Key Points
- Global climate regulations are tightening, driving demand for accurate and verifiable greenhouse gas (GHG) data.
- ISO 14064-1 provides structured requirements for organisational greenhouse gas (GHG) quantification, boundaries, data quality and uncertainty management.
- ISO 14064-3 ensures greenhouse gas (GHG) statements are transparent, consistent and assurance-ready.
- Major regulatory frameworks align with ISO standards, including:
EU Carbon Border Adjustment Mechanism (CBAM) – harmonised methods & mandatory verification
China Emissions Trading System (ETS) – strengthened monitoring, reporting, and verification (MRV) and activity-data traceability
HKEX IFRS S2 – assurance-ready climate disclosures from 2025
EU Ecodesign for Sustainable Products Regulation (ESPR)/ Digital Product Passport (DPP) – ISO-based organisational data for product carbon transparency
- ISO 14064 enables unified, comparable and audit-ready greenhouse gas (GHG) data across markets.
- Standard Introduction
ISO 14064‑1:2018 specifies organization‑level requirements for quantifying and reporting greenhouse gas (GHG) emissions and removals. It addresses organizational and operational boundaries, identification of sources and sinks, selection of quantification methods, data quality and uncertainty management, and reporting under the principles of relevance, completeness, consistency, accuracy and transparency. The standard is programme‑neutral, enabling inventories to support multiple regimes.
ISO 14064‑3:2019 sets principles and requirements for verification of greenhouse gas (GHG) statements, including assurance level, materiality, risk‑based planning, evidence evaluation, competence and impartiality—turning inventories into decision‑grade statements.
2. Importance of greenhouse gas (GHG) Inventory Quantification and Verification
Growing global regulatory pressure is rapidly reshaping how organisations quantify, manage and disclose greenhouse gas (GHG) emissions. A technically robust greenhouse gas (GHG) inventory, developed in full accordance with ISO 14064‑1:2018 and subsequently verified under ISO 14064‑3:2019, has become a foundational requirement for compliance with both established statutory frameworks and newly emerging regulatory schemes.
2.1 EU – Carbon Border Adjustment Mechanism
Carbon Border Adjustment Mechanism (CBAM)’s technical documentation embeds explicit expectations for harmonised quantification and third‑party verification of embedded emissions for specified carbon‑intensive goods. Under the definitive phase effective 2026, importers must apply prescribed system boundaries, enforce mandatory reporting of activity data at installation level, and adopt conservative assumptions where data uncertainty is high. These requirements closely mirror ISO 14064‑1’s rules on:
- Boundary selection
- Activity‑data traceability and evidence chains
- Emission factor justification and hierarchy
- Uncertainty characterization
Additionally, ISO 14064‑3’s verification approach, which includes materiality assessment, rigorous evidence gathering and risk‑based verification planning, directly parallels the verification procedures required under Carbon Border Adjustment Mechanism (CBAM). This alignment ensures that greenhouse gas (GHG) statements meet CBAM’s expectations for accuracy and reproducibility.
2.2 Mainland China – Reinforcement of National Emissions Trading System (ETS) monitoring, reporting, and verification (MRV) Requirements
China’s strengthening of its national Emissions Trading System (ETS) incorporates increasingly stringent monitoring, reporting, and verification (MRV) requirements, emphasising high‑resolution activity data, sector‑specific methodologies, and third‑party verification. ISO 14064‑1 provides a compatible framework through:
Structured categorisation of emission sources and sinks aligned with Emissions Trading System (ETS) sectoral guidelines
Activity‑data governance requirements, including documentation, traceability and quality controls
Mandatory uncertainty management, which is necessary for Emissions Trading System (ETS)‑compliant reporting
ISO 14064‑3’s verification model—focused on risk identification, validation of internal controls, and cross‑checking of measurement‑based and calculation‑based data—supports enterprises in meeting Emissions Trading System (ETS) verification standards as the system expands and tightens toward 2027.
2.3 Hong Kong – HKEX IFRS S2‑Aligned Climate Disclosure Requirements
HKEX has introduced the New Climate Requirements, effective for reporting periods beginning on or after 1 January 2025. To comply with the New Climate Requirements, issuers must establish quantification and reporting processes capable of producing transparent, traceable and assurance‑ready greenhouse gas (GHG) data. This includes:
- Clear organisational boundary determination, ensuring consistent attribution of Scope 1 and Scope 2 emissions.
- Methodological consistency in calculating emissions, including justified selection of activity data and emission factors.
- Controlled data management, including documentation of data sources, versioning of emission factors and maintenance of data lineage.
- Quantitative uncertainty assessment, aligned with internationally recognised greenhouse gas (GHG) quantification principles (e.g., ISO‑based approaches).
Given that HKEX’s climate disclosure framework is aligned with IFRS S2, where verifiability, consistency and audit‑readiness are essential principles, ISO 14064‑1 and ISO 14064‑3 provide the structural foundation needed for compliance. By adopting ISO 14064 based systems, issuers can ensure that their disclosures not only comply with HKEX requirements but also meet future expectations for external assurance, international comparability and progressive regulatory tightening.
