# Does the Greenhouse Gas Protocol's Scope 3 technical guidance count the burning of my waste at a waste-to-energy plant inside Category 5?

Canonical: https://senseible.earth/answers/waste-to-energy-combustion-leaves-category-5-guidance

For plants that make energy, the technical guidance says Category 5 should include preparing the waste and, optionally, its transport, but should not include the combustion itself. It says those emissions go in Scope 2 for whoever uses the energy. Waste burnt without energy recovery stays fully in Category 5.

## What the technical guidance says, nearly word for word

The Greenhouse Gas (GHG) Protocol technical guidance for Category 5 says companies "should account for emissions from preparing and transporting waste that will be combusted in a waste-to-energy facility in category 5, but should not account for emissions from the waste-to-energy combustion process itself." It adds that "these emissions should be included in scope 2 by the consumers of energy generated from waste." One wording tension sits in the same guidance: this paragraph says companies "should account for" preparing and transporting the waste, while the category's introduction says companies "may optionally include" transport by a third party. Our reading is that this is a wording tension in the guidance, and that transport stays optional.

The reason it gives is double counting. If a company buys energy from the same facility its waste goes to, counting the combustion both as waste upstream and as energy downstream would count it twice. It adds that in most cases the combustion emissions will be included in the grid average emission factor.

Two limits come with it. Waste incinerated without energy recovery is outside this rule: all emissions from combusting it are reported by the company that generated the waste, in Scope 3 Category 5. And if your own waste is burnt on your site, under your operational or financial control, and the energy is used there, the emissions are your Scope 1. Either way, the guidance says not to report negative or avoided emissions for waste-to-energy inside the inventory.

## How this fits the Scope 3 Standard

The Scope 3 Standard's minimum boundary for Category 5 is the Scope 1 and Scope 2 emissions of the waste company while it treats your waste. Read alone, that would put the burn in your Category 5. The technical guidance is the document that deals with this exact route, so our reading is that for a plant that generates energy from your waste, the technical guidance is the more specific rule. The page on this site about factory waste sent to waste-to-energy follows the same treatment.

Write your method note so a reader can see which treatment you used. If your buyer or verifier asks for the other view, keep the tonnes and the plant's route on file and show the combustion as its own line, so either reading can be worked out from the same records.

## What the guidance does not spell out for India

The guidance defines waste-to-energy as combustion of municipal solid waste (MSW) to generate electricity. It does not say what to do with refuse-derived fuel (RDF) that a cement kiln burns for heat, where there are no electricity consumers to pick up a Scope 2 line. Our reading is that this is a gap in the text, not a ruling. Ask your buyer or verifier which treatment they expect, and record the route you were told.

## What stays in Category 5

- The preparing of the waste for burning, and its transport if you choose to include it (the guidance lists transport by a third party as optional).
- All combustion emissions where the waste is burnt without energy recovery.
- Any landfill, composting or recycling of the rest of your waste, by type and route.
- No deduction for the electricity the plant sells.

## Example: 60 tonnes of packaging waste to a waste-to-energy plant

- Preparing and transporting (transport included by choice), example factor 12 kilograms of carbon dioxide equivalent (CO2e) per tonne: 60 x 12 = 720 kilograms
- Combustion at the plant, example factor 1,100 kilograms CO2e per tonne: 60 x 1,100 = 66,000 kilograms
- Technical guidance treatment: Category 5 holds 720 kilograms; the 66,000 sits with the energy users in their Scope 2
- If a buyer asks for the combustion inside Category 5: 720 + 66,000 = 66,720 kilograms, so the combustion is 66,000 / 66,720, about 98.9 percent of that total

Both factors are example numbers to show the arithmetic, not published factors. Use the plant's figures and your factor source, and say which treatment you used.

## What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. It does not work out waste treatment emissions for you, so keep the tonnes and the plant's route from your contractor's slips and statements yourself.

- [Factory waste sent to waste-to-energy](https://senseible.earth/answers/waste-sent-to-waste-to-energy-scope-3)
- [Waste emissions for Category 5](https://senseible.earth/answers/waste-emissions-scope-3-category-5)
- [Category 5 when you only know the shares](https://senseible.earth/answers/category-5-average-data-share-by-disposal-route)
- [Free calculators](https://senseible.earth/calculators)

Sources: [GHG Protocol Technical Guidance for Calculating Scope 3 Emissions, Category 5 (Waste generated in operations)](https://ghgprotocol.org/sites/default/files/2022-12/Ch5_GHGP_Tech.pdf), [GHG Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard](https://ghgprotocol.org/sites/default/files/standards/Corporate-Value-Chain-Accounting-Reporing-Standard_041613_2.pdf)

Last reviewed 2026-11-06. Quoted from the 2013 technical guidance. The Scope 3 Standard itself only lists waste-to-energy as a Category 5 treatment route. Re-check if the GHG Protocol publishes revised Scope 3 rules.