Scope 3 Supplier Questionnaire: What Canadian Suppliers Need To Know
If your largest customer has asked you for emissions data, you are not being audited and you have not broken any law. Their reporting obligation has reached you through the purchase order, and the only thing being tested is whether you are easy to buy from.
Last updated . Written for Canadian suppliers by Accelerated Exposure, Greater Toronto Area, Ontario.
There is no Canadian statute that requires a small supplier to report its emissions. There is no filing deadline with your name on it, no regulator who will contact you and no phase in period. That is precisely why almost nobody in Ontario manufacturing has seen this coming.
Why the request reaches you when the law names somebody else
California's climate disclosure law, SB 253, requires companies with more than one billion dollars in revenue that do business in California to publicly report their greenhouse gas emissions. Scope 3 reporting, which covers emissions the company does not create itself, begins in 2027 using 2026 data.
One of the first Scope 3 categories in scope is purchased goods and services. That means your customer is legally required to publish a number describing the emissions embedded in what they buy. They cannot calculate that number without you. So they ask, and because the ask arrives from procurement rather than from a regulator, it arrives attached to the account that pays your payroll.
Who this is actually going to hit
Southwestern Ontario is built on supplying American manufacturers. Every large automotive customer clears the revenue threshold comfortably, and so do the food, retail and industrial buyers that Ontario plants have shipped to for decades. Guidance to those companies has been to begin supplier engagement ahead of the 2027 reporting date, which is why the first questionnaires are landing now rather than in 2027.
| What people assume | What is actually true |
|---|---|
| It is a California law, so it does not apply to me | Correct. It applies to your customer, and reaches you through their purchase order |
| I will get a notice when it starts | You will not. There is no regulator on your side of this |
| Small suppliers will be exempt | There is no exemption from a contractual condition |
| 2027 is a long way off | The first reporting covers 2026 data, so questionnaires are going out now |
What a good response looks like
- Twelve months of hydro and natural gas consumption, taken from bills rather than estimates
- Direct fuel burn from company vehicles, forklifts and any on site combustion
- Production or shipment volume for the same period, so the figure can be expressed per unit
- Published emission factors applied consistently, with the source of each factor documented
- A written method, because a number nobody can trace cannot be used in a public disclosure
None of that requires special equipment or a site visit. It requires the right factors, applied correctly, and the ability to show your working.
How we help
We calculate your Scope 1 and Scope 2 emissions from your own bills, answer the questionnaire in the form your customer asked for, and build you a standing response pack so the next customer who asks is an update rather than a fresh project. Then we refresh it annually, because they will ask again every year.
We have tracked this since the rule was written, not since the envelope landed. If a form has already arrived, bring it. If one has not, book a free briefing and be ready before it does.
Common questions
What information will a Scope 3 emissions questionnaire actually ask for?
Most supplier questionnaires ask for four things. First, your annual energy use, which comes off your natural gas and hydro bills. Second, your direct fuel burn, meaning company vehicles, forklifts and any on site combustion. Third, production volume or revenue for the same period, so the customer can express your emissions per unit of what they bought. Fourth, your calculation method, because a number without a method behind it is not usable in a public disclosure. Some larger customers add questions on reduction targets and third party verification, but those are usually optional in the first year. Nothing on the form requires special equipment or a site audit. It requires twelve months of utility bills, an accurate production figure and published emission factors applied consistently. The difficulty is not the arithmetic. It is knowing which factors apply and being able to show your working when the customer asks.
What happens if I ignore my customer's emissions request?
Nothing happens immediately, and that is what makes ignoring it tempting. There is no fine, no regulator and no filing deadline attached to you, because the legal obligation belongs to your customer and not to your business. What happens instead is slower and worse. Your account gets flagged internally as a data gap, and data gaps are exactly what a procurement team is asked to close before the reporting year ends. When a buyer must choose between two suppliers of similar price and quality, and one of them returns a clean emissions figure while the other returns silence, the decision makes itself. Nobody sends a warning letter. The next contract simply goes elsewhere and you are never told why. Suppliers rarely lose accounts over emissions. They lose accounts over being the hard one to work with.
How long does it take a small supplier to get emissions ready?
For a typical small or mid sized manufacturer, two to three weeks from a standing start. The first week is gathering, meaning twelve months of hydro and gas bills, fuel card statements and your production or shipment totals for the same period. The second week is calculation, applying the correct published emission factors to each energy source and documenting which factor was used and why. The third week is packaging, turning the result into a response pack you can send to any customer who asks rather than starting over each time. Once that pack exists, every future questionnaire is an update rather than a project, and the annual refresh takes days instead of weeks. The businesses that struggle are the ones that start the week the form arrives with a two week deadline attached. Starting before the envelope lands is the entire advantage.
Now you have a guy
Accelerated Exposure is a Greater Toronto Area firm. We watch for the surprises that hit Canadian businesses so the owner running the operation does not have to go looking for them. Compliance is one arm of that. The rest of what we do is growth.
- AI integration that arms your staff rather than replacing them
- Competitive intelligence and getting found in AI search
- Reactivating the customers who quietly stopped calling
- Compliance across accessibility, hiring, privacy, transport and trade
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