SECR Reporting for Manufacturing: Industry-Specific Guide

Manufacturing businesses face unique challenges when complying with Streamlined Energy and Carbon Reporting (SECR) regulations. Energy-intensive production processes, complex supply chains, and multiple emission sources require careful consideration to ensure accurate, compliant reporting to Companies House.

This comprehensive guide addresses the specific SECR compliance needs of UK manufacturing businesses, from automotive and aerospace to food processing and chemicals production.

Why SECR Matters for Manufacturing

Manufacturing is one of the most energy-intensive sectors in the UK economy, accounting for a significant portion of industrial carbon emissions. SECR compliance is particularly important for manufacturers because:

Regulatory Compliance

Most UK manufacturers with 250+ employees or meeting the turnover/balance sheet thresholds fall under SECR requirements. Non-compliance can result in:

• Directors' liability for filing deficiencies
• Reputational damage from public non-compliance records
• Potential enforcement action by regulatory authorities

Supply Chain Pressure

Major manufacturers (automotive OEMs, aerospace primes, pharmaceutical companies) increasingly require SECR compliance from suppliers as part of their own Scope 3 reporting and ESG commitments.

Cost Management

Manufacturing energy costs represent 5-15% of total production costs for many sectors. SECR reporting provides baseline data essential for:

• Identifying energy efficiency opportunities
• Justifying capital investment in efficient equipment
• Tracking ROI on energy reduction projects

Competitive Advantage

Transparent environmental reporting differentiates manufacturers in tenders and procurement, particularly for public sector contracts and sustainability-focused customers.

Manufacturing-Specific SECR Challenges

Challenge 1: Complex Energy Sources

Unlike office-based businesses that primarily consume electricity and gas, manufacturers use diverse energy sources:

Direct Energy Sources (Scope 1):

• Natural gas for process heating and steam generation
• LPG for forklifts and material handling
• Diesel for backup generators and onsite vehicles
• Process fuels (coal, fuel oil, biomass) for high-temperature applications
• Refrigerants in cooling systems and cold storage

Purchased Energy (Scope 2):

• Grid electricity for machinery, lighting, and HVAC
• Steam purchased from adjacent facilities or combined heat and power (CHP) plants
• District heating in industrial parks

Production-Specific Sources:

• Waste heat recovery systems
• Onsite renewable generation (solar, biomass boilers)
• Combined Heat and Power (CHP) installations

Challenge 2: Process Emissions

Some manufacturing processes create direct CO2 emissions beyond energy combustion:

Cement Production:

• Calcination of limestone releases CO2 (non-combustion emission)
• Must be reported as Scope 1 using process-specific factors

Chemical Manufacturing:

• Chemical reactions releasing greenhouse gases
• Fugitive emissions from process equipment

Metal Production:

• Blast furnace emissions in steel making
• Aluminum smelting process emissions

These process emissions require specialized conversion factors beyond standard energy factors.

Challenge 3: Multiple Sites

Manufacturing businesses often operate:

• Multiple production facilities
• Distribution centers and warehouses
• Head office and administrative locations
• Research and development facilities

Each site requires separate data collection, creating coordination challenges.

Challenge 4: Production Variability

Manufacturing output varies significantly:

• Seasonal production cycles
• Product mix changes
• Capacity utilization fluctuations
• Shift patterns affecting baseline energy use

This variability complicates year-over-year comparisons and intensity metric selection.

Step-by-Step SECR Compliance for Manufacturers

Step 1: Define Your Reporting Boundary

Clearly establish which facilities and operations are included in your SECR report.

Organizational Boundary Approach:

Operational Control (Most Common): Include all facilities where you have authority to implement operational policies. This includes wholly-owned facilities and those where you have management control.

Financial Control: Include facilities consolidated in your financial statements.

Equity Share: Include emissions proportional to your ownership percentage in joint ventures.

Example Boundary Statement: "This SECR report covers all UK manufacturing operations of ABC Manufacturing Ltd under operational control, including our Birmingham casting facility, Manchester assembly plant, and Glasgow distribution center. Our 30% stake in Scottish Joint Venture Ltd is excluded as we do not have operational control."

