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Climate Action Frameworks Compared

Joel Kornberg
February 28, 2025
TCL incorporates many best practices that are expected within CSRD, CTAPs, and ISO Net Zero, particularly with regards to GHG measurement, setting near-term emissions reduction actions, investing in the net-zero transition, and performing public disclosure.
TCL incorporates many best practices that are expected within CSRD, CTAPs, and ISO Net Zero, particularly with regards to GHG measurement, setting near-term emissions reduction actions, investing in the net-zero transition, and performing public disclosure.

This guest blog post was authored by volunteer Joel Kornberg.

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Given the many different climate emissions disclosures, regulations, and standards that companies report to today, is the effort spent certifying with The Climate Label time well spent?

Whether you are thinking about your first certification cycle with the Climate Label or you have certified before, it can be daunting to consider what is the best use of your time. How will your certification activities fit into the ever changing landscape of climate regulations and standards? And most importantly, will your activities help make a difference with your organization's pursuit of a cleaner future?

As a volunteer for The Change Climate Project, I took a look at an array of different frameworks, including The Climate Label (TCL), the Corporate Sustainability Reporting Directive (CSRD), Climate Transition Action Plans (CTAPs), and the ISO Net Zero Guidelines, International Workshop Agreement (IWA 42:2022), to identify points of overlap and help people understand how they do (and don’t) address the same aspects of a company’s climate initiatives.

Here’s what I found in the research

Companies may or may not be required or expected to report under these frameworks, or others. Much depends on where you do business and what priorities you have set. Rather than being an apples-to-apples comparison, this exercise was meant to highlight how The Climate Label certification overlaps with these other frameworks. 

Let’s first summarize a few key differences. At a high level:

  • CSRD was established as a sustainability reporting standard for the European Union to enhance corporate transparency across a wide range of environmental, social, and governance topics. It has a much broader mandate than The Climate Label with more generalized guidance. In regards to emissions, for example, CSRD provides guidance that companies need to disclose their material emissions and any action plans they have in place. Meanwhile, TCL has defined the specific emissions requirements and action plans necessary for certification. Overall, it is anticipated that work performed for TCL certification can be leveraged as companies develop their CSRD reports, but there will be significant gaps in what is needed to be included for CSRD, especially across the breadth of required ESG disclosures.
  • Comparing TCL to Climate Transition Action Plans (CTAPs), it is important to remember that TCL is a certification program, while CTAPs were developed as best practice guidance aimed at companies developing forward-looking, near-term net-zero targets. CTAPs do not address specific implementation details, leaving that up to each company to develop, whereas the TCL, being a certification standard, specifies the how and what that needs to be done. For example, CTAPs assume emissions measurement is being done but does not spend much time on this in its standards, and similarly CTAPs do not fully address how to report or disclose company’s measurement programs, rather guiding that transparency and reporting should be done.
  • Lastly the ISO Net Zero Guidelines are structured as guiding principles covering a very expansive set of emissions criteria and considerations, with guideposts referencing other ISO standards, UN reports, and IPCC guidance. As part of its focus on setting targets to achieve net zero, the guidelines also emphasize the importance of performing a just transition and considering the wider impact on nature, including biodiversity, to reach NetZero. These broader requirements are not fully required in TCL. In addition, similarly to CTAPs, ISO Net Zero does not focus on implementation details, leaving that up to or organizing bodies, such as BSI, to develop.

With some high level differences now identified, let’s highlight a few key details that should also be considered:

Emission Measurement: 

Comparing The Climate Label to CSRD, CTAPs, and ISO Net Zero, all four emphasize the importance of measuring emissions for Scope 1, 2, and 3 activities. However, each differs in approach and requirements.

  • The Climate Label provides an option for companies on their climate journey, specifying in its Standard the specific scope 3 activities that must be measured.
  • ISO Net Zero and CSRD require all “material” or “relevant” scope 3 activities to be measured, leaving the details on what is relevant up to each organization
  • CTAPs assume as best practice that a company has measured their emissions, including their value chain as a pre-requisite to its focus on action plans. It does not directly address the scope of measurement.

