"Four Statements" Transform Emissions Calculation and Disclosure – GHG Protocol "Action and Market Instruments" (AMI) White Paper
(Comments will be accepted until June 15th)

Member of the GHG Protocol Expert Working Group (TWG), Vice Chair of the Global Sustainability Standards Board (GSSB)
Tomoo Machiba, Director of Zeroboard Research Institute

Companies worldwide have historically calculated and reported their greenhouse gas (GHG) emission amount in accordance with the organizational inventory (Scope 1-3) defined by the "GHG Protocol" (reporting systems vary slightly by country and region). While the "market standard" for Scope 2 (indirect emissions from the use of electricity, heat, steam, and cooling supplied by others) allows for emission amount to be considered zero through Energy attribute certificates (EACs), such as so-called non-fossil and renewable energy certificates, companies' decarbonization efforts are becoming increasingly diverse year by year. Concerns have been raised that the limited means of publicly reflecting the reduction effects (so-called reduction contributions) and carbon credits from the use of low-carbon materials and fuels such as green steel and aluminum, sustainable aviation fuel (SAF), and bio- and synthetic fuels, as well as low-carbon products, could lead to dissatisfaction among companies and hinder their efforts.

In March 2026, a "white paper" *1) summarizing the results of the first phase (Phase 1) discussions of the Expert Working Group (TWG) on "Actions and Market Instruments" ( AMI ), part of the revision of the GHG Protocol, was published, and a Request for Comment (RFI) is being held until June 15, 2026 (extended from the original end of May). This article is a transcript of our webinar held on May 14, featuring Mr. Hiromi Kawamata (AMI TWG), Group Leader of the Global Environment Group, Technology and Environment Department, Iron and Steel Federation of Japan, and Ms. Kae Takase (Scope 2 TWG), Senior Manager, Renewable Energy Foundation, who are participating in the TWG from May along with the Contents, as guests, and summarizes the key points of the white paper for practitioners.

Background and process of GHG protocol revision

A considerable amount of Year / month has passed since the issuance of the GHG Protocol's corporate standards (2004) *2) , value chain (Scope 3) standards (2011) *3) , and Scope 2 guidance (2015) *4). The environment surrounding businesses has changed dramatically, with the international disclosure requirements (IFRS S/SSBJ, CSRD/ESRS), the Settings of net-zero targets (SBTi), the emergence of "market tools" like those mentioned above, the implementation of various decarbonization actions, and the evolution of Scope 3 understanding and widespread adoption of its calculation. Following a global stakeholder survey in 2022-2023, a major revision of the entire standard is underway *5)*6) .

The revision of the GHG Protocol involves three existing expert working groups (TWGs) for each of the current standards and guidance: Corporate Standards, which oversees the overall organizational calculation disclosure; Scope 2; and Scope 3 (emissions from others related to the activities of an activity). In addition, there is a New TWG on AMI, and each TWG is further divided into subgroups that discuss specific Issue(the author is a member of Subgroup 3 of the Corporate Standards TWG, which discusses data reliability, etc.) (Table 1).

Table 1: Discussion topics of each TWG for the revision of the GHG protocol.

Note: This indicates the scope of discussion based on the initial plan, and may be revised as discussions progress.
Zeroboard Create based on the GHG protocol standard development plan *7)

In September 2025, a strategic partnership between ISO and the GHG Protocol was announced, aiming to integrate with the ISO 1406X series of standards related to GHG calculation and create a jointly branded international standard *8) . For this reason, representatives from ISO/TC 207/SC 7, which deliberates on climate change-related standards, are participating in each TWG, and from Japan, Atsushi Inaba, Chairman of the Japan LCA Promotion Organization, has joined the Scope 3 TWG. Discussions in each TWG began in 2025, and public consultations and RFIs are currently underway in areas where Phase 1 has been completed (Scope 2, AMI). The revised standards for Scope 1-3 are expected to be completed around the end of 2027, the AMI standards around the end of 2028, and full practical implementation around 2030 *9) .

This AMI white paper is not yet a draft standard that includes requirements, and therefore it is not a formal public consultation but rather a special comment period set aside for an interim result before the standard is drafted *10) . For this reason, it is important to note that the published Contents will not immediately become the standard, and it is important to comment at this stage, before the general outline is finalized, so that the Contents can be adapted to the realities of Japanese companies and stakeholders.

