Subject: Climate Disclosure Rules
From: Harry C. Moser
Affiliation:

Jan. 24, 2024

SEC staff,
I have read that Scope 3 is delaying your rules. I have a solution:
Companies will never get down to tier 5 in Asia and other remote, developing locations Instead of trying and failing to measure exactly, simplify, as follows: Define each or many items by their: i. HS code 
ii. Materials
iii. Primary manufacturing process
iv. Weight
v. Production location
vi. Point of use
vii. Method of transport
From standardized tables estimate the emissions for each country pair to include: i. Making the raw material, e.g. plastic
ii. Processing, e.g. injection molding
iii. Electricity production
iv. Transport: ocean, air, truck, rail
Result: You will have a value which is probably as accurate as achieved by collecting details and less subject to manipulation. Extra benefit: Applying the tables will help companies see the advantage of localization, strengthening U.S. manufacturing. We have developed the needed tables for 9 products and 9 representative countries.
We would be delighted to provide more details.
Best!

Harry C. Moser
Founder and President

Reshoring Initiative® 
Mobile +01 847 867 1144 
email: harry.moser@reshorenow.org
web: http://www.reshorenow.org
blog: http://www.reshorenow.org/blog/ 
Twitter: @reshorenow
Group LinkedIn: Reshoring Discussion Group
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Reshoring Initiative- Bringing manufacturing back home