As one point to consider, if a company completes TCL certification, it is possible that other Scope 3 activities will need to be measured for CSRD. Conversely, a company that has reported for CSRD, may still need to measure a scope 3 activity required as part of TCL.

Target Setting: 

When it comes to setting near term targets:

  • The Climate Label requires every company to develop two new near term action plans each year, with a minimum of 1 focused on addressing value chain emissions. Each action is meant to be measurable and achievable within a 12-24 month period.
  • The CSRD is more general in its guidance, encouraging companies to develop a strategy for transitioning to a sustainable business model and requiring companies to report their emissions and disclose any emissions reduction targets that have been set. Action plans defined as part of TCL or with ISO Net Zero / CTAPs as guidance, should improve the quality of a company’s CSRD report.
  • ISO Net Zero provides strong guidelines for what to include when setting targets, prioritizing emissions reductions within an organization value chain, but also emphasizing the broader environmental protection and safeguards of human needs (climate justice) when defining targets.  
  • With CTAPs focus on forward-looking specific action plans, it provides guidance that emphasizes near-term action plans that include value chain emissions reductions and policy advocacy, achieved while contributing towards a just transition.

Mitigation: 

When it comes to climate change mitigation, a few differences are apparent:   

  • The Climate Label requires a Climate Transition Budget (CTB) be defined and invested across a range of value chain abatement, beyond the value chain mitigations, such as with the voluntary carbon credit market, while also allowing for other investments that are critical to the company's Net Zero transition. TCL is the only model that requires a minimum investment based on a company’s emissions.
  • ISO Net Zero is more stringent in its guidance on mitigation efforts. The primary focus is on action plans that will drive companies to Net Zero through their Scope 1, 2, and 3 emissions. In ISO Netzero it is stated that an “organization should not use offsets towards achievement of interim targets.” Investments in the carbon market can only be used for residual emissions, i.e. the final ~5% of emissions.
  • CTAPs encourage investment decisions to be made as part of a company’s emissions reduction strategy but are primarily focused, similar to ISO Net Zero, on action plans that will drive a company’s emissions to net-zero. While focusing on emissions reductions across the value chain and through policy advocacy, CTAPs do acknowledge that for hard to abate sectors, if carbon credits are being used, they should be disclosed as part of their action plans, alongside their primary actions.
  • CSRD’s focus on carbon credits or beyond the value chain investments is centered around disclosure, requiring purchases of carbon credits to be reported.

What's not covered by The Climate Label? 

Since The Climate Label is focused exclusively on measuring and managing emissions, it does not require companies to measure or report on broader ESG activities, including environmental elements beyond emissions, including pollution, water and marine resources, biodiversity and ecosystems, nor does it address the circular economy. The boundaries of TCL concentrate on the cradle to customer cycle. The Climate Label also excludes directing companies to develop a governance structure, which is critical for larger companies, but may not be practical for many certifying companies. All of these components are valuable additions to a corporate sustainability program, and can be considered where appropriate to the streamlined approach of the Climate Label certification.

In closing, The Climate Label is a practical and accessible option where companies go through a rigorous certification effort to show their customers and the broader market that they are serious about making a difference. TCL incorporates many best practices that are expected within CSRD, CTAPs, and ISO Net Zero, particularly with regards to GHG measurement, setting near-term emissions reduction actions, investing in the net-zero transition, and performing public disclosure. As companies continue on their transition to net zero, The Change Climate Project encourages companies to go beyond the TCL certification requirements, whether through a broader focus on climate justice or as many TCL companies have shown, with an increased focus on climate advocacy. Additional environmental efforts can be added on, including an increased focus on circularity, a broader governance structure within organizations, and action plans on other critical environmental factors. However, as a meaningful program that can move your organization towards net-zero, The Climate Label is a valuable effort.

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About the Author

Joel Kornberg
Volunteer

Joel works with the TCCP team as a frequent volunteer - providing invaluable support on a wide range of projects, from GHG accounting to research. He has a background in operations and procurement at large tech firms, and lives in California.

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