Closing The Scope 3 Accountability Gap: Why Food Sustainability Strategies Stall – And What To Do About It
In this jointly published piece by Future Food Movement and Foodsteps, we unpack how to successfully scale Scope 3 initiatives – and look at what prevents some businesses from getting it right. Foodsteps' Stephanie Lambert and Future Food Movement's Helen Ireland break down how to build scalable data foundations and develop the cross-functional governance required to turn environmental metrics into decisive commercial action.
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Why do so many ambitious sustainability strategies stall? In our work across the food system, we see two common themes: organisations either launch siloed sustainability programmes that are impossible to scale, or they rush into action using generic industry averages that fail to prove real-world progress.
Data without organisational capability is an engine without a driver – it holds immense potential but sits stationary. Conversely, capability without decision-grade data is a driver steering in the dark.
Scope 3 is often treated as a data problem, but it is much more than that.
A retailer or manufacturer can set a bold Net Zero target, but the actual emissions are determined by day-to-day sourcing decisions made by hundreds of fragmented suppliers. Closing this execution gap requires a structural shift in how businesses operate.
True progress requires a sequential approach. First, businesses must establish granular, ingredient-level data foundations to accurately map their footprint. Second, they must upskill their teams to translate that data into commercial procurement decisions.
In this jointly published piece, Stephanie Lambert (Foodsteps) and Helen Ireland (Future Food Movement) break down how to build scalable data foundations and develop the cross-functional governance required to turn environmental metrics into decisive commercial action.
Part One: Building Foundations That Scale
Stephanie Lambert, Managing Director, Foodsteps
At Foodsteps, we get to work with some of the most progressive food businesses in the UK, and what we see again and again is that the distance between a sustainability pilot and genuine enterprise-scale delivery is wider than most organisations expect.
The pilot that goes nowhere
Sustainability targets often break down in two predictable ways.
The first is by launching a pilot that was never designed to scale. A highly decentralised business that runs a pilot in one division quickly discovers that their group looks nothing like the rest of the company – different data, different processes, different decision-makers. The result is a collection of siloed experiments instead of a replicable model.
The second failure is more costly: skipping the foundational layer entirely in a rush to act. Businesses want momentum, understandably, but if the underlying data isn’t granular enough, they cannot prove that any real-world action has actually moved the needle. Actors along the value chain have invested and changed their practices, but the impact isn't clear.
What “foundational” actually means
When we talk about foundational data, we mean moving beyond industry averages and spend-based proxies. These metrics have their place as starting estimates, but they are not decision-grade.
If you’re running supplier programmes, joint decarbonisation initiatives, or reformulation work, you need ingredient-level data: country of origin, farming practice, the specific emissions profile of what you’re procuring. Without that, you cannot prove to your business that the investment was worth it, or credibly demonstrate progress to customers, regulators, or investors.
This is what Foodsteps was built to solve. We have built a database of over 45,000 emission factors across more than 4,800 ingredients, enabling businesses to move from approximate estimates to decision-grade scope 3 data – in days, not months.
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The other gap: sustainability vs. the rest of the business
Data infrastructure alone doesn’t change behaviour. The structural gap in scope 3 isn’t just between a retailer and their supply chain – it’s between the sustainability team and everyone else.
Chefs don’t think in tonnes of CO₂ and procurement teams aren’t waking up thinking about emissions factors. R&D is focused on taste, cost, and shelf life. If you want sustainability to scale inside a business, you have to meet people where they are – with tools, goals, and language that actually make sense for them.
What works? Simple goal-setting, translated for each function in the business. Compass doesn’t ask chefs to reduce carbon – they ask them to get 60% of recipes to an A or B rating (colour-coded green and light-green respectively). Levy set a plant-based desserts target and hit 86%. The underlying ambition is the same. The language is completely different.
