SEC removes Scope 3 requirement in climate reporting rules Sarah Gonzalez March 6, 2024

SEC removes Scope 3 requirement in climate reporting rules

ARLINGTON, Va., March 6, 2024 — The U.S. Securities Exchange Commission (SEC) voted to finalize a new climate reporting rule without a previously proposed requirement for U.S.-listed companies to disclose Scope 3 greenhouse gas emissions.

The National Grain and Feed Association (NGFA) issued the following statement:

“Calculating Scope 3 emissions is widely recognized as being inherently much more difficult than determining direct and indirect emissions (Scopes 1 and 2) and calculating such emissions requires significant personnel, resources, expertise, and data management. NGFA thanks the SEC for recognizing that the proposed Scope 3 rule would have transferred the reporting burden and associated costs to participants in the agricultural value chain who in many cases do not have the resources or expertise to provide such information. The final rule avoids disproportionately affecting smaller value chain participants. Many NGFA member companies have led the industry in commitments to reduce greenhouse gas emissions. The Association is committed to fostering an environment in which resources to achieve these market-driven goals can be shared among large, small- and mid-sized value chain participants.”

SEC announced in March 2022 a proposed rule requiring publicly traded companies to provide certain climate-related information in their registration statements and annual reports, including “emissions from upstream and downstream activities in the value chain,” referred to as “Scope 3” emissions. In comments submitted in June 2022 to the SEC, the NGFA, American Feed Industry Association, and North American Millers Association outlined several burdens the proposed requirements would have created in the agricultural value chain.

The final rule approved by the SEC limits the disclosure requirement to Scope 1 and Scope 2 emissions, or those that a company directly produces, and those associated with its energy consumption.


The NGFA, established in 1896, consists of grain, feed, processing, exporting and other grain-related companies that operate facilities handling U.S. grains and oilseeds. Its membership includes grain elevators; feed and feed ingredient manufacturers; biofuels companies; grain and oilseed processors and millers; exporters; livestock and poultry integrators; and associated firms that provide goods and services to the nation’s grain, feed and processing industry. The NGFA consists of 27 affiliated State and Regional Grain and Feed Associations, is co-located and has a strategic alliance with North American Export Grain Association, and a strategic alliance with Pet Food Institute.

Media Contact:

Sarah Gonzalez

NGFA Director of Communications and Digital Media