Most carbon requests reaching pharma companies today come from customers and health systems, not from law. They are voluntary in the legal sense, and in NHS England tenders they are already a pass or fail condition.
Three standards sit under almost every request: the GHG Protocol for the company, ISO 14067 with PAS 2090 for a medicine, and ISO 14064-3 or ISAE 3410 for the assurance check.
Nine large pharma and biomanufacturing companies, through the Sustainable Markets Initiative (SMI), have asked suppliers to disclose Scope 1, 2 and 3 now, publicly set third-party validated science-based targets by 2027, and disclose footprints for their top 10 products by 2028.
NHS England already asks suppliers for a Carbon Reduction Plan. For new procurements from 1 April 2027 worth £5m or more a year, the plan must cover global Scope 1, 2 and all relevant Scope 3 emissions, with a commitment to net zero by 2050 or earlier.
What applies to you depends on who your customers are: a contract manufacturer supplying SMI members faces different requests from a generics company selling to the NHS.
If you work in a pharmaceutical company and a customer, a hospital buyer or an investor has asked for "your carbon numbers", you need to know two things: what that buyer is asking for, and which standard tells you how to count. The table below matches both to your place in the pharma value chain. The sections after it explain the customer and health system requests spreading across the industry, then the three standards that govern the count: one for the company, one for the product, one for the assurance check.
| Your position | What buyers ask for now | What buyers have said they will ask for by 2028 | Count with |
|---|---|---|---|
| Originator with its own plants | CDP and investor questionnaires; an assured company inventory where a disclosure law applies; if you are an SMI member, the SMI targets passed to your own suppliers | Product footprints for priority medicines, if NHS England confirms its planned requirements | GHG Protocol for the company; PAS 2090 for the product; ISO 14064-3 or ISAE 3410 for assurance |
| Generics, over-the-counter or consumer health company using contract manufacturers | NHS England Carbon Reduction Plans, widened from April 2027 to global Scope 1, 2 and 3 for new procurements of £5m or more a year; CDP and EcoVadis requests from wholesale and retail customers | Product footprints for priority medicines, if NHS England confirms its planned requirements | GHG Protocol, with Scope 3 Category 1 (purchased goods) at the centre; PAS 2090 for the product |
| Clinical research organisation (CRO) or pharma services company | Supplier questionnaires (EcoVadis, CDP) from pharma customers; investor questionnaires; if an SMI member is your customer, Scope 1, 2 and 3 disclosure and use of the SMI's clinical trial carbon calculator | Third-party validated science-based targets (2027), if an SMI member is your customer | GHG Protocol Scope 1 and 2, plus business travel, purchased services and logistics |
| Wholesaler or distributor | NHS England Carbon Reduction Plans (widened to global Scope 1, 2 and 3 from April 2027); an assured inventory where a disclosure law applies | Investor and lender questions on targets; if you set a science-based target, the SBTi's V2.0 rules for new submissions after January 2028 | GHG Protocol, with purchased goods (Category 1) and transport (Categories 4 and 9) dominating |
| Contract manufacturer (CDMO) or active ingredient (API) supplier | PSCI Principles through customer supplier codes and audits; the SMI targets, which members ask you to build into contracts with your own suppliers; site data through supplier programmes such as Secaro's Activate or EcoVadis | Validated science-based targets (2027); primary data on your processes, compatible with PAS 2090 clause 5.1.1, so your customers can build their product footprints (2028) | GHG Protocol for your sites; PAS 2090 clause 5.1.1 for the data you supply; PACT or TfS formats to share it |
The pattern across the table: customer requests now reach every position, but which ones reach you depends on who you sell to. All of them build on the same three standards. The rest of this page takes those two things in turn.
Three trends are turning carbon accounting from a voluntary report into a condition of winning business in pharma. None of them is a law. The examples come from the largest buyers; the direction of travel reaches suppliers far beyond them.
