Cows, Fridges, and Wastewater: Preparing for the New GHG Reporting Landscape

After nine years since establishing the foundations of greenhouse gas (GHG) reporting in South Africa, the regulatory landscape is changing. Last week, the Department of Forestry, Fisheries and the Environment (DFFE) hosted stakeholder meetings to share proposed amendments to the National Greenhouse Gas Emission Reporting Regulations (NGERs).

These updates are designed to align current reporting with the Climate Change Act of 2024. The goal is to create a more transparent, accurate, and comprehensive national inventory that meets international commitments.

For your business, this likely means GHG reporting on more production processes that were previously below the radar, and stricter methodologies. Here is a summary of what is changing across the four main IPCC sectors:

1. Energy: Closing the Gaps

The DFFE is tightening the rules for fuel combustion and energy use to ensure no significant emissions are missed.

• Threshold Clarity: It will be re-emphasised that the 10 MWth threshold applies cumulatively across all activities and IPCC codes within a company. If your combined capacity exceeds 10 MWth, even across multiple IPCC codes, all activities must be registered.
• Scope 2 Inclusion: A new activity code will be added to collect data on purchased electricity consumption, as well as steam, heat, and cooling purchased from third parties. In the past, only Scope 1 emissions were reported, therefore this represents a significant change.
• Higher Tier Reporting: Tier 2 (South Africa-specific) emission factors are now available for the most common fuels. Consequently, Tier 1 methodologies, using default global IPCC emission factors will no longer be permitted for fuel combustion activities. Importantly, new regulations will mandate that once you move to Tier 3 reporting (site-specific), you cannot revert back to Tier 2 in future years. Currently, there is no regulation preventing data providers from switching between tiers to minimise GHG emissions and carbon tax liability.
• Mandatory Documentation: Monthly fuel breakdowns and production data will become a mandatory part of your GHG submissions.
• Other Transportation (Pipeline Transport): This covers combustion emissions from the operation of pump stations and the maintenance of pipelines used to transport liquids or gases. The DFFE noted these emissions were previously reported under incorrect codes; a dedicated code (1A3e) will be introduced to ensure accurate capture.

2. IPPU: Fridges and Rare Earths

Industrial Processes and Product Use (IPPU) reporting is being refined to include specific high-impact gases and new industries.

• Process Emissions: Tier 3 reporting will become mandatory for industrial processes unless a specific Tier 2 factor has been developed by a sector or data provider and approved by the DFFE.
• Non-Energy Fuel Use: This refers to fossil fuels (e.g., lubricants, solvents, paraffin waxes, and bitumen) used for purposes other than energy combustion, chemical feedstocks, or reducing agents. While these products are not “burned” for fuel, a portion of their carbon is oxidised and released as CO₂ during normal use. The DFFE is introducing reporting for these activities (under IPCC code 2D) to ensure the national inventory captures these previously untracked emission sources.
• HFCs & Refrigeration: Mandatory reporting is being introduced for hydrofluorocarbons (HFCs), specifically refrigeration and stationary air conditioning (2F1A); and mobile air conditioning (2F1B). While the current proposal contains a threshold of “None” (i.e. processes of all sizes are regulated), the final regulations are expected to set practical limits to focus on commercial and industrial systems rather than personal vehicles or domestic units.
• Storage and Use of CO₂: The DFFE proposes adding “Storage and Use of CO₂” as a mandatory reporting activity in the IPPU sector. Affected industries likely include food and beverage, chemical manufacturing, welding, fire suppression, and wastewater treatment. The storage and use of CO₂ will likely fall under IPCC code 2G (Other Product Manufacture and Use), a category where reporting is largely not required under the existing NGERs (the exception being SF₆ use in electrical equipment).
• Rare Earth Metals: Primary rare earth metal production will become a mandatory reporting activity under the IPPU sector, in line with the 2019 IPCC Refinement (IPCC code 2C7). Associated process emissions include CO₂ generated during high-temperature roasting and calcination, as well as perfluorocarbons (PFCs) generated during molten-salt electrolysis. A reporting threshold of 50 tonnes of production per month has been proposed.

3. AFOLU: Cows and Sequestration

The Agriculture, Forestry and Other Land Use (AFOLU) sector will require reporting for livestock and carbon removals.

• Feedlots: New reporting requirements are being introduced for cattle (threshold of 8 000 head) and sheep (1 000 head).
• Poultry: The threshold for intensive poultry rearing is clarified at 40 000 places (farm capacity).
• Third-Party Sequestration: To align with the 2026 Tax Laws Amendment Act, the DFFE is proposing a framework that permits sequestration activities that are conducted by third-party timber growers to be claimed against fuel combustion emissions in the paper and wood products industries. To ensure integrity, the DFFE is making registration mandatory for all third-party growers. Any sequestration claimed from these third parties must be independently verified by a DFFE-approved verifier – Yellow Tree is in the process of becoming a registered verifier. Registered third parties will be required to provide data, including total area harvested, units of harvest, and mandatory geospatial verification (such as GPS coordinates).

4. Waste: Lowering the Floor

Thresholds in the waste sector will be reduced so as to capture smaller-scale operations.

• Solid Waste Disposal Sites: The threshold is dropping from 5 tonnes per day to 2 tonnes per day (or a total site storage capacity of 15 000 tonnes).
• Incineration: Any installation treating 10 kg per day of general or hazardous waste will need to report GHG emissions. This aligns with the threshold of Subcategory 8.1 of the air quality Listed Activities.
• Wastewater: The threshold for domestic wastewater treatment is being halved to 1 million litres per day. For industrial wastewater activities, the reporting threshold has been removed entirely, meaning anyone treating wastewater in an industrial setting will be required to report.

What This Means for You

The direction of travel is clear: more facilities in scope and more scrutiny on data. If you are unsure whether these proposed changes will affect your company, please reach out. We are here to help you navigate these technical updates and ensure your GHG reporting remains compliant and accurate.

If you did not read our update on the rumours pertaining to carbon tax, which we sent out over the Easter break, please read it here.