How football clubs should report their carbon footprint
Draft guidance for a standardised approach
Introduction
By Fran James, Football and Climate Change Newsletter
What is the carbon footprint of the club you support? In what areas are they making progress in reducing emissions and where not? How does progress compare to others? Are they prioritising the right areas and on track to meet targets?
Efforts to answer these questions are being hampered by the lack of a standardised approach to emissions reporting in football.
Despite great work on reporting by some clubs, there is a variety of disconnected approaches. Some are more comprehensive than others, and some measure the same things in different ways. A lack of clarity and consistency prevails.
Teams are not expected to play on a pitch they do not know the size of. And they are not expected to play teams who are working to different rules.
A standardised approach to carbon reporting is a prerequisite to better understanding the scale of the challenge, informing priorities, enhancing collaboration, and accelerating progress.
The new draft guidance, set out below by Thom Rawson, and posted in parallel on Sustainable Football and LinkedIn, provides desperately needed progress on this front. It has been shared as a starting point, with an open invitation for feedback and suggestions for further development.
How football clubs should report their carbon footprint
By Thom Rawson, Founder, Sustainable Football
In this draft guidance, I’ve set out a standardised approach to football clubs to report their carbon footprint, with a summarised list of recommendations, a proposed reporting template, and a discussion on what different emissions categories mean for football clubs. This is shared with an open invitation for friendly reviewers to contact me if you’d like to provide feedback or be involved in the further development of this guidance.
How are football clubs currently reporting their carbon footprint?
Many football clubs are now reporting their carbon footprint, to meet reporting requirements, be transparent about their carbon impact, and hopefully demonstrate reductions towards achieving net zero.
The Football and Climate Change Newsletter provided a really useful summary of Premier League carbon reporting for the 2021/22 season, which gives a sense of how Premier League clubs currently report their direct carbon emissions. Some clubs, including Wolves, Tottenham Hotspur, Manchester City and Liverpool, voluntarily publish extra information about their indirect or ‘Scope 3’ emissions.
As is the case across many sectors, there is no standardised carbon reporting approach for football clubs. This means that clubs report their carbon footprint in different ways, creating inconsistency, making it difficult to compare and benchmark performance between clubs, and making it difficult to interpret a club’s most significant carbon impacts.
Guidance for a standardised approach for football clubs to report their carbon footprint
In this draft guidance, I’ve set out a standardised approach for football clubs to report their carbon footprint. I’ve defined an overall checklist of recommendations to encourage a consistent approach and explored each of the different emissions categories, in turn, to discuss what they each mean for a football club. I’ve not gone into detail about calculation methodologies at this stage.
The guidance below sets out:
The guidance is probably focused towards Premier League clubs, but I think it should be applicable to football clubs more widely, internationally, and sports teams generally.
I’m sharing this with an open invitation to friendly reviewers to provide constructive feedback, especially those with professional carbon reporting experience and a passion for football, or involvement with football clubs.
It would also be great to hear from anybody who can support in adopting, formalising, publishing or embedding this guidance as best practice.
Please contact me to provide any feedback, and let me know if you are interested in being involved in the future development of this guidance.
Key recommendations
Scope 1
1. Fuel and energy emissions under Scope 1 should be reported by site and by fuel type
Scope 2
2. Electricity emissions under Scope 2 should be reported by site, and as both market- and location-based emissions
Scope 3
3. Scope 3 emissions should be reported in alignment with the 15 categories defined by the GHG protocol scope 3 standard
A. Fan travel, by team, should be reported under Category 9
B. Team travel, by team, and other business-related travel should be separately reported under Category 6
C. Food and merchandise should be reported separately under Category 1
D. Embodied carbon from any new infrastructure, by project, should be reported under Category 2
E. Charitable foundations should be reported under Category 14
F. If a club is the figurehead of a multi-club model, the emissions of each feeder club should be separately reported under Category 14
G. If a club leases its stadium and therefore doesn’t report emissions under scope 1 and 2, stadium emissions, by energy type, should be reported under Category 8
H. Category 3, Category 4, Category 5, Category 7, Category 11, Category 12 and Category 13 should all be reported where possible and relevant
I. Where emissions calculations are not yet available, this should be reported as ‘data currently unavailable’
J. Category 10 and Category 15 are deemed not applicable to football clubs
Proposed reporting template
What does each emissions category mean for football clubs?
