When Environment Canada introduced the Clean Fuel Standard (CFS) framework in May 2018, it signaled a major shift in the way oil and gas companies would be expected to account for and report their supply-chain emissions. Designed to drive reductions in the carbon intensity of fuels used across Canada, the CFS placed new obligations on producers, importers, and distributors to quantify and disclose the life-cycle emissions of petroleum products. For many in the sector, this required a fundamental rethink of data collection, attribution, and reporting practices tied to their upstream and downstream operations.
At the heart of the reporting requirement was the need to accurately attribute life-cycle emissions to each distinct fuel source. Companies were encouraged to leverage the open refinery dataset made available by Natural Resources Canada (NRCan). This dataset provided a detailed view of the operational characteristics, throughput volumes, and emission factors associated with each refinery operating within Canada’s borders. By linking their internal production data to this open source, firms could generate more precise estimates of carbon intensity on a per-barrel or per-litre basis, supporting both compliance efforts and internal decarbonization strategies.
In practice, integrating this data required close collaboration between environmental compliance teams, supply-chain managers, and operational staff at refining and distribution facilities. Many firms began by mapping their fuel streams to specific refinery configurations as outlined in the NRCan dataset. This mapping exercise enabled more granular attribution of emissions, distinguishing between, for example, conventional crude and oil sands-derived fuels, or between domestic and imported sources. In cases where proprietary refinery configurations differed significantly from NRCan’s generalized data, companies supplemented open data with their own measurements to improve accuracy.
Another crucial component of compliance was the use of GHGenius, the Canadian government’s open life-cycle model for transportation fuels. Companies were tasked with linking real-time flow data from pipeline meters and transfer points to the GHGenius model, enabling dynamic calculation of greenhouse gas intensities along the supply chain. Establishing this link required technical integration between pipeline SCADA systems and GHGenius-compatible data formats, an exercise that often revealed gaps in data quality or consistency that needed to be addressed as part of a broader digitalization effort.
Step-by-step, firms developed protocols for capturing flow meter data at key junctions: refinery outflows, pipeline inputs, tank farm transfers, and distribution terminal loadings. This information fed directly into GHGenius, where emissions estimates could be modeled for each batch or consignment. In parallel, firms implemented verification routines, comparing GHGenius outputs against internal carbon accounting models and third-party audits to ensure alignment.
To facilitate regulatory reporting, companies designed seasonal “fuel pathway” disclosure templates aligned with Clean Fuel Registry submission requirements. These templates typically summarized the carbon intensity of each major fuel type supplied during the reporting period, broken down by source, refining process, and transport mode. In addition to numerical disclosures, many templates included narrative descriptions of supply-chain adjustments or improvements made to reduce overall emissions. The seasonal cadence of these reports—often tied to production cycles or inventory turnover—enabled firms to highlight progress on a continual basis, rather than waiting for annual reporting windows.
Developing these templates required careful attention to both regulatory specifications and practical usability. Reports needed to be detailed enough to meet Environment Canada’s standards, while remaining accessible to internal and external reviewers who might lack deep technical expertise. Many companies piloted their disclosure formats internally before submission, using mock data to test the clarity, completeness, and accuracy of their reports.
As the CFS framework moved from design to implementation, it became clear that petroleum supply-chain reporting was no longer simply a compliance exercise. The process of mapping fuel pathways, integrating open datasets, and disclosing life-cycle emissions data provided firms with a clearer view of their carbon footprints and highlighted opportunities for reduction that might otherwise have remained obscured. In this way, the CFS not only reshaped reporting obligations but also encouraged a broader cultural shift toward transparency and continuous improvement within Canada’s oil and gas sector.