Background of the AMI Discussion

The starting point of the AMI work is to update the GHG protocol to match business and social realities *11) . The current standards have always centered on a "physical inventory" (attributable calculation) that collects the amount of GHG emissions and absorption directly and indirectly produced by the activity of the business itself. On the other hand, while the Scope 2 market standard has allowed claims of zero emission amount for purchased Energy through market instruments (certificates), there was no similar framework for Scope 1 and 3.

In recent years, various industries have proposed approaches to advocate for low-carbon materials and fuels using "chain of custody" (CoC) methods such as mass balance and book and claim, including biomethane, e-methane, SAF, and green steel and aluminum *12) . In addition to the demand for offsetting their own Scope 1 and 3 emission amount through such market means, there are also movements to demonstrate reductions downstream of products and across society as a whole through the widespread adoption of high-performance products and Service, such as the WBCSD reduction contribution guidance *13) and IEC 63372 (reduction contribution in electrical and electronic products) *14) .

A framework is needed to report this "information that is outside the current physical inventory but is important for investment decisions and stakeholder evaluation" without compromising transparency and consistency, and the AMI TWG has put forward a "multi-statement" type reporting structure as an interim proposal *1) . Kawamata, who is a participant in the TWG, says that it is not that the core of the current standards will be replaced, but rather "it is appropriate to understand that a complementary information layer will be added while the physical inventory remains the basis." In contrast to attributive calculations (inventory) that look at the year-on-year changes in a company's emission amount, "outcome calculations," which are project-based and measure the reduction (or increase) effect that a specific action (intervention) brings to a set current scenario, must be clearly considered separately (Figure 1) *15) .

Figure 1: Difference between inventory (consequential) calculation and result calculation
Zeroboard Create based on GHG Protocol Land Sector and Removal Standard (p.91, Figure 16.1) *16)

White Paper overview: Four Statements

The AMI white paper proposes a multi-statement structure to complement the physical inventory. The four statements under consideration are as follows (Figure 2) *1) .

Figure 2: Four proposed GHG statements
Zeroboard Create based on AMI white paper *1)

The first statement (physical GHG inventory) refers to emission amount (including removals) in the value chain resulting from the organization and its activity , under the traditional Scope 1-3 framework, and continues to be the basis for calculation and disclosure under the GHG Protocol. In Scope 2, the "location basis" is applied, reflecting emission amount on a physical location basis. Only if low-carbon materials and products can be physically secured without emission amount allocation can those emission intensity be allocated to Scope 3.

The second statement (market-based GHG inventory) extends the Scope 2 market-based methodology to Scope 1 and 3, providing a framework to visualize differences in emission amount due to procurement choices. This is expected to include certificates and contracts for low-carbon fuels and materials based on CoC models, etc. (such as GX steel *17) , green gas certificates *18) , and SAF certificates *19) , if approved in future discussions. Discussions on existing Scope 2 market standards are continuing separately in the Scope 2 TWG, and the AMI TWG will not change the Scope 2 reporting requirements themselves. Concerns may remain that the reporting sections for market standards will be consolidated into the second statement, separating them from the first physical inventory, which remains the primary evaluation axis.

The third statement (GHG Impact Statement) is a dedicated framework for result-based calculations, distinct from the inventory method (attribution-based calculation). It deals with the avoidance, reduction, and elimination of GHG emissions by projects, investments, products, etc., and categorizes them according to their scope of effect, such as within the organizational boundary, within the value chain, sector-related, global (outside sectors and value chains), and impact from the use of sold products (e.g., reduction effect when using products). The positioning of carbon credits is also expected to be clarified here.

The fourth statement (non-GHG indicator statement) is a disclosure framework for KPIs that cannot be shown by total GHG emissions but represent organizational efforts and investment activity that can serve as "leading indicators" for decarbonization. Possible indicators here include carbon intensity (GHG emission amount per unit), sales and percentage of low-carbon products, procurement amount and percentage of low-carbon raw materials and products, changes in land use area and percentage, and expenditures on various climate change mitigation projects. However, drawing the line between useful indicators and "noise" is a key agenda item in Phase 2.

What will change with AMI? — Practical Issues

In the second half of the webinar, the three of us discussed the significance of the four statements and their impact on the practical operations of Japanese companies, focusing on the following aspects.

① Towards a structure where low-carbon procurement is rewarded (Second Statement)

Kawamata emphasizes that the second statement is of great significance to the Manufacturing and materials Industry. "By including low-carbon materials like GX steel in the inventory, consumers will be able to confidently report their Scope 3 reduction effects on the GHG protocol, which will boost purchasing. As a result, a virtuous cycle is expected where the green premium added to low-carbon materials will be used for the next decarbonization investment."