Scope 1: Direct emissions
This scope includes the emissions from sources that are directly owned or controlled by a football club, including fuel burn in gas boilers, vehicles and generators.
This would typically be based upon gas consumption used to provide heating and hot water across the club’s sites, other fuel directly purchased by the club including for use in company vehicles, and refrigerants used in air conditioning systems.
Scope 1 emissions should be reported by fuel type, with gas, fuel and refrigerants reported separately. Gas consumption specifically should also be reported by site, separating significant facilities such as the stadium and training ground to allow for comparison between clubs and improved understanding of what is causing the emissions.
Scope 1 description as defined within the GHG Protocol Reporting Standard:
“Direct GHG emissions occur from sources that are owned or controlled by the company, for example, emissions from combustion in owned or controlled boilers, furnaces, vehicles, etc.; emissions from chemical production in owned or controlled process equipment.”
Scope 2: Electricity
This scope includes the emissions from the electricity purchased by a football club.
This would be based upon the club’s electricity consumption across the club’s sites, including lighting, screens, IT equipment, electric vehicle charging and anything else across the club that requires power.
Emission from electricity should be reported as ‘location-based’, which takes into account the carbon intensity of the local electricity grid based on overall mix of how the electricity is generated, and ‘market-based’, which specifically considers the electricity tariff or product that a football club is on. Therefore if a club purchases ‘100% green electricity’, this can be reported as zero carbon under the ‘market-based’ value, but doesn’t change the ‘location-based’ value.
Scope 2 emissions should be reported by site, separating significant facilities such as the stadium and training ground to allow for benchmarking between clubs and improved understanding of what is causing the emissions.
Scope 2 description as defined within the GHG Protocol Reporting Standard:
“Scope 2 accounts for GHG emissions from the generation of purchased electricity consumed by the company. Purchased electricity is defined as electricity that is purchased or otherwise brought into the organizational boundary of the company. Scope 2 emissions physically occur at the facility where electricity is generated.”
Scope 3: Other Indirect Emissions
Scope 3 emissions should be reported in alignment with the 15 categories defined by the GHG protocol scope 3 standard. The 15 categories are:
Category 1: Purchased goods and services
This category includes the emissions from the production of all products that a football club purchases as operational expenditure, including merchandise and food.
Operational expenditure means the money a football club spends on a day-to-day basis as part of the normal running of the club.
Products typically purchased as operational expenses might include football merchandise and equipment, food, office supplies and service fees for cleaning, maintenance and security.
Category 1 description as defined within the GHG Protocol Scope 3 Standard:
“This category includes all upstream (i.e., cradle-to-gate) emissions from the production of products purchased or acquired by the reporting company in the reporting year. Products include both goods (tangible products) and services (intangible products).”
Category 2: Capital goods
This category includes emissions from the production of all products that a football club purchases as capital expenditure, including new facilities and vehicles.
Capital expenditure refers to major, long-term purchases that a football club makes.
Products typically purchased as capital expenses might include buildings, equipment and vehicles, and would also include construction projects, including new stadiums or other facilities.
Uniquely to football clubs, player transfer fees are also accounted for as capital expenditure. Transfer fees should not be included in capital goods emissions calculations due to the nature of the spend.
Category 2 description as defined within the GHG Protocol Scope 3 Standard:
“This category includes all upstream (i.e., cradle-to-gate) emissions from the production of capital goods purchased or acquired by the reporting company in the reporting year. Emissions from the use of capital goods by the reporting company are accounted for in either scope 1 (e.g., for fuel use) or scope 2 (e.g., for electricity use), rather than in scope 3.”
