This chapter explains the distinctions between several closely related concepts:

    • the carbon footprint calculation concerns all methods for characterizing greenhouse gas (GHG) emissions,
    • regulatory carbon footprint calculation are conducted to comply with statutory obligations of the french decree n°2011-829 of 11 July 2011 which imposes to realise scope 1 (direct emissions) and scope 2 (indirect emissions due to the use of electricity, heat or steam) and scope 3 as an option (other indirect emissions),
    • the Bilan Carbone® is the most widespread method used in France to estimate emission sources,
    • other methods for assessing GHG emissions are used in other countries, such as the PASS 2030 system in the UK.

Whatever the tool, method or strategy applied under the regulations, GHG estimation is always associated with an action plan to reduce emissions.



The development of human activities accentuates the greenhouse effect. The international community recognized the importance of the issue in 1993, with the United Nations Framework Convention on Climate Change (UNFCCC) signed in Rio, and has developed measures to control the greenhouse effect.

The UNFCCC recognizes "common but differentiated responsibilities" depending on countries. This is why, although certain parties are willing to make efforts, only the industrialized countries (those in Annex I to the Convention) undertook to stabilize their emissions from 1990 to 2000, a goal that has not been fully achieved.

The scope of the Convention was reinforced by the signature of the Kyoto Protocol in 1997 by 84 countries. This Protocol assigns legally binding commitments to the industrialized countries to reduce their greenhouse gas emissions within the 2008-2012 period, with 1990 emission levels used as a baseline. Following its ratification by Russia at the end of 2004, the Kyoto Protocol came into force on 16 February 2005.

Under the Kyoto Protocol, the European Union undertook to reduce its greenhouse gas emissions by 8% during 2008-2012, as compared to its 1990 emission levels. The necessary efforts were shared between the different Member States. France's target is to stabilize its emissions and emit no more than 557 million tonnes of CO2 equivalent per year from 2008 to 2012.

A new global greenhouse gas emissions reduction target was set for the period 2013-2020 (KYOTO 2): at least -18 % compared to the level of 1990. 37 Parties have made a commitment on individual reduction targets for this period. For example, the European Union has to reduce its emissions by 20 % on the basis of 1990.

The EU adopted the Climate and Energy Package, which aims to reduce GHG emissions in the 27 Member States by 20% from 1990 to 2020. This is the first time that differentiated reduction targets were adopted for sectors covered by the EU emissions trading system (EU-ETS) and those not covered (road transport, agriculture, residential sector, etc.). Various European legislative acts (regulations, directives and decisions) have been adopted to build up a regulatory framework supporting the achievement of these targets.

Moreover, at the 21st Conference of the Parties to the Climate Convention (COP-21), the Paris Agreement was adopted on 12 December 2015 by its 196 Parties. It is the first international legal instrument which binds industrialized countries and developing country in a new common and unified system which aims to reduce greenhouse gas emissions. The Paris Agreement sets a target to limit the increase of the global average temperatures "well below" 2°C (before 2100) with regard to pre-industrial levels and to aim if possible 1.5°C.

The EU intends to reduce by at least 40% its greenhouse gas emissions, between 1990 and 2030.


Regulatory carbon footprint calculation

Among the provisions set out in the French "Grenelle 2" law (n°2010-788 of 12 July 2010), Article 75 imposes the elaboration of greenhouse gas emission calculation under conditions.

Under the French "Grenelle 2" law (article L 229-25 of the Environmental Code), decree n° 2011-829 of 11 July 2011 defines the content and procedures to elaborate the carbon footprint calculation and territorial energy-climate Plan (PCET).

At first, the carbon footprint calculation concerns:

    • corporate entities under private law employing more than 500 people in mainland France and 250 people in overseas,
    • local authorities with more than 50 000 inhabitants and state,
    • public bodies with more than 250 agents.

Under the French Ordinance n°2015-1737 of December 24, 2015, the carbon footprint calculation must be made public and updated every four year at least for the companies concerned and for three years for the public entities concerned. The first calculation had to be carried out by 31 December 2012 at the latest.

Moreover, Decree n°2015-1738 of December 24, 2015 specifies the arrangements for the penalty regime in the event of the carbon footprint not being conducted (a fine amounting to maximum of 1500 €). It also specifies rules on collecting the information necessary for the follow-up and assessment of the carbon footprint (

The carbon footprint calculation must be established according to the organizational scope of the legal entity:

  • Financial control: the organization strengthens 100% of its installations emissions for which it exercises a financial control,
  • Operational control: the organization strengthens 100% of its installations emissions for which it exercises an operational control.