Trend 1: big pharma is asking suppliers to meet shared minimum targets. On 21 November 2025 the chief procurement officers of nine companies (AstraZeneca, Chiesi, GSK, Novartis, Novo Nordisk, Roche, Samsung Biologics, Sanofi and UCB), acting through the SMI Health Systems Task Force, wrote to their suppliers asking them to align with one set of joint minimum targets, updating targets their chief executives first issued in 2023. Disclose Scope 1, 2 and 3 emissions now. Publicly set third-party validated near- and long-term science-based targets by 2027. Disclose product carbon footprints or LCAs for your top 10 products by emissions by 2028, with medicines following PAS 2090; contract manufacturers and materials suppliers are asked for primary data compatible with standards such as PAS 2090 clause 5.1.1, so their customers can build those footprints. By 2030, source at least 80 percent renewable electricity and cut process-heat emissions by at least 20 percent against your base year. The letter also sets targets on resource efficiency, nature and water. Then build the same targets into contracts with your own suppliers. Suppliers can report progress through CDP, their ESG report, the SBTi dashboard or directly. The letter is an expectation, not a contract, but the last clause is what turns nine company policies into an industry trend: each tier is asked to pass the same targets to the tier below.
Trend 2: health systems are adding carbon to procurement. NHS England is the clearest case. It has asked suppliers on contracts worth £5m or more a year for a Carbon Reduction Plan since April 2023, and for a proportionate plan or net zero commitment on all new procurements since April 2024. For new procurements from 1 April 2027 worth £5m or more a year, and for new frameworks where relevant, the plan must cover global Scope 1, 2 and all relevant Scope 3 emissions, with a commitment to reach net zero by 2050 or earlier. NHS England encourages, but does not require, independent validation of that target. In medicines, these rules bite mainly where the NHS runs competitive tenders, such as generics and biosimilars frameworks. Since January 2024 it has also used its Evergreen supplier assessment on a pass or fail basis in medicines tenders. From April 2028, its roadmap says it will introduce product-level carbon footprinting requirements; a market survey in June 2026 set out proposals for a gradual rollout from priority products, and NHS England has said these are not yet agreed policy. Other buyers are moving the same way. Norway's hospital procurement agency, Sykehusinnkjøp, is piloting PAS 2090 in its tenders. In France, public procurements launched from August 2026 must include at least one environmental award criterion, with limited exceptions, and the health ministry encourages hospital buyers to use a medicine carbon score built on a separate French method.
Trend 3: supplier programmes and ratings are standardising what a supplier shows. The Pharmaceutical Supply Chain Initiative (PSCI) Principles v3.0 (2023) say suppliers shall monitor and reduce their greenhouse gas emissions and support their own suppliers to do the same; they reach you through customer supplier codes and shared audits. CDP is one of the disclosure channels SMI members accept, with a shorter questionnaire for smaller companies. EcoVadis scorecards are widely used by pharma buyers: Teva, for example, aims to have 95 percent of its in-scope supplier spend assessed by 2030. Secaro's Activate programme, backed by several large pharma companies, helps active ingredient suppliers measure and cut their site emissions. For product footprints, the Partnership for Carbon Transparency (PACT) data format and the Together for Sustainability (TfS) guideline for chemicals are becoming the formats buyers ask for.
What the target requests rest on. The Science Based Targets initiative (SBTi) is a voluntary standard-setter, not a regulator. Its Corporate Net-Zero Standard V2.0, released in June 2026, replaces version 1.3. Companies can still submit targets under version 1.3 until 31 January 2028; after that, the SBTi assesses new submissions against V2.0. For larger companies (the SBTi's Category A), a Scope 3 target must cover every Scope 3 category that makes up 5 percent or more of emissions across categories 1 to 14, replacing the old rule of covering 67 percent of Scope 3. V2.0 also asks Category A companies for limited assurance of their base year. The SBTi is not the only route: the SMI toolkit accepts other target pathways, as long as a third party validates them.
Almost every request above asks for one of three things: a number for the company, a number for a product, or an independent check of either. One family of standards governs each.
The company: GHG Protocol. The Greenhouse Gas Protocol Corporate Standard (2004) and Scope 3 Standard (2011) define the three scopes. Scope 1 is the fuel you burn and the gases you release on your own sites, including refrigerant leaks and, for inhaler makers, propellant losses in manufacturing. Scope 2 is the energy you buy. Scope 3 is everything else in your value chain, from the ingredients you purchase to the propellant a patient releases when using an inhaler and the way a pack is disposed of. Most customer requests, rating schemes and disclosure laws build on it, and ISO 14064-1 sets out the same inventory in ISO form.
