Evaluating Embodied Carbon: How Data Center Vendors Play A Part In Reporting Scope 3 Emissions

As data centers seek greener footprints, understanding and managing Scope 3 emissions is becoming increasingly important. The TM65 calculation methodology, explored in a recent collaboration between Kohler, Schneider Electric, and the iMason’s Climate Accord, proposes a practical approach for quantifying the embodied carbon of data center components. This framework offers a glimpse into the evolving practices that aim to standardize sustainability measures across the industry, promising more accurate assessments and consistent reporting in the pursuit of reduced environmental impacts.

The environmental movement in the data center industry is quickly gaining steam. As a crucial part of a data center’s sustainability efforts, gaining a firm grasp on sustainability-related metrics represents a vital foundation for any serious improvement effort. After all, a data center can’t fully understand its carbon usage until it begins tracking it, and reporting is an integral part of any Environmental, Social, and Governance (ESG) initiative. Nailing down reasonable figures, however, can be difficult.


One of the emerging ways to approach the measurement of greenhouse gas (GHG) emissions in the data center industry is the three-scope framework of the industry-standard GHG Protocol. Within this framework, the trickiest to tackle is Scope 3, known as the Corporate Value Chain Standard. Chiefly, the reason this category is so difficult to measure lies in the fact that it deals with indirect activities within a data center’s operations that are not directly controlled by that data center. Notably, it represents all the carbon tracking associated with goods or services a data center purchases and employs.

Solving Scope 3

Currently, the methodologies for calculating and reporting on Scope 3 emissions are continuously evolving as new research and better practices develop, and data center industry suppliers are still in the midst of a long process of standardizing across products and regions. As part of the iMasons Climate Accord working groups, Kohler’s Louis Liu has been actively involved in the effort to assist data center vendors move closer to this goal, helping to create a set of case studies to demonstrate the different methodologies that can be used to account for carbon footprint of the data center equipment that falls into Scope 3 carbon accounting.

Liu’s latest project as part of the Equipment Working Group is a case study in collaboration with Schneider Electric that explores an important concept in the materials and products that data centers use to accomplish their mission critical uptime: embodied carbon. Set apart from a data center’s carbon emissions or operational carbon, embodied carbon refers to the carbon dioxide emissions associated with materials and construction processes throughout the entire lifecycle of a building or product. These emissions typically arise from the extraction, manufacturing, transportation, installation, maintenance, and disposal of materials and products. Since these activities are usually not owned or directly controlled by the data center using the materials or products, they fall under Scope 3. In the case study, Accounting For Carbon In Data Center Equipment, Liu presents the possibility of using something called the TM65 calculation methodology to estimate the embodied carbon of different data center elements.

The TM65 Method

Released by The Chartered Institution of Building Services Engineers (CIBSE) in 2021, the TM65 Embodied Carbon Calculation Methodology, is tailored for building services engineering, aiming to streamline how manufacturers and stakeholders measure and manage emissions. Whether it’s ultimately useful for the data center industry, though, is the focus of the case study.

Here’s how the methodology works. First, a data center equipment manufacturer submits either an Environmental Product Declaration (EPD) or equivalent. Then the manufacturer submits detailed information including the capacity, service life, total weight, and major materials used in the product, alongside additional information about the manufacturing process. Using the TM65 method, inputs from those submissions are calculated, including the computation of embodied carbon based on material extraction, repairs, and scale-up factors which take into account product complexity. Then, an output is provided in units of kilograms of carbon dioxide equivalents (kgCO2e) per declared unit of the product, such as a backup power generator. This unit accounts for the total amount of greenhouse gases, including carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), and fluorinated gases, emitted over the lifecycle of the product, expressed in terms of the equivalent amount of CO2.

The methodology is designed to be user-friendly, allowing quick calculations and comparability across different manufacturers. However, TM65 has its limitations. For one, the system needs more work to be applicable to different geographic locations. For another, the process lacks granularity in some data reporting, opting for a more simplified representation of information compared to other, more detailed measuring systems. Nevertheless, TM65 represents a beneficial starting point, and the system will continue to be refined to provide a more comprehensive tool for environmental impact assessments.

In essence, TM65 offers a pragmatic approach for calculating embodied carbon, enabling more informed decisions in the production and lifecycle management of operational infrastructure for data centers. Although further advancements are necessary to capture a fuller picture of environmental impacts, a move towards an accurate, standardized measurement system underscores the data center industry's shift towards more sustainable practices.

Charting the Course Ahead

Data centers and their equipment are rapidly evolving, bringing about increased scrutiny on its environmental impacts, particularly in terms of carbon emissions associated with manufacturing and lifecycle impacts of its equipment. Scope 3 emissions often play a large part in total emissions, but they are the most difficult to calculate, as accurately measuring Scope 3 emissions often relies on obtaining specific data from suppliers and other third parties, which can vary in quality and completeness. This lack of uniformity can make it challenging to compare emissions data across companies and equipment effectively.

In an effort to overcome these obstacles, data center suppliers must also be vigilant in improving their ability to provide data centers visibility into their operations and practices in order to paint an accurate picture for Scope 3 reporting. Whether TM65 or something else, data center vendors need to ensure the necessary data collection mechanisms are in place to support their data center clients with sustainability reporting just as they do with their commitment to reliable connectivity.

To read the full case study on embodied carbon and the TM65 method, click here. Or, to read a similar case study on environmental product declarations and lifecycle assessments, click here. To learn more about Kohler’s partnership with the iMasons Climate Accord, click here.

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