Once the organizational scope is defined, the legal entity has to define its operational scope (which operations generate emissions within the entity?). A distinction according to three scopes is done:

  • Scope 1: direct emissions generated by the stationary or mobile sources necessary for the activities of the legal entity (compulsory),
  • Scope 2: indirect emissions related to electricity, steam and heat consumption necessary for activities of the legal entity (compulsory),
  • Scope 3: other indirect emissions generated by activities of the legal entity (optional).

The list of the various sources to be taken into account is presented in the following table:

Scope Sources Obligation towards
the decree
1 Direct GHG emissions 1 Direct emissions from stationary combustion Compulsory

2 Direct emissions from mobile combustion
3 Direct process emissions
4 Direct fugitive emissions
5 Removals and emissions from biomass (grounds and forests)
2 Indirect GHG emissions related to energy 6 Indirect emissions from electricity use Compulsory
7 Indirect emissions from heat, stream and cooling
3 Other indirect GHG emissions 8 Energy-related activities not included in scope 1 and 2 Optional
9 Purchased products and services
10 Capital equipment
11 Wastes
12 Transport from supplier
13 Business travel
14 Upstream leased assets (only for lessees)
15 Investments
16 Client and visitor transport
17 Transport and distribution to clients
18 Use phase of sold product
19 End of life of sold product
20 Downstream franchises (only for franchisors)
21 Upstream franchises (only for franchisors)
22 Employee commuting
23 Other indirect emissions


The French Environment Ministry also provides methodological guides for operators and local authorities on the production of carbon footprint calculation. All of these documents may be downloaded from:

The decree sets out the regulatory scope and obligations as follows:

"The carbon footprint calculation [...] assesses the volume of greenhouse gas emissions generated by the activities of the corporate entity within the national territory during a given year. The volume to be assessed is that produced during the year preceding the year when the carbon footprint calculation is made or updated or, if the data are not available, during the penultimate year. Emissions must be expressed in tonnes of carbon dioxide equivalent. The carbon footprint calculation distinguishes between:

  1. Direct emissions produced by stationnary and mobile sources necessary to the activities of the corporate entity;
  2. Indirect emissions from the consumption of electricity, heat, steam or cooling necessary to the activities of the corporate entity.

A summary of reduction actions, attached to the report [...], describes, for each category of emissions indicated in 1. and 2. above, the measures that the corporate entity plans to implement during the three years following the carbon footprint calculation. The corparate entity indicates the total volume of expected GHG emission reductions."

CITEPA dedicated its 2012 "study day" to the Carbon footprint calculation theme. You can download the best sheets of this "study day" on this site if you are a member.


Voluntary emission carbon footprint calculation

Any entity, company or public authority not required by law to produce a carbon footprint calculation may, if they so wish, do so on a voluntary basis.


Indirect emissions

Indirect emissions generated by an organization

The regulatory provisions of Decree n°2011-829 only require an assessment of indirect emissions from electricity, heat or cooling consumption. However, assessments of other indirect GHG emissions are strongly recommended, especially those generated by employee and visitor travel, goods transport, production of inputs, treatment of waste generated, uses and end-of-life of products sold, etc.

Characterizing indirect emissions has several advantages:

    • In most cases, the majority of an organization's emissions are indirect. Estimating these therefore helps to define an action plan allow to achieve significant reductions in the organization's GHG emissions.
    • Later the inclusion of these emissions could become compulsory (their integration is supported by the Association of the Professional Carbon Consultants (APCC) which CITEPA is a member).

The main emission sources from the three scopes are shown in the diagram below:

 Graph1 Postes emissions Categories

Source : CITEPA from from carbon footprint calculation and Bilan Carbone®


Indirect emissions generated by a local authority area

Local authorities producing a carbon footprint calculation may also, if they so wish, characterize the indirect GHG emissions generated by their activities. Doing so can, in particular, help to determine ways of acting on transport modes, goods transport and imports. CITEPA has developed a specific tool to assess these emissions (see below).

The emission sources considered are as follows:

Graph2 Postes emissions consideres


Bilan Carbone®

As indicated above, all human activities of whatever nature release GHG emissions either directly or indirectly. It is therefore legitimate for any company, administrative activity or association to take an interest in calculating carbon footprint in order to take action. This is the context in which the French Agency for the Environment and Energy Management (ADEME) developed its Bilan Carbone® methodology in 2004. The Bilan Carbone® is designed to:

  • calculate the GHG emissions generated by the activity concerned,
  • establish the order of importance of its emissions by source,
  • assess the activity's GHG impacts,
  • if necessary, propose an action plan to reduce emissions in the short and medium term, setting out strategic guidelines.

The value and originality of Bilan Carbone® method lie on its capacity to assess both direct and indirect carbon emissions generated by the activity in question.