Category 3: Fuel and energy-related activities
This category includes emissions from the extraction, production and transportation of fuel used by a football club, or used to generate electricity used by a club, as well as power losses from transmission and distribution of electricity to the club.
There are no considerations for this category which are specific or unique to a football club.
Category 3 description as defined within the GHG Protocol Scope 3 Standard: “This category includes emissions related to the production of fuels and energy purchased and consumed by the reporting company in the reporting year that are not included in scope 1 or scope 2.”
Category 4: Upstream transportation and distribution
This category includes emissions from the transportation and distribution of products purchased by a football club, in vehicles not owned or controlled by the club, as well as emissions from transportation and distribution services purchased by the club.
For example, this may include where a kit supplier delivers kit to the club, or where a club pays a shipping company either to deliver purchased kit from the supplier to the club, or to transport it from a retail warehouse to a club store, or to deliver sold merchandise to customers.
Category 4 description as defined within the GHG Protocol Scope 3 Standard: “Category 4 includes emissions from:
• Transportation and distribution of products purchased in the reporting year, between a company’s tier 1 suppliers and its own operations in vehicles not owned or operated by the reporting company (including multi-modal shipping where multiple carriers are involved in the delivery of a product, but excluding fuel and energy products)
• Third-party transportation and distribution services purchased by the reporting company in the reporting year (either directly or through an intermediary), including inbound logistics, outbound logistics (e.g., of sold products), and third-party transportation and distribution between a company’s own facilities.”
Category 5: Waste generated in operations
This category includes emissions from the disposal and treatment of the waste that a football club generates.
Football clubs, like many businesses, will pay one or more waste management companies to manage and deal with the waste that they create. Waste created by a club may include plastic bottles, packaging, paper, food, glass and electricals.
Waste can be dealt with in a number of different ways, including recycling, composting, incineration to generate energy, and disposal to landfill. This will depend on the type of waste, the service agreement and local waste management facilities.
Football clubs will also pay a fee to their water company to treat wastewater, which is also included in this category.
Category 5 description as defined within the GHG Protocol Scope 3 Standard: “Category 5 includes emissions from third-party disposal and treatment of waste generated in the reporting company’s owned or controlled operations in the reporting year. This category includes emissions from disposal of both solid waste and wastewater.”
Category 6: Business travel
This category includes emissions from a football club’s team travel and other business-related travel.
Football teams may travel by different modes such as coach, minibus, train, car or plane, depending on distance, schedule and club policy. This reporting should include all home fixtures hosted at the main stadium and any secondary stadia, as well as away matches, including both domestic and international team travel, across men’s, women’s and academy teams. This should include all competitions as well as pre-season.
Team travel emissions should be reported separately to other business-related travel, and should be broken down by team.
Other business-related travel for a football club may include non-playing staff travel to games, as well as business travel to off-site meetings, negotiations, conferences and scouting assignments. This may include expenses for car mileage, fuel, taxis or traveling bookings, and should also include hotel bookings.
Category 6 description as defined within the GHG Protocol Scope 3 Standard:
“This category includes emissions from the transportation of employees for business-related activities in vehicles owned or operated by third parties, such as aircraft, trains, buses, and passenger cars.”
Category 7: Employee commuting
This category includes emissions from a football club’s employees travelling between their homes and their places of work, and working from home.
As well as players and coaching staff, football clubs employ people across a number of different departments including finance, operations, media, HR, hospitality and retail. Travel to and from work, which may be the stadium, training ground, club store or other facility, causes carbon emissions which depend upon the mode of transport and commuting distance.
Working from home emissions should also be accounted for in this category, based on the amount of energy a club employee uses for home working.