After the appropriate goals are in place, the tools must follow to empower teams to take action. They need to be simple enough for the person using them, not for the sustainability practitioner who designed them. If tools are too complex and not accessible to those who haven’t been in the sustainability space, they won’t get adopted at scale. And lastly, the companies we’ve seen progress fastest are intentional in building the cultural infrastructure alongside the technical layer: procurement playbooks, peer learning forums, and workshops where practitioners share what’s working. This is how things get truly embedded in organisations.
Making it stick
The businesses genuinely operationalising sustainability share one thing: they’ve connected sustainability to the incentive structures that already govern behaviour. When a C-suite bonus includes a food waste metric, food waste goes down. When procurement targets include sustainability components, procurement decisions change.
What gets measured gets done. What gets rewarded gets embedded. The scope 3 accountability gap only truly closes when the internal architecture of the business – its goals, its tools, its culture, and its incentives – is all pointing in the same direction.
Part two: turning data into decisions
Helen Ireland, Strategy & Transformation Director, Future Food Movement
Getting the data right is the necessary first step. But in our experience working with food businesses, the harder challenge is what comes next: building the governance structures, the board-level confidence, and the cross-functional capability to actually act on what the data is telling you.
Everywhere we look, organisations have more data than ever but very little confidence around what to do with it. The challenge isn’t measurement anymore. It’s decision-making.
That challenge has just become more urgent. Under SBTi V2.0, businesses are expected to demonstrate not only what emissions reductions have been achieved, but the actions that delivered them and how those actions connect to their wider transition plans. Climate data is now expected to carry the same rigour as financial reporting. Organisations that have been measuring without acting – or acting without being able to prove it – are running out of road.
A more complex operating environment
Scope 3 doesn’t sit in isolation. Food businesses are now operating at the intersection of three converging pressures: health expectations reshaping what products succeed, carbon constraints reshaping cost, supply and claims, and supply risk exposing weaknesses in sourcing and strategy.
Individually, these are known challenges. Combined, they change how commercial decisions need to be made. Sourcing, pricing, product mix, positioning – these are now influenced simultaneously by health, carbon and risk. Yet most teams are still tracking them separately, with separate data, without a clear way to translate the combined picture into action.
The gap is not awareness. It’s decision-making under combined pressure.
Where organisations get stuck
Most sustainability strategies stall not because the data is wrong, but because the organisational conditions aren’t right. The insight layer – the ability to take decision-grade data and translate it into something a procurement director, a CFO, or a board can act on – is missing.
That means building three things in parallel: governance structures that give sustainability decisions the same rigour as financial ones; cross-functional alignment that connects sustainability targets to the incentives and language of each function; and board-level confidence grounded in commercial risk and opportunity, not just compliance.
The organisations making the most progress are those that have stopped treating scope 3 as a sustainability workstream and started treating it as a business transformation challenge. That reframe changes everything, who’s in the room, what questions get asked, and what actions follow.
What Future Food Movement does
The challenge is making the right commercial calls as pressures accelerate. Future Food Movement equips leaders with the capability, confidence and connection to act decisively, influence outcomes and stay ahead, turning pressure into advantage.
Most food businesses are facing the same brutal reality: the pressures hitting them right now – HFSS compliance, UPF scrutiny, producer viability, climate disruption, affordability – don’t sit in one team, one function or one part of the supply chain. But organisations are still structured as if they do. The result is leaders making consequential decisions with incomplete visibility, commercial teams disconnected from supply realities, and sustainability agendas that never quite land as business strategy.
The cost isn’t just slow progress – it’s execution risk that amplifies every other risk on the board.
This is precisely why a siloed approach to Scope 3 fails, and why solving it requires looking beyond the boundaries of any single organisation. By combining data-led visibility with cross-system collaboration, businesses can connect leaders across the entire value chain – from farming and manufacturing to retail and finance – to match commercial strategy with climate reality.
Ready to close the gap?
If you need decision-grade, lifecycle data for your supply chain: Discover how Foodsteps can map your footprint at foodsteps.earth or get in touch at hello@foodsteps.earth.
If you need to turn environmental metrics into cross-functional decisions: Learn how Future Food Movement can help upskill your teams and build internal capability at futurefoodmovement.com.

