The GHG Protocol defines primary data as data from specific activities within a company’s operations or value chain. Primary data can include site-specific measurements, models or other methods and does not necessarily have to be generated by the reporting company itself.
At Good Earth Cotton®, this translates to farm-specific data, collected annually on a farm-by-farm basis and representative of the activities occurring on that farm, providing evidence of actual farm performance rather than relying solely on regional or industry averages.
Living Soil
Sunlight, air and water become leaf, stem and root, and some of that carbon continues below ground — transferred through living roots and returned as crop residues break down. Underground, carbon moves through a living system of roots, microbes and fungi. Some is returned to the atmosphere, while some can become stabilised within soil organic matter and stored for longer periods.
What these builds are not abstract. Soil organic carbon contributes to soil structure, water-holding capacity and nutrient cycling functions that support productive, resilient soils.
Deconstructing the Landscape
There is currently no single regulated EU definition of regenerative agriculture. As environmental claims face greater scrutiny under the EU’s Empowering Consumers Directive, being able to demonstrate what sits behind terms such as regenerative is becoming increasingly important.
In 2025, the European Economic and Social Committee (EESC) called for a common EU understanding of regenerative agriculture and proposed an approach that is adaptive, science-based and outcome-focused.
Importantly, the EESC says regenerative agriculture should not be defined by a prescribed list of farming practices. Instead, it should be driven by results and outcomes that can be defined, measured and verified, taking account of the specific context of the land. It also proposes that regenerative performance should demonstrate improvement over time across environmental, economic and social outcomes.
For Good Earth Cotton®, this distinction matters. Farming practices are determined by the conditions of each farm, but environmental performance is demonstrated through measured outcomes rather than assumed from the adoption of a practice.
Practices describe what we do. Outcomes show what changed.
Downforce Technologies is a leader in delivering actionable soil health data that is locally relevant, globally scalable and supported by historical perspective. The Downforce platform combines ground-based data, including historic soil samples, with satellite observations, machine learning and statistical analysis to measure Soil Organic Carbon (SOC).
The platform provides nine years of continuous records, at 10m × 10m resolution, with observations every 10 days — creating a high-resolution picture of how soil carbon varies across the landscape and changes over time.
The Downforce methodology for measuring and reporting carbon removals aligns with global standards and frameworks including:
- GHG Protocol Land Sector and Removals Standard (LSRS)
- Science Based Targets initiative Forest, Land and Agriculture (SBTi FLAG)
- ISO 14064-1 and ISO 14064-2
Downforce is a founding member of the International Soil Carbon Industry Alliance (ISCIA) and an active contributor to industry initiatives advancing credible approaches to the measurement and reporting of carbon removals.
For Good Earth Cotton®, Downforce quantifies annual greenhouse gas emissions at the organisational level under ISO 14064-1 and separately quantifies verified soil carbon removals at the project level under ISO 14064-2. Every Good Earth Cotton® removal figure is independently verified.
Emissions and removals are reported as distinct figures rather than combined into a single net result and are presented using a three-year centred moving average, reflecting the impact of farming practices over time.
A credible environmental claim should not rely solely on the party making it to substantiate it. Under the EU’s Empowering Consumers Directive, sustainability labels must be established by a public authority or underpinned by a qualifying certification scheme with independent third-party monitoring. Independent verification provides confidence that the evidence behind a claim can withstand scrutiny.
Where the data comes from matters just as much as who checks it. Carbon figures can be derived from regional or national averages applied to a known country of origin. That may be appropriate for some forms of greenhouse gas accounting, but it is not the same as measuring what happened on a particular farm.
Ours is primary data: our fuel, our fertiliser, our chemistry, our energy, our yields and the carbon measured in our own soil. It describes this farm and no other.
That farm data is then independently verified by SGS. The verification assesses conformance with the Downforce Technologies methodology for soil organic carbon and the ISO 14064 family of standards for greenhouse gas quantification and verification. SGS examines the methodology, underlying input and production data and completed assessment, cross-checking and reconciling the evidence before reaching its verification opinion.
ISO 14064-1:2018 — organisation-level greenhouse gas inventories. How emissions and removals across the operation are quantified and reported.
ISO 14064-2:2019 — project-level quantification and monitoring. How soil carbon removals are quantified, monitored and reported over time.
ISO 14064-3:2019 — validation and verification of greenhouse gas statements. How those GHG statements are independently examined and verified.
Together they address three things a claim has to survive: the accounting, the measurement and the audit.
For Good Earth Cotton®, SGS concludes to reasonable assurance that the reported CO₂e assertion is materially correct and fairly represents the underlying CO₂e data and information.
What reaches a brand is therefore not simply a statement of belief. It is an assessed, documented and independently verified position, supported by evidence that can be produced when someone asks to see the working.
The GHG Protocol Land Sector and Removals (LSR) Standard takes effect from 1 January 2027. For companies accounting under the GHG Protocol with land-related emissions and removals in their value chains, the LSR Standard establishes how these impacts are quantified, accounted for and reported within Scope 3.
For companies setting SBTi targets, a separate FLAG target is required where FLAG-related emissions represent 20% or more of total Scope 1, 2 and 3 emissions, unless the company is already within a designated FLAG sector.
For fashion brands sourcing cotton and other land-derived natural fibres, this increases the importance of knowing what happened on the land, where the fibre came from and maintaining the connection between the two.