In 2011, given the method's success and the need to meet ever-increasing demand in a changing regulatory context, ADEME selected the Association Bilan Carbone (ABC) to manage and upgrade the method.

The tool "Bilan Carbone®" has the advantage to be able to answer, either in the statutory carbon footprint calculation, or in the voluntary carbon footprint calculation or in the consideration of a wider scope.


CITEPA assistance in preparing carbon footprint calculation and seeking improvements

CITEPA's areas of competence

CITEPA has the necessary experience and competence to produce carbon footprint calculation. CITEPA proposes several types of contribution:

    • Ensure conformity for a large majority of the emission factors between the "Base Carbone" managed by the ADEME for the entities who produce carbon footprint calculation and emission factors produced by CITEPA in its national GHG inventory,
    • Realisation of carbon footprint calculation from a regulatory minimum to a voluntary approach spread to scope 3 and widened to action plans under constraint (references),
    • Realisation of footprint calculation for other pollutants,
    • Optimisation of action plans under constraint (for the GHG as for other pollutants),
    • Audit and third expertise of footprint calculation already realised by the organisation,
    • Audit and third expertise in a tool developed by another organisation in order to verify the conformity of the tool with different references as the GHG Protocol or the standard ISO 14064/14069,
    • Assistant for the writing of sectorial guides allowing to define common methodologies specific to a sector,
    • Combined offer of the previous services.


Producing a regulatory or voluntary carbon footprint calculation

CITEPA has required experience and skills to realise carbon footprint calculation:

  • Use of the tool Bilan carbone® developed by ADEME and recently updated by the ABC (CITEPA holds a licence to use version 7 of the Bilan Carbone® tool),
  • Experience and realisation of numerous Bilan Carbone® and carbon footprint calculation (references),
  • A reference skill regarding inventories of GHG emissions and the atmospheric pollutants. CITEPA is mandated from the Ministry of Ecology, to realise the inventories of greenhouse gas emissions and atmospheric pollutants of France, and towards the international authorities such as UNECE and UNFCCC. CITEPA participates in the national Pole of coordination of Carbon Footprint Calculation and in the Committee of Governance of the Base Carbone,
  • A thorough and realistic knowledge of activity sectors. CITEPA leans on a group of 80 representative members of the sectorial diversity.


Development of technico-economic approach within the framework of the determination of action plan

Once the calculation of greenhouse gas emissions realised according to the defined scope, the global volume of greenhouse gas emissions reduction must be estimated for the 3 years following the reporting year.

The action plan can be wider than the simple calculation of the reduction of GHG emissions. It can also integrate technical and economic dimensions on the various categories (1, 2 and 3) and thus be a decision-making tool for local authority areas and industrials.

CITEPA offers to its clients an action plan for its carbon footprint including at least hypothesis of cost/efficiency calculation up to a module of cost-benefit analysis.

This innovative approach allows industrial or local authorities to assess scenarios under economic constraint. It allows to optimise costs and benefits related to defined mitigation objectives or to optimise mitigation objectives according to defined costs and benefits objectives. In both cases, an estimation of profits and internal and internalised costs, caused by emissions reductions, is made allowing scenarios analysis.


Audit of existing tool for the calculation of greenhouse gas emissions 

CITEPA has already audited existing GHG emissions calculation tools in order to check the consistency of thesetools with the statutory requirements of the decree n°2011-829.

This audit usually leads to recommendations from CITEPA in order to conform the tool with the regulation or the GHG Protocol or the standard ISO 14064/14069.


Development of specific tool

As mentioned previously, CITEPA has developed a specific tool for the calculation of indirect emissions of a territory. This tool has been implemented for several territories (references).


Implemented approach to realise statutory or voluntary carbon footprint or more widened scope

CITEPA helps you during the realisation of your carbon footprint calculation. The most important stages are defined on the plan below:

Graph3 Etapes rea BEGES

Source : Methodological guidelines from carbon footprint calculation (BEGES)


Determining direct and indirect emissions of local authority areas

Estimating the emissions of a local authority area at the point where they are actually produced provides a guarantee of methodological consistency for international comparisons between geographical entities. The advantage of this approach lies in the thorough and objective definition of perimeters within which the same emissions cannot be attributed to different sources.

Activities within a local authority area have repercussions beyond its boundaries (e.g. movement of people, incoming and outgoing goods transport, external production of consumer goods), generating external emissions which are described as "indirect". When these emissions are known, the information provides additional material to support policies addressing the greenhouse effect. Different approaches for their quantification have emerged in recent years.

