BEGES-R fact sheet
Regulatory method for carrying out greenhouse gas emission assessments
Type : National regulatory standard
Date : Last version in July 2022
Author : Ministry of Ecological Transition Target : Organisations
With the Grenelle II law of 12 July 2010 and the creation of article L229-25 of the Environmental Code, the French government generalised the obligation to perform a bilan d’émissions de gaz à effet de serre (BEGES-r). Article R.229-48 of the Environmental Code provides that the ministry in charge of the environment organises the publication of the methodological information necessary to comply with the law. A general method is therefore available on the website of the Ministry of Ecological Transition and ADEME.
The regulatory method was developed within the work of the national coordination unit on greenhouse gas emissions assessments, created by article R. 229-49 of the Environmental Code. The BEGES-r method is strongly inspired by existing frameworks, in particular those defined at international level such as theISO 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 of action to reduce their impact on the climate. By requiring the publication of these assessments on the Bilan GES section of ADEME, the French regulation encourages transparency and pooling.
The latest version of the BEGES-r methodology accompanies Decree No. 2022-982 of 1 July 2022 and supports an extension of the BEGES-r scope for organisations subject to the regulation to include significant indirect emissions to promote a more comprehensive and relevant action.
The BEGES-r methodology frames the following steps for organisations:
Framework : definition of the organisation's organisational boundary
Identification of sources and emissions : definition of the operational boundary and the reporting boundary
Data collection : general principles for the assessment of GHG emissions
Calculation of the assessment and analyses : Detailed presentation of the emission categories
Transition Plan : definition of a trajectory, 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 subject to the French regulation in measuring and reducing their GHG emissions. While any type of organisation can use this method to embark on carbon accounting, the French organisations concerned, according to Decree No. 2022-982 of 1 July 2022, are as follows:
Legal entities employing more than 500 employees during an accounting period
For legal entities in overseas regions and departments, the regulatory obligation threshold is 250 employees
-> Obligation to publish a BEGES-r at least every 4 years
Public establishments of more than 250 employees
-> Obligation to publish a BEGES-r at least every 3 years
All State services are concerned
-> Obligation to publish a BEGES-r at least every 3 years
Regions, departments, urban communities, communities of agglomeration, municipalities and groups of municipalities of more than 50,000 inhabitants
-> Obligation to publish a BEGES-r at least every 3 years
Private law legal entities and obligation to report significant indirect emissions
The Private law legal entities not subject to the DPEF are not required to report significant indirect emissions from their activities.
Thus, the organisations concerned by the consideration of significant indirect emissions are as follows:
For listed companies : at least €20M of total balance sheet or €40M of turnover and 500 employees on average during the accounting period
For unlisted companies : at least €100M of total balance sheet or €100M of turnover and 500 employees on average during the accounting period.
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 over all the companies included in the consolidation perimeter, that is to say at the group level and not for the individual legal entities that compose it.
Does the approach rely on a shared scientific basis?
The ministry responsible for ecology in France has set that the seven types of GHG 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 (HFCs), perfluorocarbons (PFCs), sulphur hexafluoride (SF6) and nitrogen trifluoride (NF3).
Does the approach rely on a specific methodology?
The BEGES-r method was developed with the objective of supporting the preparation of BEGES-r and ofharmonising practices. In this perspective, the method developed and updated by the ministry is based on the technical report ISO/TR 14069, and therefore on the ISO 14064-1 standard with which it seeks coherence.