Step 2: Identify All Energy and Emission Sources

Create a comprehensive register of energy consumption and emission sources:

Electricity:

• Main production machinery (CNC machines, presses, injection molding)
• Material handling equipment
• Compressed air systems
• HVAC and ventilation
• Lighting
• Office equipment
• Clean rooms or controlled environments
• Onsite EV charging stations

Natural Gas:

• Process heating furnaces
• Steam boilers for production
• Space heating in facilities
• Hot water systems
• Paint curing ovens
• Heat treatment processes

Other Fuels:

• LPG for forklifts and material handlers
• Diesel for backup generators
• Fuel oil for high-temperature processes
• Biomass for renewable heat
• Coal (if still used in legacy processes)

Refrigerants:

• HVAC system refrigerant top-ups
• Industrial refrigeration in food processing
• Chiller systems

Transport:

• Company-owned delivery vehicles
• Forklift and material handling fuel
• Mobile plant and equipment
• Grey fleet business travel

Purchased Heat:

• Steam from external CHP plants
• District heating in industrial estates

For detailed energy data collection guidance, see our guide on SECR energy data collection.

Step 3: Collect Manufacturing Energy Data

Manufacturing energy data comes from multiple sources:

Utility Bills: Standard monthly or quarterly bills for electricity and gas from suppliers

Sub-Metering Systems: Many manufacturers have production-level metering:

• Machine-level electricity monitoring
• Department or production line sub-meters
• Building management systems (BMS) data

SCADA and Process Control Systems: Industrial control systems often log energy consumption:

• Programmable Logic Controllers (PLCs) with energy monitoring
• Manufacturing Execution Systems (MES) with utility tracking
• Energy Management Systems (EMS)

Fuel Delivery Records: Invoices and delivery notes for:

• Bulk LPG deliveries
• Heating oil tanker deliveries
• Biomass fuel receipts

Maintenance Records: Refrigerant top-up logs showing:

• Refrigerant type (GWP - Global Warming Potential)
• Kilograms added per service event
• Date of maintenance

Vehicle and Equipment Logs:

• Forklift fuel consumption records
• Delivery vehicle mileage and fuel purchases
• Mobile equipment fuel tracking

Step 4: Calculate Manufacturing Emissions

Apply UK Government conversion factors to your consumption data.

Standard Energy Conversions:

Electricity: 100,000 kWh × 0.22931 kgCO2e/kWh = 22,931 kgCO2e (22.93 tonnes)

Natural Gas: 500,000 kWh × 0.18316 kgCO2e/kWh = 91,580 kgCO2e (91.58 tonnes)

Diesel (Generators/Vehicles): 10,000 litres × 2.69869 kgCO2e/litre = 26,987 kgCO2e (26.99 tonnes)

LPG (Forklifts): 5,000 litres × 1.51427 kgCO2e/litre = 7,571 kgCO2e (7.57 tonnes)

Refrigerant Emissions: Refrigerants require GWP-specific factors:

• R404A: 3,922 × kg released = kgCO2e
• R410A: 2,088 × kg released = kgCO2e
• R134a: 1,430 × kg released = kgCO2e

Example: 5 kg of R404A topped up = 5 × 3,922 = 19,610 kgCO2e (19.61 tonnes)

Process Emissions: Process-specific emissions use specialized factors. For example:

• Cement clinker production: Use tonne cement × specific process factor
• Consult UK Government's industrial process guidance for sector-specific factors

For detailed conversion factor guidance, see our article on UK Government conversion factors.

Step 5: Choose Appropriate Intensity Metrics

Manufacturing intensity metrics should reflect your core business activity:

Production-Based Metrics (Recommended):

Emissions per Tonne of Product: Most relevant for manufacturers with consistent product types

• Total emissions ÷ tonnes produced = kgCO2e per tonne

Example: 150 tonnes CO2e ÷ 2,000 tonnes steel produced = 75 kgCO2e per tonne steel

Emissions per Unit Produced: For discrete manufacturing (automotive, aerospace, electronics)

• Total emissions ÷ units produced = kgCO2e per unit

Example: 150 tonnes CO2e ÷ 50,000 widgets = 3 kgCO2e per widget

Emissions per Revenue: Useful when product mix varies significantly

• (Total emissions ÷ revenue) × £1M = tonnes CO2e per £1M turnover

Alternative Metrics:

Emissions per Employee: Allows comparison across different sectors but less meaningful for capital-intensive manufacturing

Emissions per Production Hour: Useful for job shops and contract manufacturers

Emissions per Square Meter: Applicable for warehouse and distribution operations

Best Practice: Choose a metric that:

1. Reflects your core manufacturing activity
2. Can be tracked consistently year-over-year
3. Adjusts for production volume changes
4. Enables meaningful benchmarking within your sector

Step 6: Document Energy Efficiency Actions

SECR requires describing energy efficiency measures implemented during the reporting period. Manufacturers typically have more opportunities than service businesses:

Common Manufacturing Energy Efficiency Measures:

Process Optimization:

• Variable speed drives (VSD) on motors and compressors
• Waste heat recovery from furnaces and ovens
• Process control optimization reducing energy per unit
• Batch process consolidation to reduce start-up energy

Equipment Upgrades:

• High-efficiency motors (IE3 or IE4 rated)
• LED lighting in production areas and warehouses
• Efficient compressed air systems with leak detection
• Modern CNC machines with energy-saving modes

Building Improvements:

• Industrial door replacements (rapid doors, insulated doors)
• Warehouse roof insulation upgrades
• Skylights and natural lighting in production halls
• HVAC system modernization

Renewable Energy:

• Rooftop solar PV installations
• Biomass boilers replacing fossil fuel heating
• Wind turbines (for large sites with suitable conditions)
• Ground source heat pumps for office areas

Behavioral and Operational:

• Shutdown procedures for non-production hours
• Production scheduling to avoid inefficient partial loads
• Predictive maintenance reducing equipment inefficiency
• Staff training on energy-conscious operation

Example Energy Efficiency Disclosure: "During the reporting period, we installed variable speed drives on 12 major compressed air compressors across our Birmingham facility, delivering estimated annual savings of 85,000 kWh. We also replaced 350 metal halide warehouse lights with LED alternatives, saving an estimated 120,000 kWh annually. In our Manchester plant, we implemented a waste heat recovery system capturing exhaust heat from paint curing ovens, reducing natural gas consumption by an estimated 200,000 kWh per year."

Manufacturing Sector-Specific Considerations

Automotive Manufacturing

Energy Intensity Drivers:

• Body shop welding and stamping operations
• Paint booths with high ventilation requirements
• Assembly line conveyor systems
• Testing and quality control equipment

Typical Intensity Metrics:

• kgCO2e per vehicle produced
• Emissions per £1M turnover (for tier suppliers making diverse components)

SECR Reporting Focus:

• Paint shop energy consumption (often 40-50% of facility total)
• Compressed air system efficiency
• Conveyor system optimization

Food and Beverage Manufacturing

Energy Intensity Drivers:

• Refrigeration and cold storage
• Cooking, pasteurization, and sterilization
• Cleaning and sanitization (hot water/steam)
• Packaging equipment

Refrigerant Reporting: Food manufacturers must carefully track refrigerant top-ups, which can represent significant CO2e emissions due to high GWP refrigerants.

Typical Intensity Metrics:

• kgCO2e per tonne of product
• Emissions per liter produced (beverages)

SECR Reporting Focus:

• Refrigeration system efficiency and leak prevention
• Heat recovery from refrigeration condensers
• Steam system efficiency

Chemicals and Pharmaceuticals

Energy Intensity Drivers:

• Reaction vessels and process heating
• Distillation and separation processes
• Clean rooms and controlled environments
• Ventilation and fume extraction

Process Emissions: Some chemical reactions release CO2 or other greenhouse gases. These must be reported as Scope 1 using specialized factors.