2.4 EU- Ecodesign for Sustainable Products Regulation (ESPR)
Though Ecodesign for Sustainable Products Regulation (ESPR) applies at the product level, it presupposes a technically sound organisational greenhouse gas (GHG) inventory as a prerequisite for accurate lifecycle‑based assessments. Compliance with Ecodesign for Sustainable Products Regulation (ESPR)’s anticipated requirements, such as Digital Product Passport (DPP) emissions transparency, requires the following:
- A complete and uncertainty‑quantified organisational greenhouse gas (GHG) baseline, derived from ISO 14064‑1
- Methodological coherence between organisational inventories and product‑level calculations (e.g., ISO 14067)
- Evidence‑based verification controls, aligning with ISO 14064‑3’s materiality and sampling rules
Thus, ISO 14064‑1 and ISO 14064‑3 enable organisations to construct the data infrastructure necessary to support Ecodesign for Sustainable Products Regulation (ESPR)’s product‑level quantification, verification and digital‑traceability demands.
3. CMA Testing’s Role
CMA Testing, originating from the Chinese Manufacturers’ Association and carrying a longstanding mandate to support industrial development, has continuously expanded its technical competence in environmental and sustainability assessment. The organisation is accredited by the Hong Kong Accreditation Service(HKSA) for greenhouse gas (GHG) inventory quantification under ISO 14064‑1:2018 and greenhouse gas (GHG) verification under ISO 14064‑3. Through HKAS’s participation in the multilateral recognition arrangements of the International Accreditation Forum, the International Laboratory Accreditation Cooperation and the Asia Pacific Accreditation Cooperation, the results issued within the accredited scope are internationally recognised, reflecting the principle of accredited once, accepted everywhere.
Against this regulatory backdrop, CMA Testing supports industries in strengthening their organisational readiness through the following integrated roles.
3.1 Building reliable and standardised greenhouse gas (GHG) inventory systems
A credible greenhouse gas (GHG) inventory forms the foundation of all climate‑related disclosure and compliance work. CMA Testing assists organisations in designing and implementing ISO 14064‑aligned systems that define clear boundaries, establish traceable data collection processes and maintain consistent methodologies over time. By embedding evidence chains, data lineage and uncertainty management into routine operations, companies can shift from fragmented carbon accounting practices to structured and verifiable greenhouse gas (GHG) data governance. This foundation is essential for meeting regulatory expectations under HKEX, Carbon Border Adjustment Mechanism (CBAM), Emissions Trading System (ETS) and other emerging regimes.
3.2 Strengthening assurance readiness and internal controls
As external assurance becomes increasingly central to climate reporting frameworks, organisations must ensure that their greenhouse gas (GHG) statements can withstand rigorous verification. CMA Testing supports this process by conducting gap analyses against ISO 14064‑1 and ISO 14064‑3, carrying out pre‑verification assessments and helping enterprises establish effective internal controls to reduce material uncertainties. This enables organisations to produce assurance‑ready disclosures that meet the expectations of regulators, auditors and investors.
3.3 Reducing compliance burden for SMEs and large enterprises
Many companies in Hong Kong and the region lack dedicated environmental teams, which can make compliance with new climate regulations challenging. CMA Testing addresses this by providing practical guidance and tools such as structured activity‑data templates, sector‑specific emission‑factor recommendations and uncertainty‑reduction practices. These resources allow enterprises to meet regulatory requirements efficiently while maintaining technical integrity.
3.4 Supporting alignment across multiple regulatory regimes
Supply chains are now operating under increasingly overlapping regulatory jurisdictions. CMA Testing helps organisations align their methodologies across HKEX, Carbon Border Adjustment Mechanism (CBAM), China Emissions Trading System (ETS) and the Ecodesign for Sustainable Products Regulation (ESPR), ensuring consistency in carbon accounting practices. This includes harmonising organisational greenhouse gas (GHG) inventories with product carbon footprint methodologies based on ISO 14067 and building data management systems capable of supporting future requirements such as the Digital Product Passport.
3.5 Delivering internationally recognised end‑to‑end greenhouse gas (GHG) services
With its accredited competencies and sector experience, CMA Testing provides a full suite of greenhouse gas (GHG)‑related services, including ISO 14064‑1 inventory quantification and reporting, ISO 14064‑3 verification with reasonable or limited assurance, and advisory services that help organisations align their reporting processes with IFRS S2, the greenhouse gas (GHG) Protocol, Carbon Border Adjustment Mechanism (CBAM) and Emissions Trading System (ETS) monitoring, reporting, and verification(MRV) requirements. These services support companies in transforming climate compliance from a regulatory obligation into a strategic capability that enhances supply‑chain confidence and global market access.
For inquiries about related services, please contact:
HK, China
Eva Kung evakung@cmatesting.org
SZ,China
Clara Chu (+86) 138 2880 6404 clarachu@cmatesting.org
SH,China
Yuki Zheng (+86) 021 6433 0500*388 yukizheng@cmatesting.org