Detailed steps of the BEGES-r methodology
Scoping: Definition of the organisational boundary of the legal entity
Identification of sources and emissions
Definition of the operational boundary
Reporting boundary
Data collection
Identification of the data to be collected for the calculation of induced emissions
Selection of criteria to determine significant emissions among indirect emissions not related to energy
Evaluation and identification of significant indirect emissions
Collection of the data necessary for the calculation of induced emissions
Valuation of avoided emissions and of energy consumption guaranteed as of origin or renewable
Calculation and analysis of the Assessment
Calculation of induced emissions according to the methodology and the regulatory emission categories
If necessary: Recalculation of GHG emissions for the base year
Transition Plan
If relevant: Analysis of the results obtained over previous years
Definition of medium- and long-term reduction objectives
Formalisation of a transition plan
Identification of the means mobilised for the implementation of action
Quantification of reduction potentials
Publication of the Assessment on the ADEME
As the completion of BEGES-r is a regulatory obligation, the scope to be covered is also imposed. As mentioned above, the minimum reporting scope differs for two types of organisations:
Obligation to report direct emissions
Obligation to report indirect emissions associated with energy
Obligation to report direct emissions
Obligation to reportat least 80% significant indirect emissions resulting from the organisation's operations and activities, and, where applicable, from the use of the goods and services it produces
The notion of significant emission, drawn from ISO 14064-1, corresponds only to indirect emissions and takes into account the emission categories that meet the criteria chosen by the organisation:
Mandatory criterion :
Magnitude criterion : the indirect emission categories estimated to be substantial from a quantitative point of view are to be retained. Each organisation may set a minimum magnitude threshold to be considered which, except for particular reasons, shall not be less than 80%.
Optional
Level of influence and levers of action : measure to what extent the organisation can monitor and reduce emissions from 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 to related commercial opportunities
Sector-specific guidelines : emissions considered significant for the sector concerned, notably according to the guidelines defined in ADEME's sectoral guides
Outsourcing : indirect emissions resulting from outsourced activities
Staff engagement : indirect emissions likely to motivate employees to reduce their professional emissions or to mobilise team spirit around the fight against climate change
The magnitude criterion, or importance according to ISO 14064-1, must always be applied when identifying the categories to be considered. The optional criteria are present to allow the inclusion of emission categories that would not have been taken into account with the magnitude criterion.
To define which indirect emissions are significant, an organisation shall consider only 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 related to energy and other indirect emissions respectively. But since 2022, the regulatory methodology follows the categories and 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. However, direct emission categories cannot be excluded from a reporting 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 include in the transition plan an action to remedy this blockage and the emission category must be included in the organisation's next assessment
Therefore it is only possible to exclude a significant emission category during the first BEGES-r
The BEGES-r method also gives recommendations on the quality of the 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 the types of activity data, prioritising primary data and secondary data.
Moreover, the regulatory method encourages the presentation of elements of uncertainty assessment (on the activity data and on emission factors) at least for the main emission categories, in a quantitative or qualitative manner.
Does the approach rely on tools?
No tool is proposed: the French regulatory method leaves the choice to the user.
Nevertheless, several ADEME resources are highlighted as references to rely on when implementing a BEGES-r approach:
Guide for the construction, implementation and monitoring of a transition plan
Project footprint (former QuantiGES)
Sector guides for the preparation of a greenhouse gas emissions assessment
Can other low-carbon transition methods and tools be used to achieve the objectives of this approach?
The BEGES-r provisions have been established to be coherent with other recognised carbon accounting methods such as Bilan Carbone®, the GHG Protocol and ISO 14064-1.
-> It is possible to fulfil a regulatory obligation by using the methods cited above instead of the BEGES-r method, provided that the deliverables remain the same.
Does it allow third-party recognition? If so, in what manner?
As the BEGES-r method aims to enable organisations to meet their regulatory obligation, a control system is ensured by the DREAL. The authorised officers carry out these controls based on the elements published by the obliged party on the Bilan GES ADEME platform.
In case of failure to comply within the allotted time for this regularisation, the prefect may order the payment of a fine of up to €50,000 and up to €100,000 in case of repeat offence.
To publish their regulatory assessment, the obliged parties must therefore use the form accessible upon registration on the Bilan GES website and complete at least the required fields, indicated by an asterisk, including notably the emissions in the regulatory format, the transition plan with its objectives, actions and identified means and the possibility to highlight other efforts and benefits such as avoided emissions.
Can this approach be harmonised with other international frameworks?
In addition to being able to choose among major carbon accounting standards, private law legal entities subject to the regulation and to the DPEF are exempted from preparing a transition plan to attach to the BEGES-r provided that their non-financial performance declaration presents the medium-term objectives and actions envisaged for the reduction of their GHG emissions.
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