Typical Intensity Metrics:

• kgCO2e per tonne of active ingredient
• Emissions per batch produced

SECR Reporting Focus:

• Process efficiency optimization
• Heat integration and pinch analysis
• Solvent recovery systems

Aerospace Manufacturing

Energy Intensity Drivers:

• CNC machining of complex parts
• Autoclave curing of composites
• Clean room assembly environments
• Testing and quality assurance

Typical Intensity Metrics:

• kgCO2e per aircraft delivered
• Emissions per £1M turnover (more common for component suppliers)

SECR Reporting Focus:

• Autoclave scheduling and efficiency
• Compressed air and vacuum system optimization
• Clean room conditioning efficiency

Metal Fabrication

Energy Intensity Drivers:

• Cutting, forming, and welding operations
• Surface treatment and coating
• Heat treatment processes
• Compressed air for pneumatic tools

Typical Intensity Metrics:

• kgCO2e per tonne of metal processed
• Emissions per £1M turnover

SECR Reporting Focus:

• Furnace and oven efficiency
• Welding power optimization
• Compressed air leak management

Multi-Site Manufacturing SECR Reporting

Large manufacturers with multiple facilities face additional coordination challenges:

Centralized Data Collection

Establish Clear Ownership:

• Designate a corporate SECR owner (often sustainability or facilities manager)
• Assign site-level data collection responsibility
• Create standardized data templates for all sites

Implement Centralized Systems:

• Energy management platforms aggregating multi-site data
• Centralized utility bill management
• Cloud-based data repositories accessible to all sites

Standardized Reporting

Create standardized processes across all manufacturing sites:

Data Collection Timing: Set quarterly or monthly data submission deadlines for each site

Data Format: Use standardized templates ensuring consistency:

• Same units (kWh, litres, tonnes)
• Same categorization (by energy type and scope)
• Same level of detail

Quality Assurance: Implement validation checks:

• Year-over-year comparison flags for unusual variances
• Cross-check with production volumes
• Verification of unit conversions

Site-Level vs Consolidated Reporting

Consolidated Reporting (Most Common): Single SECR report covering all UK operations, with data aggregated across sites

Advantages:

• Simpler compliance (one report)
• Lower administrative burden
• Enables corporate-level intensity metrics

Site-Level Reporting: Some manufacturers report site-specific data within their SECR disclosure

Advantages:

• Better visibility into facility performance
• Supports site-level improvement tracking
• Demonstrates transparency

Hybrid Approach: Report consolidated totals in your official SECR disclosure, but maintain detailed site-level data internally for management purposes.

For multi-site retail guidance applicable to distribution operations, see our article on retail multi-site SECR reporting.

Advanced Manufacturing SECR Topics

Combined Heat and Power (CHP) Reporting

CHP systems generate both electricity and heat onsite, requiring careful emission accounting:

Calculation Approach:

1. Calculate total fuel input to CHP (natural gas in kWh)
2. Apply gas conversion factor to fuel input
3. Report as Scope 1 emissions
4. Deduct electricity generated onsite from grid electricity purchased (Scope 2)

Example:

• Natural gas to CHP: 500,000 kWh
• Emissions: 500,000 × 0.18316 = 91,580 kgCO2e (Scope 1)
• Electricity generated: 150,000 kWh (reduces Scope 2 purchases)

Carbon Capture and Storage (CCS)

Some large industrial facilities are implementing carbon capture:

SECR Treatment:

• Report gross emissions before capture
• Optionally note captured CO2 separately
• Follow GHG Protocol guidance on CCS accounting

Onsite Renewable Generation

Manufacturing facilities increasingly install solar PV or other renewables:

Reporting Options:

Option 1 - Net Consumption: Report only grid electricity purchased (net of generation)

• Simpler approach
• Renewable benefit implicit in reduced Scope 2

Option 2 - Separate Disclosure: Report grid electricity and onsite generation separately

• Demonstrates renewable investment
• Provides transparency

Example: "Grid electricity purchased: 850,000 kWh (195.9 tonnes CO2e). Additionally, our rooftop solar PV system generated 150,000 kWh consumed onsite, avoiding an estimated 34.5 tonnes CO2e."