For pharma, Scope 3 is usually most of the story. In one global originator's request for proposal that we answered in 2025, Scope 3 was 90 percent of total emissions, and purchased goods and services (Category 1) was 63 percent of Scope 3. iNova Pharmaceuticals, which supplies more than 75 markets through third-party manufacturers, found Scope 3 at 99 percent of its footprint.
The GHG Protocol is revising both standards, and everything it has published so far is a draft. Its Scope 3 progress update (March 2026) proposes that companies report at least 95 percent of their required Scope 3 emissions, show which figures rest on supplier data and which on spend estimates, and add an optional category for other value chain activities, including licensing. That last proposal matters for pharma companies that license products out. The GHG Protocol plans a public consultation in 2027 and, with ISO, a joint standard in late 2028 that would bring ISO 14064-1 and the GHG Protocol together.
The product: ISO 14067 and PAS 2090. A product carbon footprint counts the greenhouse gases emitted to make, move, use and dispose of one unit of a product. ISO 14040 and 14044 set the general life cycle assessment method; ISO 14067 applies it to carbon. PAS 2090:2025, published by BSI on 30 November 2025 with support from NHS England, the UK Office for Life Sciences and the Pharmaceutical LCA Consortium, adds the choices the ISO standards leave open for medicines: what one unit of product is, where the boundary sits, how to split a factory's energy across products, how to handle the cold chain and patient use. It is free to download and voluntary. No law requires it; the SMI targets point medicine makers to it, and NHS England plans product footprinting requirements from 2028 with the method still to be agreed. Our explainer, What is PAS 2090?, covers it in detail. To share a footprint with a customer, the PACT Methodology V3 and data format, and the TfS guideline for chemicals and active ingredients, are the formats buyers now specify.
The audit: ISO 14064-3 and ISAE 3410. When a buyer, an investor or a law asks for assurance, the assurance provider works to ISO 14064-3:2019 or ISAE 3410; ISSA 5000, the new international sustainability assurance standard, applies to periods starting on or after 15 December 2026, and Australia uses its local equivalents, ASSA 5000 and ASSA 5010, for AASB S2 assurance. Limited assurance means the provider found nothing to suggest the number is materially misstated. Reasonable assurance means the provider has gathered enough evidence to state that the number is fairly stated and free from material misstatement. The SMI targets ask for science-based targets validated by a third party and do not mention verification of product footprints. NHS England's 2027 plan asks for a net zero commitment and recommends, but does not require, independent validation. Where disclosure laws require assurance, most start at limited assurance.
Nearly every request above starts from the same place: one set of emissions numbers that will stand up to an assurance provider. Terrascope is a platform with experts built in, and its customers build that inventory with Terrascope's sustainability team alongside them. Dyno Nobel completed its first external global greenhouse gas audit, limited assurance over Scope 1 and 2, a year ahead of its Australian reporting deadline. iNova Pharmaceuticals, which manages more than 1,100 SKUs made by third-party manufacturers, moved from spend-based estimates to its first complete, audit-ready baseline.
If a customer letter or a hospital tender has landed on your desk, book a demo with a Terrascope sustainability specialist. You will leave with a list of the requests that apply to your company and what your first inventory needs.
Climate disclosure rules. Larger pharma companies may also face climate reporting rules that build on the same GHG Protocol inventory: AASB S2 in Australia (Group 2 from financial years starting 1 July 2026, Group 3 from 1 July 2027), the EU's CSRD (after the Omnibus changes, companies with more than 1,000 employees and €450m turnover, with the next wave reporting on FY2027), California's SB 253 (companies with more than US$1bn revenue; first Scope 1 and 2 reports due 10 November 2026), the UK Sustainability Reporting Standards, which the FCA applies to listed companies on a comply-or-explain basis from 2027, and Singapore's climate reporting rules for listed companies.
Sources: SMI Health Systems Task Force CPO letter (21 Nov 2025) and supplier targets toolkit (2026); NHS England 2027 Carbon Reduction Plan requirements and Net Zero Supplier Roadmap; BSI PAS 2090:2025; Pharmaceutical LCA Consortium; PSCI Principles v3.0; SBTi Corporate Net-Zero Standard V2.0; GHG Protocol Scope 3 progress update (March 2026); ISO 14064-3, ISO 14067; Teva supplier decarbonisation deck (Aug 2026); Secaro Activate; Projet Celsius. Accessed October 2026.