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 Harry’s LinkedIn: https://www.linkedin.com/in/harry-moser-58a8024/ Facebook: https://www.facebook.com/ReshoreNow/ Reshoring Initiative- Bringing manufacturing back home