This approach has several advantages:

    • Direct emissions from a local authority area can be calculated to comply with different reporting formats: Kyoto, National Climate Plan and others (SECTEN), specific formats used by local authorities, etc.);
    • Direct and indirect emissions are separated so that specific prevention and reduction measures can be more closely targeted;
    • Emissions can never be counted twice as the different sources are completely separated;
    • CITEPA provides its expertise to help choose relevant emission factors and apply the necessary tools, and to clarify climate change and air pollution issues and associated regulations;
    • Offer of training to understand how to calculate emissions and conduct periodic updates;
    • Provide indicators to monitor the activities undertaken and keep a check on progress;
    • Our services and tools can be adapted to cater for different needs.


Approach exclusively GHG or multi-pollutants?

Depending on the organisation concerned by the carbon footprint calculation, namely a company or a local authority, the request and ambitions regarding monitoring, reporting and verification (similar process to the MRV) will not be necessarily the same.

Then, as State operator in charge of GHG emissions and atmospheric pollutants national inventories, CITEPA often adopts the position of the minor expert (or third expert). Participating with ADEME in the validation of emission factors for Base Carbone, CITEPA can check the carbon footprint already realised and propose recommendations related to its methodological optimisation or to its extension. However, holder of the license Bilan Carbone® and with an already extensive knowledge of all activity sectors and emission factors, CITEPA carries out carbon footprint calculation for different clients.

Thus CITEPA will examine with its client (local authority, territory or private enterprise) the best scope for carrying out its carbon footprint calculation. Indeed, while the decree n°2011-829 concerns only greenhouse gases, CITEPA can recommend, if necessary, a multi-pollutants / GHG monitoring which would allow the organisation to report its progress regarding greenhouse gas emissions while watching the consequences of the GHG reduction plan over atmospheric pollutant emissions with regard to human health for example. In a wider perspective of Corporate Social Responsibility, it can be particularly relevant to check that GHG action plans do not damage health because of non required and non anticipated consequences to the air quality. Yet in many cases of energetic mix choice, such as process optimisation, reduction of GHG emissions can come along with an increase of atmospheric pollutant emissions (NOx, particulate matter, etc.). Organisations try to apply their responsibility within the framework of a sustainable development not only with regard to the climate change, but also in terms of local air quality or transboundary pollution. This optional offer widened to particulate matter, NOx and CO for example is possible using the knowledge of CITEPA regarding national inventories of pollutants.


Statutory carbon footprint calculation or technico-economic approach?

Regarding the current law, there is no need to implement the scope 3 (indirect emission) or to establish action plans other than one with reduction figures.

But the uncertain macroeconomic context as well as the search for competitiveness incite these operators to optimise the progress.

Within the framework of an action plan integrating technical and economic extents for the scopes 1, 2 and 3, and in order to develop a decision-making tool for every type of organisation, CITEPA suggests establishing an action plan for carbon footprint including at least the hypothesis of cost/efficiency calculation. This innovative approach would allow the industrial or the local authority to estimate scenarios under economic constraint.


Scheme for all scope options for carbon footprint and action plan on the scale of an entity or a local authority

The figure below shows two possibilities of service offered by CITEPA, either considering only GHG or including pollutants, given the different possible scopes.

Schema1 Service CITEPA

Schema2 Service CITEPA

Legend :

(1)= physical quantity of GHG
(2)= physical quantity of GHG for direct and indirect emissions
(3)= direct and indirect GHG emissions according to technical and economic sizes extent
(1')= physical quantity of different pollutants
(2')= physical quantity of different pollutants for direct and indirect emissions
(3)= direct and indirect emissions of different pollutants according to technical and economic sizes extent

In the graphs above, footprint calculation types are spread out horizontally towards the option relative to pollutants (noted X') according to the consideration of various pollutants in the footprint calculation, and vertically according to the complexity of the technical or technico-economic parameters.

The multi-pollutants approach requires a large knowledge of activity sectors and emission factors.

As the case may be, CITEPA can work as third expert who verifies and audits carbon footprint which are realised by the organisation or by an external service provider, in order to make recommendations about methods or objectives. In other cases, CITEPA can itself realise footprint calculations according to the defined choice of scope.

Then according to the organization ambitions, several solutions can be offered by CITEPA (as third expert or external service provider):

  1. Only the statutory carbon footprint calculation was realised. The calculation of the indirect emissions (scope 3) and the realisation of technico-economic action plan can be proposed or a complete approach for other pollutants (calculation of the direct and indirect emissions and determination of a technico-economic action plan).
  2. A widened carbon footprint calculation was already realised (scopes 1, 2 and 3). CITEPA will complete or recommend an economic approach for the action plan concerning greenhouse gases. It can also realise a complete approach for other pollutants (calculation of the direct and indirect emissions and determination of a technico-economic action plan for these pollutants).


CITEPA references concerning Bilan Carbone®, carbon footprint calculation and indirect emissions from local authority areas


The results of carbon footprint calculation for CITEPA