Manufacturing SECR Best Practices

Implement Energy Monitoring Systems

Invest in real-time energy monitoring:

• Sub-metering at production line or department level
• Integration with SCADA and ERP systems
• Dashboards for energy managers and production teams

Benefits:

• Identifies energy-intensive processes
• Enables rapid response to inefficiencies
• Supports continuous improvement

Integrate with ISO 50001

Many manufacturers pursue ISO 50001 Energy Management System certification:

• SECR data feeds directly into ISO 50001 reporting
• ISO 50001 processes streamline SECR data collection
• Combined approach reduces duplication

Benchmark Against Sector Peers

Compare your intensity metrics with industry standards:

• Carbon Trust sector guides
• Trade association benchmarking data
• Energy Savings Opportunity Scheme (ESOS) findings

Engage Production Teams

Involve shop floor and production managers:

• Share SECR results and energy performance
• Incentivize energy efficiency ideas
• Celebrate successes and improvement milestones

Plan Capital Investment

Use SECR baseline data to justify energy efficiency capex:

• Calculate payback periods for efficiency projects
• Model ROI of renewable energy installations
• Prioritize high-impact, low-cost improvements

Common Manufacturing SECR Mistakes

Mistake 1: Omitting Process Emissions

Problem: Reporting only energy combustion, missing chemical process CO2 or refrigerant leakage

Solution: Conduct thorough site audit to identify all emission sources, including process and fugitive emissions

Mistake 2: Inconsistent Boundary

Problem: Including different sites year-over-year without explanation

Solution: Clearly document reporting boundary and note any changes with explanation

Mistake 3: Inappropriate Intensity Metric

Problem: Using emissions per employee when production volume varies significantly

Solution: Choose production-based metric (per tonne, per unit) that adjusts for output changes

Mistake 4: Missing Multi-Site Data

Problem: Incomplete data collection from remote or smaller facilities

Solution: Implement centralized data collection system with clear site-level accountability

Mistake 5: Ignoring Production Context

Problem: Reporting emissions increase without explaining production volume growth

Solution: Always present emissions alongside intensity metrics and production volumes

Streamlining Manufacturing SECR Compliance

Manual SECR compliance for complex manufacturing operations can take days or weeks of effort across multiple teams.

Automation Benefits for Manufacturers

Modern SECR platforms like Comply Carbon streamline manufacturing compliance:

Multi-Site Data Aggregation: Upload bills from all facilities, automatically consolidated

Diverse Energy Source Handling: AI recognizes electricity, gas, LPG, diesel, and other fuels from various bill formats

Automated Calculations: Latest UK Government conversion factors applied automatically across all energy types

Flexible Intensity Metrics: Calculate multiple intensity metrics based on your production data

Time Savings: Reduce compliance from weeks to hours, freeing manufacturing teams for operational priorities

Cost Savings: £1,999 platform fee vs. £15k-25k consultants, with faster turnaround

Frequently Asked Questions

Q: Do I include emissions from contracted logistics? Contracted delivery services are Scope 3 (optional for SECR). Company-owned delivery vehicles are Scope 1 (mandatory).

Q: How do I handle co-generation (CHP) emissions? Report fuel input to CHP as Scope 1. Electricity generated reduces your Scope 2 grid consumption.

Q: What if production varies significantly year-to-year? Use production-based intensity metrics (per tonne, per unit) to show efficiency independent of volume changes.

Q: Do I need third-party verification? SECR doesn't require external verification for most manufacturers. Focus on robust internal data collection and documentation.

Q: How do I compare my manufacturing emissions to peers? Use intensity metrics and compare against sector benchmarks from trade associations, Carbon Trust sector guides, or ESOS data.

Conclusion

Manufacturing businesses face unique SECR compliance challenges due to energy-intensive operations, multiple emission sources, and often complex multi-site structures. However, with systematic data collection, appropriate intensity metrics, and clear documentation of energy efficiency measures, manufacturers can achieve full compliance while generating valuable insights for energy management.

Key Takeaways for Manufacturing SECR Compliance:

• Define clear reporting boundaries across all facilities
• Identify all energy and emission sources (including process emissions and refrigerants)
• Choose production-based intensity metrics aligned with core manufacturing activity
• Document energy efficiency measures with quantified savings
• Implement robust data collection systems across multiple sites
• Consider automation to reduce compliance burden and ensure accuracy

Manufacturing energy data doesn't just fulfill compliance obligations—it provides the foundation for continuous improvement, cost reduction, and demonstrating environmental leadership to customers and stakeholders.

Ready to streamline your manufacturing SECR compliance? Explore Comply Carbon's automated platform or review our complete SECR guide for additional guidance.