On the practical side, however, the burden of data preparation may increase, such as understanding Emission factor by supplier and switching from average Intensity to Intensity appropriate for procured goods. Kawamata said, "If market-based methods are not used, the additional burden will be limited, but the way emission reductions are presented may create a difference compared to other companies. It is important to weigh the costs and benefits, but the value of preparing the data seems to be great."

② The distinction between physical and market-based approaches (Statements 1 and 2)

While the general framework of listing physically traceable procurement in the first statement and contract and certification (CoC) procurement in the second statement is easy to understand, the distinction between green steel and low-carbon fuels, which are mixed in grids and pools, remains a Issue for future discussion. Kawamata gives the example of steel, explaining, "Although some blast furnaces have been used for steelmaking using hydrogen reduction, the amount is still small, so if we allocate the decarbonization effect to specific steel materials, it will be recorded in the market-based inventory (second statement). In the future, when hydrogen reduction steelmaking becomes widespread and physically low-emission steel materials are realized, eliminating the need for allocation, it can be recorded in the physical inventory (first statement)."

Mr. Takase introduced the discussions on the revision of ISO 14067 (Product Carbon Footprint) *20) (an outline of which can be found in Annex D of the white paper), and explained that suitable CoC models (such as identity preservation, segregation, mass balance, book and claim) are being organized for each of the three approaches: physical, contractual, and mitigation (consequential), corresponding to the first to third statements.

③ Reduction contributions and credit treatment (Statement 3)

The downstream reduction effects of products of interest to Japanese companies (e.g., vehicle weight reduction through the use of high-tensile steel plates, reductions from the use of high-efficiency air conditioners) are expected to be covered in the "Impact of Product Use" category of the third statement. This will allow for the demonstration of the effects of products that significantly reduce emissions during use, even if emissions increase during Manufacturing , without confusing them with inventory data. Mr. Kawamata says that attention should be paid to how existing reduction contribution guidelines such as WBCSD are incorporated into the third statement. In the calculation of results, since reporting only positive effects may undermine stakeholder confidence, there is a growing need for completeness in the calculation, including negative "leakage."

The inclusion of carbon credits in the third statement is seen as a positive development, as it will promote credit utilization and improve transparency. However, Mr. Kawamata pointed out the need to clearly recognize the differences between various credit schemes. While J-credits can be used to deduct emission amount under the Global Warming Countermeasure and GX-ETS (emission amount Trading Scheme), they cannot be used for direct offsetting in inventories under the GHG Protocol. Furthermore, whether international credits such as Verra and Gold Standard, J-credits, and the Joint Crediting Mechanism (JCM) will be treated equally in the third statement remains a key point of discussion going forward.

④ The "consequential emissions impact" of electricity (Third Statement)

Subgroups of the Scope 2 TWG have been discussing how the introduction of low-carbon power sources can lead to reduced emissions by causing a decrease in the operation of high-emission fossil fuel power sources or delays in construction. Mr. Takase presented supply and demand examples from Tokyo and Kyushu, explaining that while increased solar power can lead to a reduction in fossil fuel power generation in some regions, daytime solar power generation exceeds demand and is therefore wasted. Thus, even with the same 1 MWh of renewable energy procurement, the impact on grid emission amount differs depending on the region and time of day *21) .

The Scope 2 TWG proposed using the formula "MWh × marginal Emission factor*22) " (considering both short-term and long-term marginal impacts) on the procurement and transaction units for the reporting year to evaluate the CO2 emission reduction effect that low-carbon power procurement brings to the grid *15) . This discussion was carried over to the AMI TWG and is expected to be incorporated into the third statement.

Furthermore, current revision discussions anticipate that virtual PPAs (virtual power purchase agreements) that do not meet the requirements for simultaneous and equal supply and availability will no longer be covered by the Scope 2 market standard *15) , but they may instead be mentioned in the third statement. In any case, it will be essential to clarify the roles of the statements and establish rules for duplicate disclosure, as well as whether to avoid double counting between attributable and consequential calculations.

Impact on other standards

Various standards- Settings bodies participated in the discussions to revise the GHG Protocol, and the design emphasizes interoperability. However, ultimately, how to apply the protocol's rules, including the four statements, to goal Settings and disclosure will be left to the discretion of each program, country, and region.

