Twenty-two percent of global greenhouse gas emissions stem from Forestry, Land and Agricultural (FLAG) activities. It should come as no surprise that the apparel and textile industries play a big role in that figure as raw materials are frequently derived from natural, land-based sources.
FYI: Throughout this article, you’ll see us reference both the Greenhouse Gas Protocol (GHG Protocol) and the SBTi. These two bodies work closely together to ensure alignment in the accounting and target-setting for FLAG emissions. FLAG emissions, as defined by the SBTi, represent a subset of GHG Scope 3 emissions, focusing specifically on land-based emissions sources. For more on the GHG Protocol, read our Carbon Accounting for Fashion Guide.
FLAG emissions in a fashion and apparel company's Scope 3 category, specifically from Purchased Goods & Services, largely originate from the production of natural fibers like cotton, leather, and wool. In fact, for some apparel brands, wool alone can account for up to 50% of their total carbon emissions. That’s why accurately measuring and setting reduction targets from land-based CO2 emissions is essential for fashion brands to lower their climate impact.
The Science Based Targets initiative's (SBTi) FLAG guidance is a new framework that requires companies to measure and set precise reduction targets for their FLAG-related emissions in addition to their energy/industry SBT. For apparel and footwear brands, following this guidance can provide greater visibility into your emissions down to the farm level. In addition to reducing land-based emissions, following the SBTi FLAG guidance enables companies to identify opportunities to restore important carbon sinks such as forests, oceans, and peatlands.
The GHG Protocol provides the foundational guidelines and tools for companies to accurately measure and report their greenhouse gas emissions. In 2023, the organization released a draft Land Sector & Removals (LSR) guidance. SBTi has since mandated that companies use the GHG guidance to set targets.
SBTi is a corporate climate action organization that helps companies set emissions-reduction targets grounded in climate science, driving climate action towards the goals of the Paris Agreement. The organization has developed a series of standards, tools, and guidance mechanisms, but until recently, their work only covered energy and industry-related GHG emissions. Enter FLAG, expanding the scope from energy-and-industry only.
There are five key requirements of the SBTi FLAG Guidance:
The new FLAG guidance enlarges the scope of their work, enabling fashion and textile brands to include FLAG emissions. As you’ll soon see it’s extremely comprehensive, and at times complex. It demands a lot of data — especially from suppliers — but we’ll take it piece by piece and delve into how your brand can utilize this guidance.
There are three critical emissions-related categories covered under the FLAG guidance that will define how data is collected and later reported upon.
These include:
This category highlights the environmental impact of transforming natural ecosystems — whether that’s deforestation, forest degradation, or wetland conversion — into agricultural land. The amount of time that has passed since the land was transformed for agricultural purposes will impact the emissions count, which will be discounted linearly over 20 years.
Tip: fossil-based emissions from machinery (e.g., tractors) and energy emissions embedded in fertilizer are not technically "land-based emissions." However, you can choose to include them in your FLAG emissions accounting. Alternatively, they may be included in an energy/industry target, but pay attention not to double-count them across FLAG and energy/industry targets.
SBTi reporting is not currently mandatory from a regulatory standpoint. However, it does serve as a strong framework for reducing carbon emissions in line with reporting requirements such as the CSRD. Companies submitting new SBTi targets or doing their rebaselining must already submit FLAG SBTs today, using the GHG Protocol FLAG draft guidelines.
If your business has already set SBTs, then you will be required to set a FLAG SBT if 20% or more of your Scope 1, 2, and 3 emissions are derived from FLAG sources. In other words, a large percentage of apparel and footwear brands.
The SBTi recommends that companies with FLAG-related emissions that fall below the 20% threshold nonetheless set a FLAG target. If a company chooses not to set a FLAG target, FLAG-related emissions still must be included in the overall energy/industry (non-FLAG) target boundary.
Small and medium enterprises (SMEs) are exempt if they meet two or more of the following criteria:
Many apparel and footwear brands will find that 20% of their emissions are derived from land-based uses. If you use naturally sourced materials such as wool, viscose, rayon, cotton, or leather, there’s a good chance your company falls in this category.
Below are some anonymous examples from our customers using wool:
In order to assess your own percentage, you’ll first need detailed insights into your value chain. If you’re already measuring your environmental impact for legislation such as the Corporate Sustainability Reporting Directive, you will already be collecting much of this data. If not, utilizing a sustainability platform to measure product emissions – such as Carbonfact – will provide deep insights into your textile supply chain.
Without the use of Carbonfact, your approach would likely be:
The timeline for implementation is in flux, depending on when the final FLAG Guidance by the Greenhouse Gas Protocol is released (you can access the draft here). For now, companies should expect the following:
Example of a FLAG target:
For fashion brands setting FLAG targets, it’s important to adhere to the data-quality guidelines from the GHG Protocol's Land Sector and Removals Guidance.
To calculate land use change (LUC) emissions, textile companies should use the most accurate and representative data available – whether from their own operations, suppliers or established emission factors. For FLAG scope 3 emissions, companies should collect high-quality data from suppliers and value chain partners. If emission factors are used, they should be representative of the commodity and region, and any uncertainty associated with default data should be disclosed.
Companies should use granular, representative data for FLAG-related emissions, disaggregating emissions by commodity and region, and separating land use change emissions from land management emissions. CO2 and non-CO2 emissions from land management should also be reported separately.
Land removals should rely on primary data to be included in a FLAG target.
Carbonfact is designed to collect and make sense of large datasets, providing your company with comprehensive climate reporting tools. As you’ve probably gathered by now, FLAG guidance is data intensive. Here’s how Carbonfact can help:
Calculating your FLAG inventory requires a lot of data. For deforestation alone, we will look at inputs such as location of the project, duration, the vegetation type that will be deforested, and final land use after deforestation. This will translate into a metric identifying the CO2 emitted during the entire phase of the project due to land use change. As you can see, that’s already a lot of information for just one reporting category within the LUC related emissions.
Besides sourcing data, the calculation of FLAG emissions relies highly on performing Life Cycle Assessment (LCA) for all of your products. For example, for a sweater made from wool, you need to extract from the full LCA the emissions linked to the agricultural production (e.g., fertilizer input) and upstream emissions (e.g., production of fertilizers).
This is a time-and-resource intensive project that quickly overwhelms.
While our platform does the heavy lifting, we have a whole team of data and climate experts by your side supporting you in building plans and making decisions.
- SBTi FLAG Guidance https://sciencebasedtargets.org/resources/files/SBTiFLAGGuidance.pdf
- GHG Protocol FLAG guidance draft https://ghgprotocol.org/land-sector-and-removals-guidance