Category 7 description as defined within the GHG Protocol Scope 3 Standard:
“This category includes emissions from the transportation of employees between their homes and their worksites. Emissions from employee commuting may arise from automobile travel, bus travel, rail travel, air travel and other modes of transportation (e.g., subway, bicycling, walking). Companies may include emissions from teleworking (i.e., employees working remotely) in this category. A reporting company’s scope 3 emissions from employee commuting include the scope 1 and scope 2 emissions of employees and third-party transportation providers.”
Category 8: Upstream leased assets
This category includes emissions from the operation of any asset that a football club leases, such as a stadium, building or vehicle.
While this may be irrelevant or of low significance to clubs who do not lease their main assets, for other clubs, particularly those that lease their stadium, this category may be highly significant.
If a club does lease a stadium, it may not report stadium energy consumption within scope 1 and scope 2, as would typically be expected.
This is the case for West Ham, who lease the London Stadium and therefore report their scope 1 and 2 carbon footprint as being significantly lower than the Premier League average.
To enable accurate benchmarking and comparison, football clubs who lease their stadium, or other significant asset, should report the operational emissions in this category, broken down by asset and by electricity and fuel type.
Category 8 description as defined within the GHG Protocol Scope 3 Standard: “Category 8 includes emissions from the operation of assets that are leased by the reporting company in the reporting year and not already included in the reporting company’s scope 1 or scope 2 inventories. This category is applicable only to companies that operate leased assets (i.e., lessees). For companies that own and lease assets to others (i.e., lessors), see category 13 (Downstream leased assets).”
Category 9: Downstream transportation and distribution
This category includes emissions from a football club’s fan travel and customer travel to matches and events.
Fan travel is deemed to be included in this category as a result of the GHG protocol guidance which states that “companies may include emissions from customers travelling to and from retail stores.”
Therefore, football clubs should account for fan travel in this section, based on attendance, distance and travel mode.
Fan travel reporting should include all home fixtures hosted at the main stadium and any secondary stadia, as well as away matches and those held at neutral venues, across men’s, women’s and academy teams. For away games, just the away attendance should be accounted for. Fan travel emissions should be broken down by team.
Other fan and customer travel, such as to and from other club-hosted charity matches and events, and customer travel to and from club retail stores, should also be included.
This category also incorporates the transportation and distribution of products sold by the club to customers or retailers, if this service is not paid for by the club.
Category 9 description as defined within the GHG Protocol Scope 3 Standard:
“This category includes emissions that occur in the reporting year from transportation and distribution of sold products in vehicles and facilities not owned or controlled by the reporting company.”
Category 10: Processing of sold products
This category is deemed not applicable to football clubs, since clubs do not produce intermediate products that require further processing, transformation, or inclusion in another product before use by the end consumer.
Category 3 description as defined within the GHG Protocol Scope 3 Standard: “Category 10 includes emissions from processing of sold intermediate products by third parties (e.g., manufacturers) subsequent to sale by the reporting company. Intermediate products are products that require further processing, transformation, or inclusion in another product before use (see box 5.3 of the Scope 3 Standard), and therefore result in emissions from processing subsequent to sale by the reporting company and before use by the end consumer. Emissions from processing should be allocated to the intermediate product.”
Category 11: Use of sold products
This category includes emissions from customer use of products sold by a football club.
This includes ‘direct use-phase emission’, where a product sold by the club directly consumes energy when used. This may include electricals sold from the club shop.
It also includes ‘indirect use-phase emissions’, where a product sold by the club indirectly consumes energy through its lifetime. This might include the customer washing and drying a football shirt or other merchandise purchasedfrom the club.
In both cases, the emissions footprint would be expected to be of very low significance.
Category 11 description as defined within the GHG Protocol Scope 3 Standard:
“This category includes emissions from the use of goods and services sold by the reporting company in the reporting year. A reporting company’s scope 3 emissions from use of sold products include the scope 1 and scope 2 emissions of end users. End users include both consumers and business customers that use final products.”
