communities, agglomeration communities, municipalities and communities of municipalities with more than 50,000 inhabitants
-> Obligation to publish a BEGES-R every 3 years minimum
Private legal entities and the obligation to report significant indirect emissions
Private legal entities not subject to the NFRD (Non-Financial Reporting Directive) are not required to report significant indirect emissions from their activities.
Thus, the organisations concerned by the inclusion of significant indirect emissions are as follows:
For listed companies: at least €20M in total balance sheet or €40M in turnover and 500 employees on average during the financial year
For unlisted companies: at least €100M in total balance sheet or €100M in turnover and 500 employees on average during the financial year.
According to Article L.225-102-1 of the Commercial Code, for any company preparing consolidated accounts in accordance with Article L. 233-16 of the Commercial Code, these thresholds are assessed across all companies within the consolidation boundary, i.e. at group level and not at the level of the legal entities that compose it.
Does the approach draw on a shared scientific basis?
The Ministry in charge of ecology in France has determined that the seven types of GHGs covered by the Kyoto Protocol are to be taken into account for the preparation of a BEGES-R: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFC), perfluorocarbons (PFC), sulphur hexafluoride (SF6) and nitrogen trifluoride (NF3).
Does the approach draw on a specific methodology?
The BEGES-R method was developed with the objective of supporting the preparation of BEGES-R assessments and harmonising practices. In this perspective, the method built and updated by the Ministry draws on the technical report ISO/TR 14069, and therefore on ISO 14064-1, with which it seeks coherence.
The detailed steps of the BEGES-R methodology
Scoping: Definition of the legal entity's organisational boundary
Identification of sources and emissions
Definition of the operational boundary
Declaration boundary
Data collection
Identification of data to collect for the calculation of induced emissions
Choice of criteria to determine significant emissions among indirect non-energy-related emissions
Assessment and identification of significant indirect emissions
Collection of data necessary for calculating induced emissions
Valorisation of avoided emissions and consumption of certified renewable energy
Calculation and analysis of the Assessment
Calculation of induced emissions according to the regulatory methodology and emission categories
If necessary: Recalculation of GHG emissions for the reference year
Transition plan
If relevant: Analysis of results obtained over previous years
Definition of medium and long-term reduction objectives
Formalisation of a transition plan
Identification of means mobilised for implementing actions
Quantification of reduction potentials
Publication of the Assessment on the ADEME website
As the preparation of BEGES-R assessments is a regulatory obligation, the scope to be covered is also imposed. As mentioned above, the minimum declaration boundary differs for two types of organisations:
Obligation to declare direct emissions
Obligation to declare indirect emissions associated with energy
Obligation to declare direct emissions
Obligation to declare at least 80% of significant indirect emissions arising from the organisation's operations and activities, as well as, where applicable, from the use of the goods and services it produces
The notion of significant emission, derived from ISO 14064-1, only applies to indirect emissions and takes into account the emission categories meeting the criteria chosen by the organisation:
Mandatory criterion:
Magnitude criterion: indirect emission categories estimated to be substantial from a quantitative point of view are to be retained. Each organisation can set a minimum magnitude threshold to consider which, unless there is a particular reason, must not be less than 80%.
Optional
Level of influence and levers for action: the extent to which the organisation can monitor and reduce emissions in certain emission categories.
Strategic importance and vulnerability: according to a risk or opportunity approach, this criterion concerns indirect emissions that contribute to exposure to climate risks or related commercial opportunities
Sector-specific guidelines: emissions considered significant for the sector of activity concerned, particularly according to the guidelines defined in ADEME's sectoral guides
Subcontracting: indirect emissions resulting from outsourced activities
Employee engagement: indirect emissions likely to motivate employees to reduce their professional emissions or to mobilise team spirit around combating climate change
The magnitude or importance criterion according to ISO 14064-1, must always be applied when identifying the categories to consider. The optional criteria are present to allow the integration of emission categories that would not have been taken into account with the magnitude criterion.
To define which indirect emissions are significant, an organisation should only consider certain emission categories. Before the decree of 1 July 2022, the emission scopes of the BEGES-R method were Scopes 1, 2 and 3, namely direct emissions, indirect emissions linked to energy and other indirect emissions respectively. But since 2022, the regulatory methodology follows the emission categories of ISO 14064-1 with 6 emission categories:
Direct GHG emissions
Indirect emissions associated with energy
Indirect emissions associated with transport
Indirect emissions associated with purchased products
Indirect emissions associated with sold products
Other indirect emissions
The French regulatory method allows the exclusion of certain indirect emission categories, as long as the magnitude criterion remains respected. On the other hand, direct emission categories cannot be excluded from a declaration boundary.
It is possible to justify the exclusion of an emission category considered significant in the absence of a method for its calculation or the impossibility of accessing source data enabling an acceptable calculation.
It is then necessary to integrate into the transition plan an action to remedy this blockage and the emission category must be integrated at the organisation's next assessment
It is therefore only possible to exclude a significant emission category during the first BEGES-R
The BEGES-R method also gives recommendations on the quality of data used for the carbon accounting phase. Indeed, in addition to broadly recommending the use of EFs from ADEME's Base Empreinte, the BEGES-R method encourages careful selection of activity data types by prioritising primary data and secondary data.
Furthermore, the regulatory method encourages the presentation of elements for assessing uncertainty (on activity data and on emission factors) at minimum for the main emission categories, in a quantitative or qualitative manner.
Does the approach draw on tools?
No tool is proposed: the French regulatory method leaves the choice to the user.
However, several ADEME resources are highlighted as references to draw on when implementing a BEGES-R approach:
Guide for building, implementing and monitoring a transition plan
Project Footprint (formerly QuantiGES)
Sectoral guides for carrying out a GHG emission assessment
Can other low-carbon transition methods and tools be used to achieve the objectives of this approach?
The provisions of the BEGES-R have been established to be coherent with other recognised carbon accounting methods such as the Bilan Carbone®, GHG-P and ISO 14064-1.
-> It is possible to meet a regulatory obligation by using the previously mentioned methods instead of the BEGES-R method, as long as the deliverables remain the same.
Does it allow for third-party recognition? If so, in what way?
As the BEGES-R method aims to enable organisations to meet their regulatory obligation, a control system is ensured by the DREAL (Regional Directorates for Environment, Planning and Housing). Authorised agents carry out these controls drawing on the elements published by the obligee on the ADEME Bilan GES platform.
In the event of non-compliance with the deadline imposed for this regularisation, the prefect may order the payment of a fine of a maximum of €50,000 and a maximum of €100,000 in the event of a repeat offence.
To publish their regulatory assessment, obligees must therefore use the form accessible upon registration on the Bilan GES website and complete at minimum the required fields, indicated by an asterisk, including in particular the emissions in regulatory format, the transition plan with its identified objectives, actions and means and the possibility of valorising other efforts and benefits such as avoided emissions.
Can this approach be harmonised with other international reference frameworks?
In addition to being able to choose among the major carbon accounting standards, private legal entities subject to regulatory obligations and the NFRD are exempt from preparing a transition plan to be attached to the BEGES-R as soon as their non-financial performance declaration presents the medium and long-term objectives and actions envisaged for the reduction of their GHG emissions.
The sheets from the Overview of carbon accounting methods and tools are the result of a synthesis work by the ABC. We welcome your feedback or questions via this form.
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