Does a power trader or discom report the generation of electricity it resells under Scope 3 Category 3?
Yes. Electricity a utility or energy retailer buys and sells on to end users is Scope 3 Category 3, activity D, in the GHG Protocol: report the life cycle emissions of generating it, upstream fuel plus combustion. A generator selling its own output does not, because that combustion is already its Scope 1.
Where each tonne sits along the power chain
The Scope 3 technical guidance follows one coal plant's output through four companies. Its example numbers show why activity D exists: without it, nobody in the middle of the chain would show the emissions of the power they trade.
- Coal miner: the coal it sells is burned by others, so that combustion is its Category 11, use of sold products.
- Generator: the coal it burns is its Scope 1. It reports nothing in Scope 3 for the electricity it sells, because that is already in its Scope 1. Mining and transport of its coal go in its Category 3, activity A.
- Utility that buys the power: electricity it uses itself is its Scope 2. Generation of the power it buys and sells to customers, upstream plus combustion, is its Category 3, activity D.
- End customer: its metered kWh are Scope 2; upstream fuel and the power lost in the grid go in its Category 3, activities B and C.
The calculation
Emissions = kWh bought for resale x a life cycle emission factor, summed across suppliers or regions. Life cycle here means upstream fuel supply plus combustion at the plant, not combustion alone.
Supplier-specific method: use CO2, CH4 and N2O data for the generating units the power came from. Your power purchase agreements and scheduling records already name them. Average-data method: use the grid average factor for where the power came from, when unit data is not available.
Indian points to watch
- The CEA grid factor counts CO2 from combustion per kWh of net generation. On its own it is not a life cycle factor: add an upstream value from a named life cycle database and say so.
- Renewable power bought for resale gets its own generator data, not the coal-heavy grid average. Keep the plant-wise purchase quantities separate.
- The guidance writes activity D for power sold to end users. It does not single out a trading licensee that sells to another discom. Counting all power you buy for resale and stating that choice leaves nothing out.
- The guidance's example gives a utility no Scope 1 unless SF6 escapes from its network equipment. Track SF6 top-ups in switchgear and breakers as Scope 1.
Worked example: a trader resells 200 million kWh bought from the grid mix
- Power bought for resale in FY 2025-26: 200,000,000 kWh, with no generating unit data
- Combustion part: 200,000,000 x 0.675 kg CO2 per kWh (CEA, FY 2025-26) = 135,000,000 kg, or 135,000 t CO2
- Upstream part: 200,000,000 kWh x the upstream factor from your chosen life cycle database, added on top
- Category 3, activity D = 135,000 t plus the upstream part, reported with both sources named
Quantities are an example. The CEA figure is CO2 only; if the upstream factor is in CO2e, say that the total mixes the two.
What Senseible does here
Senseible reads electricity bills and applies the CEA grid factor to the units you consume, as Scope 2. It does not calculate emissions of power you trade; plant-wise purchase volumes for activity D come from your own scheduling records.
- Captive coal power and Category 3
- T&D losses in Category 3
- Discom fuel mix instead of the CEA factor
- Scope 3 supplier evidence
Sources: GHG Protocol, Technical Guidance for Calculating Scope 3 Emissions, Category 3 (tables 3.1 and 3.2, formula 3.4), GHG Protocol, Corporate Value Chain (Scope 3) Standard, CEA, CO2 Baseline Database for the Indian Power Sector
Last reviewed 2026-10-31.