Takase, who also participates in the SBTi(Science-Based Targets Initiative) Technical Advisory Group, states that in the second draft of the Corporate Net Zero Standard 2 (CNZS 2.0) *23) , while activity pool-level traceability will be recognized, pool averages will be used at the emission intensity*24) , and the carbon bank method *25) will not be used in order to maintain the integrity of certificates, and that the focus going forward will be on designing consistency with the second statement. On the other hand, there is a direction to evaluate the effort itself to use primary data in the calculation of Scope 3, which, along with "visualization of efforts" in the third statement, could be a tailwind for companies working on decarbonization.

CDPs is a program that has collected data in accordance with the GHG Protocol for many years, and revisions to its questionnaires and scoring are expected once multi-statement practices become established. Climate-related disclosures under IFRS S2, SSBJ, GRI, and CSRD/ESRS require disclosure of GHG emission amount based on the GHG Protocol, and the calculation methods will likely be reviewed in line with revisions to the Protocol. While physical inventory is expected to remain the mainstay of these standards, there will be more room to disclose and use statements 2-4 as supplementary information for explanation. All of these programs should be expected to gradually align with the revised GHG Protocol between 2027 and 2030 *29) .

overview of the Request for Public Comment (RFI) and Key Points for Responding

The purpose of the RFI is to gather insights from diverse stakeholders regarding the multi-statement structure and the fundamental concepts of the second to fourth statements, and to reflect these insights in the standard- Create in the second phase (Phase 2). The questions remain at a conceptual level, and issues to be discussed in Phase 2, such as additionality and quality requirements, are summarized in Annex A of the white paper. By commenting on the RFI, it is believed that the GHG Protocol Secretariat and TWG members will gain a better understanding of the context of Japan's electricity market, certificate practices, and materials Industry, which will be beneficial for future system design.

The following are important points to note when submitting your RFI (submit via the URL provided at the end of this document).

• In principle, all responses will be made public. While anonymity can be selected at the beginning of the survey, respondents are responsible for ensuring their responses do not include any descriptions that could identify individuals or organizations.
• Requests for confidentiality of trade secrets, etc., require prior approval via a separate form (the original application deadline was April 30, 2026. Please check with the secretariat regarding how this will be handled after the extension).
• Comments sent via email or other methods may not be considered as valid procedural comments.

The first half of the survey (Q1-Q15) consists of agreement points and respondent attributes, while the actual questions are Q16-Q35.

(1) The entire multi-statement (Q16-19)

• Support for and opposition to the new reporting structure
• Benefits and Issue of implementation
• Proposed changes and improvements to increase support (with a space for writing up to 4,000 characters)
• Do you wish to proceed to the subsequent detailed questions? (Selecting No will end the survey.)

(2) Purpose, Goal, and Objective (Q20-21)

• Level of agreement with the objectives and goals of Chapter 4 of the white paper
• Evidence and proposed improvements (within 4,000 characters)

(3) Second Statement: Market-Based GHG Inventory (Q22-23)

• Evaluation of whether it should be included in multi-statements
• Supporting evidence and additional comments for Phase 2 (examples such as GX Steel and green gas certificates can be shown here)

(4) Third Statement: GHG Impact Statement (Q24-29)

• Evaluation of whether it should be included in multi-statements
• Agreement on subcategories (within organizational boundaries/within value chain/sector-related/global/product use impact), and whether subcategory consolidation is possible.
• Should both positive and negative effects (such as leakage) be reflected?
• Treatment of GHG impact (reduction contribution) from the use of products sold.
• Supporting evidence and additional comments (within 4,000 characters)

(5) Fourth Statement: Non-GHG Indicator Statement (Q30-32)

• Evaluation of whether it should be included in multi-statements
• Level of detail of the regulations
• Supporting evidence and additional comments (within 4,000 characters)

(6) Conclusion (Q33-35)

• other comments, concerns, or specific examples regarding the white paper as a whole (you can provide examples of Japanese companies in Q33)
• Issues not covered in Annex A but to be considered in Phase 2
• Registration for future pilot tests

To aid understanding, the appendix to the white paper's explanatory document (Exploratory Note) *26) provides an image of how GHG data would be distributed to each statement, assuming a European machinery manufacturer (Table 2). Adding Japanese examples to Q33 and the free-response sections would include examples not anticipated by the secretariat or TWG, which would help in creating detailed rules for Phase 2. Mr. Kawamata advises that companies that have pursued low-carbon procurement with a strong motivation to "properly report their efforts" are more likely to play a role in advancing international discussions through comments on the design of the second and third statements.

