In short
- Process emissions make scope 1 the difficult part, which is unusual. Most sectors get to treat scope 1 as the easy line.
- CBAM has a 50 tonne de minimis that exempts roughly 90 percent of importers. Weigh your tonnage before you chase a single supplier.
- Your data lives in process historians and energy meters, not in a purchase ledger, and that changes what you should test in a tool.
Chemicals is one of the few sectors where scope 1 is the hard part: process emissions and energy sit inside your own fence line, not in your purchase ledger. Two rules are usually named as the drivers, and both reach fewer companies than the coverage suggests: CBAM's definitive regime began on 1 January 2026 but exempts importers under 50 tonnes a year, and CSRD now requires both EUR 450 million of net turnover and 1,000 employees. Check whether either actually catches you before you buy anything. What survives either answer is the customer questionnaire, and for that the software has to produce an auditable organisational inventory that separates process emissions from combustion, holds a stable method year on year, and exports to whatever template a customer or an auditor asks for.
Which rules apply to a chemicals company, and when?
Two, and they ask for different things from different parts of your business.
CBAM, and only if you import enough. The definitive regime began on 1 January 2026, covering six sectors: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. But there is a de minimis threshold most coverage leaves out, and it decides the answer for most companies. If your cumulative net mass of imported iron and steel, aluminium, fertilisers or cement does not exceed 50 tonnes in a calendar year, you have no obligation. The Commission's own stated effect is that this exempts roughly 90 percent of importers while keeping roughly 99 percent of embedded emissions in scope. There is no threshold for electricity or hydrogen. So the first thing to do is weigh your annual tonnage, not chase your suppliers. Above the threshold it becomes a product-level question about embedded emissions per tonne, answered largely by your suppliers rather than by your own inventory, and no carbon accounting tool produces that figure: it is a product number from an installation, or a Commission default value. We cover the mechanism in what you need to know about CBAM.
CSRD, if your company exceeds both a net turnover of EUR 450 million and an average of 1,000 employees, measured on a consolidated basis if you are a parent. Both tests, not either, and the first financial years on that basis begin on or after 1 January 2027. A large chemicals group will usually clear both; a mid-sized formulator usually will not, and the revised thresholds took a great many companies out that were preparing under the old ones. This one is a company-level question, and for those still caught it asks for a full inventory with a method you can defend to an assurance provider.
Then there is the request that is not a rule at all and still arrives every quarter: your downstream customers, many of whom are in CSRD scope, asking for your figures so they can complete their own value chain reporting. Where those customers are smaller and want a standard format to point at, the VSME standard is increasingly what gets used.
Why is scope 1 the hard part here?
Because in chemicals, scope 1 is not just combustion. It is process emissions, and process emissions do not fall out of a fuel bill.
In most sectors, scope 1 is the easy line. You burn gas, you run vans, the meters and the fuel cards tell you how much. Scope 3 is where the estimation lives and where the argument happens.
Chemicals inverts that. A reaction that releases CO2 as a stoichiometric consequence of what you are making is a scope 1 emission with no fuel behind it. Getting it right means going to mass balances, feedstock composition and production volumes, and it means someone in process engineering has to be involved rather than someone in finance.
Three practical consequences follow.
Your emission factor library will not cover it. Generic factors are built for common activities. Site-specific process chemistry is not a common activity, which is why the ability to load your own factors matters more here than almost anywhere else.
Your figure is defensible or it is not, with little middle ground. A spend-based proxy for purchased goods can be improved later. A wrong process emission number is simply wrong, and it moves your total materially.
Energy allocation gets contested. Steam, heat and on-site generation shared across product lines have to be split somehow, and whichever rule you pick has to survive being applied again next year.
Where does the data actually come from?
Three sources, and only one of them is a finance system.
| Source | What it gives you | Who owns it |
|---|---|---|
| Process data and mass balances | Process emissions by reaction and line | Process engineering |
| Energy meters and on-site generation | Combustion scope 1 and purchased scope 2 | Site or utilities management |
| Feedstock purchase records | Scope 3 purchased goods, and inputs to mass balance | Procurement and finance |
The organisational structure is the reason this gets slow. A footprint owned by an HSE or sustainability manager needs data from three departments who do not report to them and who each have a busier day job. That is a scheduling problem before it is a software problem, and the tools that help are the ones that let those three people enter their own data with their own logins rather than emailing spreadsheets to one coordinator.
What does the software have to produce?
Five things worth testing with your own data before you commit.
A split between process and combustion emissions. If the tool only understands fuel, it cannot represent your site. Ask to see how a process emission is entered.
Your own factors, held permanently. Site-specific and supplier-specific values need to live in the system as first class entries, not as manual overrides that someone has to remember next year.
Multi-site, multi-entity roll-up. Chemicals groups run several sites and often several legal entities. You want per-site figures that consolidate without double counting shared utilities.
A traceable audit route. Assurance providers ask how a number was produced. Every entry should lead back to a source record and a factor version.
An export into somebody else's template. Customer questionnaires arrive in their format, not yours. Test this with a real one you have received.
What does Hedgehog do for chemicals companies?
The platform guides you through GHG Protocol setup, identifying your data sources, data owners and documents, and inventory building, with an AI guide and human GHG experts reachable in-app. It holds over 20,000 spend-based and activity-based factors and lets you add your own organisation-specific or supplier-specific CO2 data, which is the mechanism for site-specific process values. Entity management covers locations and sites, with roles for data owners, auditors and managers, so process engineering and utilities can own their own inputs. Named legislation support includes CSRD, SECR and SB253.
Free account with no sales call. Pro from EUR 1,200 per year.
Three limits, stated plainly.
Getting the data in is the slow part. A Small-Business reviewer said on G2 in August 2026, rating us 5 out of 5, that it takes a lot of manual labour to load data, and that once the data is there it works perfectly. In chemicals, where the first step is often getting process engineering to produce a mass balance in a usable form, that is the honest shape of a first year.
We are an emissions platform, not a full ESG suite. A Mid-Market reviewer rated us 3.5 out of 5 on G2 in June 2026 and said that for a broader ESG and CSRD reporting platform this one is less complete, with no data source management feature and no decarbonisation target monitoring. If CSRD in the round is your requirement, buy accordingly and read ESG reporting software versus carbon accounting first.
Product footprints are a service, not a feature. An LCA, an EPD, an ECI (MKI in Dutch) or a product carbon footprint is delivered by our people, not by a subscription. The platform does organisational footprints. Where customers are asking you for a per-product number, that is carbon footprint consulting work.
What should you do first?
Weigh your annual imports against the 50 tonne CBAM threshold. That is a customs records question, it takes an afternoon, and for most companies the answer is that CBAM is not their problem at all, which changes the priorities completely.
Then get one site's scope 1 done properly, process emissions included, before you scale to the group. A method proven on your most complex site travels well. A method proven on your simplest one does not.
You can start a free account and build a first site inventory without talking to anyone, which is also the cheapest way to find out how long the process data will take to assemble.
Sources: Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083 for the CBAM sectors, the 1 January 2026 definitive regime and the 50 tonne de minimis in Article 2a; Directive 2013/34/EU as amended by Directive (EU) 2026/470 for the CSRD thresholds; the GHG Protocol Corporate Accounting and Reporting Standard for the scope definitions. Hedgehog platform and Hedgehog on G2, both read on 27 August 2026. Page verified 17 September 2026.
Facts on this page were last verified on 2026-09-17.