As climate and sustainability information moves closer to financial reporting, the evidence supporting environmental claims will increasingly need to withstand expectations of accuracy, assurance and auditability. Where emissions and removals influence reported performance, procurement decisions, access to finance or other financial outcomes, the ability to substantiate those figures becomes increasingly important.
Farm-level primary data provides greater specificity than regional and sector averages. Independent verification provides confidence in that data. Physical fibre verification provides an additional evidence layer by preserving a verifiable connection between the fibre and the land-specific impact data associated with its origin.
The shift is from sustainability claims towards financial-grade evidence.
Primary data provides the evidence.
Verification of data provides the confidence.
Physical fibre verification preserves the connection.
Global climate accounting is increasing the importance of primary data for businesses with emissions associated with land-based activities.
IFRS S2 Climate-related Disclosures prioritises data from specific activities within a company’s value chain when measuring Scope 3 greenhouse gas emissions because it provides a more accurate representation of those activities and a better basis for measurement. For agricultural supply chains, farm-specific data can therefore provide greater specificity than generic industry or regional averages.
The GHG Protocol Land Sector and Removals (LSR) Standard takes this further. Effective from 1 January 2027, it establishes requirements for companies to quantify, report and track land-sector emissions and CO₂ removals. The level of spatial specificity a company can report is connected to the data and traceability available for the physical product.
This changes the value of primary farm data.
For Good Earth Cotton®, that evidence begins with actual farm-level inputs, energy, fuel, production and measured soil carbon collected annually, farm by farm, and independently verified.
When connected to physical fibre identity, that evidence can preserve the connection between what happened on the land and what a company reports through its value chain.
Primary data provides the evidence.
Verification of data provides the confidence.
Physical fibre verification preserves the connection.
The Greenhouse Gas (GHG) Protocol provides the world’s most widely used framework for greenhouse gas accounting and reporting. Developed by the World Resources Institute (WRI) and the World Business Council for Sustainable Development (WBCSD), its standards provide globally recognised frameworks for measuring and reporting greenhouse gas emissions across company operations and value chains.
The Land Sector and Removals (LSR) Standard, effective from 1 January 2027, extends GHG Protocol accounting to land-sector emissions and CO₂ removals. It establishes requirements for companies to quantify, report and track emissions from agricultural land management and land-use change and, where the required safeguards are met, CO₂ removals stored in land carbon pools.
Importantly, accounting for a removal requires a physical connection to the land where that removal occurred.For Scope 3 land-management removals, the LSR Standard requires physical traceability to the relevant sourcing region, land management unit or harvested area. The level of spatial specificity at which emissions and removals can be accounted for is therefore connected to the level of physical traceability available.
For agricultural fibres such as cotton, this means farm-specific removal data cannot simply be separated from the physical product and attributed elsewhere in the value chain if that removal is to be included in the physical GHG inventory. The chain of custody must preserve the required physical traceability between the cotton being sourced and the land boundary associated with the removal.
The LSR Standard therefore brings the land, the data and the physical product together: the removal is measured where it occurred, and physical traceability preserves that connection as the agricultural product moves through the value chain.
SBTi FLAG (Forest, Land and Agriculture) provides the framework for companies to set science-based climate targets for emissions and removals associated with land-based activities, including agriculture, forestry and the production of natural fibres derived from the land, such as cotton.
FLAG targets are required for companies in designated land-intensive sectors. Companies in other SBTi-designated sectors are also required to set FLAG targets where FLAG-related emissions represent 20% or more of their total Scope 1, 2 and 3 emissions.
For fashion and textile companies, sourcing cotton does not automatically mean a FLAG target is required. What matters is the significance of FLAG-related emissions within the company’s overall emissions footprint. For businesses sourcing substantial volumes of cotton and other land-derived natural fibres, those emissions contribute to Scope 3 and, where the 20% threshold is reached, trigger the requirement for a separate FLAG target.
The SBTi FLAG Guidance and GHG Protocol Land Sector and Removals (LSR) Standard work together. The LSR Standard establishes how companies account for and report land-based emissions and removals; FLAG establishes how those emissions and removals are translated into science-based targets. From 1 January 2027, companies setting FLAG targets are required to use the final LSR Standard for their greenhouse gas accounting.
For companies whose value chains depend significantly on cotton and other land-derived natural fibres, understanding the emissions associated with producing those materials becomes increasingly important and so does access to credible, farm-level primary data.
LSR Standard = how you account for the emissions and removals.
SBTi FLAG = the target you set using that accounting.
Soil carbon sequestration is the process of removing carbon dioxide from the atmosphere and storing that carbon in the soil as organic carbon. Increasing soil organic carbon can contribute to climate mitigation while supporting important soil functions.
In cotton systems, practices such as reduced tillage, cover crops, diversified rotations and residue retention can increase the amount of carbon entering the soil. Whether soil carbon stocks increase, and how much carbon remains stored over time, depends on the soil, climate, farming system and conditions in which those practices are applied.
Which leads to the question that really matters.
Every one of those practices can be a sensible thing to do. Not one of them, on its own, is a measurement of outcome. A farm can adopt a range of recognised practices and still lose soil carbon. Another can adopt different practices and increase it. The outcome cannot be determined from a practice checklist or assumed from a regional average.
The question is not simply what a farm did. It is what its soil did.
Soil carbon stocks can increase, decrease or remain relatively stable over time. Understanding that change requires measurement against an established baseline and monitoring over time not an assumption based on the practices adopted. This is consistent with the LSR Standard’s approach to carbon-stock change and ongoing monitoring of stored carbon.
At Good Earth Cotton, our aim is to make the invisible, visible.