Table 2: Examples of GHG data inclusion in four statements

Zeroboard Create based on the AMI white paper explanation document *26)

How will the AMI discussion proceed from here? - Phase 2

Phase 1 involves creating the framework for "what, why, and within what framework to report," while Phase 2 involves creating practical rules for "how to quantify, what to make mandatory and optional, and how to verify." Feedback from the RFI will be released in the second half of 2026. After additionality, quality standards, and traceability are concretized, the TWG will draft the report, and after approval by the Independent Standards Board (ISB) in the first half of 2027, a formal public consultation will be held in the third quarter. The final adjustments and approval by the steering committee are expected to take place in early 2028 *9) .

The central agenda for Phase 2, as outlined in Annex A of the white paper, is as follows:

• Eligibility criteria, quality criteria, and safeguards for each statement (integrity of credits, certificates, contracts, and reduction claims)
• Whether the second and third statements are mandatory or optional, and whether overlap between statements is permitted.
• Levels of physical connectivity and traceability of market instruments in Statements 1 and 2 (feasibility and handling of residuals for each CoC model)
• Use of residual Emission factor in the second statement
• Third statement: Boundaries between subcategories, procedures for calculating product use impact, and treatment of positive and negative impacts.
• Common indicators and optional/mandatory disclosures in Statement 4
• Detailed definition and calculation methods, and verification of practical feasibility.
• Guidance for goal- Settings programs (how SBTi, CDPs, etc. can refer to each statement)

The possibility of providing supplementary guidance on sector-specific details, such as steel, chemicals, power, and aviation fuels, will also be a point of discussion in Phase 2.

The "four statements" expand the grammar of the GHG reports.

The AMI discussion goes beyond the single indicator of GHG emission amount by organizational units and attempts to standardize internationally the grammar for discussing the roles of various decarbonization efforts by providing four statements: physical reality (1), procurement and market choices (2), the results of interventions (3), and other progress indicators (4).

For Japanese companies, particularly those in sectors such as steel, chemicals, power, and Manufacturing, which are already pursuing decarbonization strategies through certificates and contracts, the design of the second and third statements will be directly linked to their business strategies. The RFI, due by June 15th, presents a valuable opportunity to contribute Japanese practical expertise to that design process.

In closing, Mr. Kawamata stated that, with an eye on the additionality, quality standards, and traceability that will be concretely implemented in Phase 2, it would be a realistic preparation for this entire long process for Japanese companies to proceed with procurement and the development of data and evidence without waiting for the rules to be finalized.

AMI Request for Comment (RFI) submission page
https://forms.cloud.microsoft/Pages/ResponsePage.aspx?id=H6xrR7I22UqGmc2mutH4YhlrKRh6eVZNoi6gmSnLL8BURE1JVEFFNUQ1NUJPNkozN0ozS0JYRFFaVS4u

*1) Greenhouse Gas Protocol, Actions and Market Instruments: Phase 1 Progress Update White Paper, Version 3 – Request for Information, March 2026.
https://ghgprotocol.org/sites/default/files/2026-03/AMI-Phase1-WhitePaper-RFI.pdf

*2)World Business Council for Sustainable Development (WBCSD) and World Resources Institute (WRI), The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard, Revised Edition, March 2004.
https://ghgprotocol.org/corporate-standard

*3) WRI and WBCSD, Corporate Value Chain (Scope 3) Accounting and Reporting Standard: Supplement to the GHG Protocol Corporate Accounting and Reporting Standard, September 2011.
https://ghgprotocol.org/corporate-value-chain-scope-3-standard

*4) WRI, GHG Protocol Scope 2 Guidance: An Amendment to the GHG Protocol Corporate Standard, 2015.
https://ghgprotocol.org/scope-2-guidance

*5) Greenhouse Gas Protocol, GHG Protocol Corporate Suite of Standards and Guidance Update Process.
https://ghgprotocol.org/ghg-protocol-corporate-suite-standards-and-guidance-update-process

*6) Progress of the TWG discussions on the revision of the GHG protocol is published in the Standards Development and Governance Repository.
https://ghgprotocol.org/standards-development-and-governance-repository

*7) Greenhouse Gas Protocol, Standard Development Plans.
https://ghgprotocol.org/standard-development-plans

*8) JETRO, "ISO and GHG Protocol Announce Strategic Partnership for Unifying GHG emission amount Standards," Business Brief, September 12, 2025.
https://www.jetro.go.jp/biznews/2025/09/1434cffe24688d4b.html

*9) Tomoo Machiba, Mahiro Endo, "Interim Report on the Revision of the GHG Protocol: How Will Scope 3, Renewable Energy Procurement, and Reduction Contributions Change?", Zeroboard Insight, November 4, 2025.
zeroboard

