Fleets subject to the Corporate Sustainability Reporting Directive (CSRD) are reevaluating how they clean vehicles because Article 19a requires disclosure of Scope 3 emissions, and ESRS E1 specifies that purchased goods and services must be included. Traditional petrol-station hand washes do not supply the granular, auditable water-consumption data needed for this reporting, creating a gap that mobile waterless valeting can close.

CSRD Article 19a and ESRS E1 Scope 3 requirements

CSRD Article 19a mandates that large undertakings report on sustainability matters, including environmental impacts. ESRS E1 Climate change defines the disclosure requirements for greenhouse‑gas emissions, dividing them into Scope 1 (direct), Scope 2 (indirect from energy) and Scope 3 (other indirect). Scope 3 Category 1 covers purchased goods and services, which for a fleet includes the water and cleaning agents used in vehicle washing. To comply, fleet managers need a way to quantify the water volume associated with each wash event and convert it to CO₂‑equivalent using recognised factors.

Auditability gaps in petrol‑station hand wash water use

Petrol‑station hand washes typically operate on a pay‑per‑use basis with no individual metering per vehicle. The water flow is shared across multiple bays, and the station does not provide a receipt that specifies how many litres were consumed for a particular wash. This lack of granular, verifiable data makes it impossible to allocate water use to a specific vehicle or to aggregate it accurately for Scope 3 reporting. Without an auditable trail, the data cannot be traced back to the fleet’s purchased service, violating the traceability principle required by ESRS E1.

How MMCC provides verifiable per‑service data

MMCC’s mobile waterless valeting service generates a record for every vehicle serviced. Each record includes the date, time, location (outward postcode only), vehicle class and the volume of pre‑treatment fluid applied. Because the service is performed at the customer’s chosen location, the water‑free process eliminates on‑site water consumption entirely, and the fluid usage is measured per vehicle. These records can be exported in a simple format (e.g., CSV) on request, allowing fleet managers to map each service event to their ESG platform’s Scope 3 Category 1 field using the outward postcode as the geographic dimension.

GHG conversion factors for water use

When water is used in a washing process, associated emissions arise from both water supply and wastewater treatment. The UK Department for Environment, Food and Rural Affairs (DEFRA) publishes annual GHG Conversion Factors for Company Reporting. The 2024 edition lists:

Water supply: 0.149 kgCO₂e per m³
Water treatment: 0.272 kgCO₂e per m³

By multiplying the metered water volume (if any) by these factors, a fleet can calculate the CO₂‑equivalent emissions attributable to water use. For a waterless process where the water volume is zero, the associated emissions from water supply and treatment are also zero, simplifying the calculation.

Choosing a verifiable waterless alternative

Fleet sustainability leads evaluating alternatives should consider:

Data granularity: Does the provider supply a per‑service record that can be audited?
Water footprint: Does the method eliminate on‑site water use, thereby removing supply‑and‑treatment emissions?
Data format: Is the output compatible with common ESG reporting tools (CSV, Excel, JSON)?
Geographic tagging: Are records tagged with an outward postcode to enable location‑based Scope 3 allocation?

MMCC meets these criteria by delivering a waterless process that avoids water consumption entirely and by supplying verifiable, postcode‑tagged service records on request.

Internal resources for fleet managers

For more information on how MMCC supports corporate fleets with Scope 3 data, see our Corporate fleet solutions page. The service operates across Surrey and Greater London, including areas such as mobile car valeting in Esher and mobile car valeting in Cobham.

Fleet managers can request a sample Scope 3 data export by visiting our Corporate fleet solutions page.