Category 12: End-of-life treatment of sold products
This category includes emissions from the disposal of products sold by a football club, once they become waste.
Anything sold from the club shop may be considered to have a lifespan and will eventually be disposed of as waste after a period of time. This category therefore includes the recycling, incineration, disposal to landfill or other method of waste treatment for all products sold by the club, that isn’t dealt with by the club’s own waste management company.
Category 12 description as defined within the GHG Protocol Scope 3 Standard: “Category 12 includes emissions from the waste disposal and treatment of products sold by the reporting company (in the reporting year) at the end of their life. This category includes the total expected end-of-life emissions from all products sold in the reporting year. (See section 5.4 of the Scope 3 Standard for more information on the time boundary of scope 3 categories.)”
Category 13: Downstream leased assets
This category includes emissions from the operation of any asset which a football club leases to others.
This may not be applicable to many clubs, but may be relevant if a club leases part of it’s site, stadium or facility to another organisation, and therefore deems the energy used in operation of that building or area as excluded from their direct emissions.
Category 13 description as defined within the GHG Protocol Scope 3 Standard:
“This category includes emissions from the operation of assets that are owned by the reporting company (acting as lessor) and leased to other entities in the reporting year that are not already included in scope 1 or scope 2. This category is applicable to lessors (i.e., companies that receive payments from lessees). Companies that operate leased assets (i.e., lessees) should refer to category 8 (Upstream leased assets).”
Category 14: Franchises
This category includes emissions from the football club’s charitable foundation and from other football clubs linked as part of a multi-club model.
Football clubs do not operate franchises as such, however I’ve proposed here 2 examples of football clubs acting in a way that has similarities to a franchisor.
The first is a club’s charitable foundation, or other charitable organisation closely associated with the club that uses the club’s name and branding, to deliver social and community initiatives. Relevant operational emissions, which aren’t already accounted for elsewhere through the club’s emissions reporting, should be reported in this category.
Secondly, many large clubs operate a ‘multi-club model’, in which they establish close ties to other clubs, usually around the world, in order to derive benefits including obtaining work permits, developing players and increasing brand presence. While it is usually a separate umbrella company that formally links the clubs through shared ownership, where the football club is the figurehead of the multi-club model, the relevant operational emissions from each linked club should be reported in this category, broken down by club.
Category 14 description as defined within the GHG Protocol Scope 3 Standard: “Category 14 includes emissions from the operation of franchises not included in scope 1 or scope 2. A franchise is a business operating under a license to sell or distribute another company’s goods or services within a certain location. This category is applicable to franchisors (i.e., companies that grant licenses to other entities to sell or distribute its goods or services in return for payments, such as royalties for the use of trademarks and other services). Franchisors should account for emissions that occur from the operation of franchises (i.e., the scope 1 and scope 2 emissions of franchisees) in this category.”
Category 15: Investments
This category is deemed not applicable to football clubs, since it is relevant to for-profit investment companies, not-for-profit investment companies and companies that provide financial services.
Category 3 description as defined within the GHG Protocol Scope 3 Standard:
“This category includes scope 3 emissions associated with the reporting company’s investments in the reporting year, not already included in scope 1 or scope 2. This category is applicable to investors (i.e., companies that make an investment with the objective of making a profit) and companies that provide financial services. This category also applies to investors that are not profit driven (e.g. multilateral development banks), and the same calculation methods should be used. Investments are categorized as a downstream scope 3 category because providing capital or financing is a service provided by the reporting company.”
Feedback
This is all draft guidance, shared with an open invitation for friendly reviewers to contact me if you’d like to provide feedback or be involved in the further development of this guidance.
Thom Rawson
Founder, Sustainable Football
 | A guest post by
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This is so interesting! Thank you for your work!
Great article Fran and Thom! One note, not sure where non-travel matchday emissions from fans would be counted. Would food and merchandise sold to fans be covered in category 1 of Scope 3? The wording seems slightly ambiguous.