*10) Greenhouse Gas Protocol, Explanatory Memo: Request for Information – Actions and Market Instruments Phase 1 Progress Update White Paper, March 2026.
https://ghgprotocol.org/sites/default/files/2026-03/AMI-Phase1-WhitePaper-RFI-ExplanatoryMemo.pdf

*11) Greenhouse Gas Protocol, GHG Accounting and Reporting on the Impacts of Actions and Market Instruments – Standard Development Plan, 20 December 2024.
https://ghgprotocol.org/sites/default/files/2025-01/AMI-SDP-20241220.pdf

*12) International Organization for Standardization (ISO), ISO 22095:2020 Chain of custody – General terminology and models, Edition 1, 2020.
https://www.iso.org/standard/72532.html

*13) WBCSD, Guidance on Avoided Emissions v2.0: Drive innovations and scale solutions toward net zero, 24 July 2025.
https://www.wbcsd.org/resources/guidance-on-avoided-emissions-helping-business-drive-innovations-and-scale-solutions-toward-net-zero

*14) International Electrotechnical Commission (IEC), IEC 63372: Quantification of GHG emissions avoided through use of electrical and electronic products and systems – Principles, methodologies, requirements and guidance, Edition 1, January 2026.
https://cdn.standards.iteh.ai/samples/iec/iec-63372-2026/165991431b6e426189749a1aefe990f4/iec-63372-2026.pdf

*15) Tomoo Machiba, "Guide to Participating in Public Comments on the Draft Revision of the GHG Protocol Scope 2,"Zeroboard Insight, January 9, 2026.
zeroboard

*16) WRI and WBCSD, Greenhouse Gas Protocol Land Sector and Removals Standard Version 1.0: Agriculture and CO2 removal technologies, Supplement to the GHG Protocol Corporate Standard and Scope 3 Standard, 30 January 2026.
https://ghgprotocol.org/land-sector-and-removals-standard

*17) Japan Iron and Steel Federation, "GX Steel Guidelines and Related Guidelines"
https://www.jisf.or.jp/business/ondanka/kouken/greensteel

*18) Clean Gas Certificate Evaluation Committee, "Green Gas Certificate"
https://www.clean-gas-certificate.com

*19) JAL Corporate Solutions & Service website, "CO2 Reduction Certificate by SAF 'JAL Corporate SAF Program'" https://solution.jal.co.jp/solution-list/detail/saf-program

*20) ISO, ISO/WD 14067.2 Greenhouse Gases: Carbon footprint of products – Requirements and guidelines for quantification (under development).
https://www.iso.org/standard/90578.html

*21) Renewable Energy Foundation "Electricity Supply and Demand Chart" (updated as needed)
https://www.renewable-ei.org/statistics/electricity/#demand

*22) The marginal Emission factor refers to the amount of CO2 that is additionally emitted (or reduced) when electricity consumption increases by one unit. Generally, CO2 emission amount the amount of electricity used by the average Emission factor of all power sources. However, to calculate the effectiveness of CO2 reduction measures, it is necessary to use the Emission factor(= marginal Emission factor ) of power sources that are affected by the measures, such as reduced operating rates or postponement/cancellation of New construction (marginal power sources: in Japan, thermal power generation). (Reference: Japan Gas Association, "Effectiveness of CO2 Reduction Measures and CO2 Emission factor of Electricity," www.gas.or.jp/kankyo/taisaku/denki )

*23) Science Based Targets Initiative (SBTi) SBTi Corporate Net-Zero Standard, Version 2.0, Draft for Second Public Consultation, November 2025.
https://sciencebasedtargets.org/consultations/cnzs-v2-second-consultation

*24) Tomoo Machiba, Josefarisa Michel, "Revision of SBTi Net Zero Standard - Second Draft Released, Allowing Diverse Pathways to Emission Reductions,"Zeroboard Insight, December 1, 2025.
zeroboard

*25) The carbon banking method refers to an allocation method in which the "reduction value" generated when low-carbon products and materials are actually produced is managed like a "bank," separate from the physical product itself, and allocated to other products or customers.

*26) Greenhouse Gas Protocol, Actions and Market Instruments: Phase 1 Progress Update White Paper, Version 3 – Request for Information, Explanatory Memo, March 2026.
https://ghgprotocol.org/sites/default/files/2026-03/AMI-Phase1-WhitePaper-RFI-ExplanatoryMemo.pdf