Dow's Path2Zero and the CSRD Scope 1 Emissions Question: What Procurement Teams Should Consider

Corporate decarbonisation strategies increasingly influence procurement decisions as companies work to reduce greenhouse gas emissions throughout their supply chains. Large chemical manufacturers often publish long-term emissions roadmaps that customers use when assessing supplier performance and estimating Scope 3 emissions. When one of those projects changes significantly, procurement and sustainability teams may need to revisit their assumptions. Dow's decision to delay construction of its flagship Path2Zero project illustrates why supplier decarbonisation plans require ongoing monitoring rather than one-time assessment.

For organisations preparing reporting under the Corporate Sustainability Reporting Directive (CSRD), supplier project delays may affect the assumptions used to estimate future emissions reductions. While a delayed project does not automatically change reported historical emissions, it can influence forward-looking planning, supplier engagement and audit documentation.

What Is Dow's Path2Zero Project?

Path2Zero is Dow's flagship decarbonisation project at its Fort Saskatchewan site in Alberta, Canada. The project is designed to create what Dow describes as the world's first net-zero Scope 1 and Scope 2 emissions integrated ethylene cracker and derivatives facility.

The project combines several technologies, including:

• Low-emissions energy systems.

• Carbon capture infrastructure.

• Modern process design.

• Increased polyethylene production capacity.

• Lower operational carbon intensity.

Dow has stated that the project is intended to decarbonise approximately 20% of its global ethylene capacity while supporting long-term business growth.

Why the Project Timeline Changed

In 2025, Dow announced that construction would be delayed to better align capital spending with market conditions. The company said the decision would reduce planned capital expenditure by approximately $1 billion while maintaining its long-term commitment to the project. More recent company updates indicate revised startup expectations extending into 2029 and 2030.

From a procurement perspective, the delay does not necessarily alter the project's strategic importance. It does, however, change the expected timing of future emissions reductions associated with the facility.

Why This Matters for CSRD Reporting

Under the CSRD, companies are expected to provide transparent and supportable sustainability information, including climate-related disclosures where applicable.

Many organisations estimate parts of their Scope 3 emissions using supplier information, published emissions factors or publicly announced decarbonisation commitments. When a major supplier revises the timing of a significant emissions reduction project, sustainability teams should evaluate whether existing assumptions remain appropriate.

That review is particularly important if supplier-specific emissions projections were incorporated into internal climate models or transition planning.

Procurement Teams Should Review Supplier Assumptions

Supplier sustainability commitments should not be treated as static information.

Procurement and sustainability teams should periodically review:

• Updated supplier sustainability reports.

• Public announcements affecting major projects.

• Revised implementation schedules.

• Changes in emissions targets.

• New regulatory disclosures.

Keeping supplier information current improves the reliability of procurement decisions and sustainability reporting.

Strengthening the CSRD Audit Trail

Good governance under the CSRD extends beyond calculating emissions. Organisations should also document the assumptions used to develop those calculations.

Useful documentation may include:

• The supplier information used when preparing emissions estimates.

• The publication date of supporting sustainability reports.

• Any subsequent supplier announcements affecting emissions trajectories.

• Internal reviews explaining whether assumptions required updating.

• Records showing when revised information was incorporated into reporting processes.

Maintaining this audit trail improves transparency and supports consistency if reporting assumptions are reviewed in future assurance activities.

Building More Resilient Supplier Assessments

Supplier decarbonisation projects often span several years and may be influenced by capital allocation, market conditions and technology development. As a result, procurement professionals should combine long-term sustainability commitments with regular monitoring of project progress rather than relying solely on original announcements.

Best practice includes comparing published climate targets with annual sustainability reports, monitoring significant project updates and maintaining open communication with strategic suppliers regarding implementation timelines. This approach helps procurement teams respond to changing circumstances while maintaining credible sustainability reporting.

What Procurement Teams Should Do Now

Dow's Path2Zero project continues to represent one of the chemical industry's most significant decarbonisation investments, but its revised implementation schedule demonstrates that major climate projects can evolve over time. For organisations relying on supplier climate commitments in CSRD-related analyses, periodic review of published project updates is an important part of maintaining accurate reporting assumptions.

Procurement professionals should regularly validate supplier sustainability information, document significant changes affecting emissions expectations and update internal records where necessary. Combining ongoing supplier engagement with a well-maintained audit trail supports stronger governance and more reliable sustainability reporting as climate disclosure requirements continue to mature.

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