CDP (Carbon Disclosure Project) response history is a practical proxy indicator for assessing whether a company has developed Scope 1 and 2 emissions data and can disclose it externally. In Japan, CDP Japan publishes a list of responding companies annually, with Prime Market-listed companies leading the growth in response numbers. The presence or absence of a response, along with the score range, is a useful source for rapidly screening the disclosure infrastructure maturity of potential suppliers.
What Is CDP — The Basic Structure of the Assessment Framework
CDP (Carbon Disclosure Project) is an NPO established in 2000 that promotes disclosure of information on climate change, water resources, and forests from corporations and local governments. Each year, the world's major institutional investors and large companies (CDP Supply Chain participants) send questionnaires to suppliers via CDP requesting responses.
The CDP climate change questionnaire is a detailed, annually revised survey comprising the following major sections:
- Governance (board-level responsibility structures for climate change)
- Risks and Opportunities (identification of transition and physical risks and their financial impacts)
- Business Strategy (scenario analysis and low-carbon transition plans)
- Emissions Data (Scope 1, 2, and 3 figures and calculation methodologies)
- Emissions Reduction Targets (alignment with SBTi, etc.)
- Energy Consumption (renewable energy usage status)
CDP evaluates responses on a scale from A to D- (non-responses receive "F") and publishes the scores. The A-List in particular is published annually, identifying corporate leaders in climate action.
Trends in CDP Responses Among Japanese Companies
Japan maintains a globally top-ranking position by number of responding companies. However, the pace of growth in respondents has slowed, and many small- and mid-cap manufacturers listed on the Prime Market have yet to respond. Some non-responding companies do disclose emissions in the sustainability section of their annual securities reports, but CDP-responding companies tend to have higher data granularity and calculation methodology transparency.
The number of Japanese CDP A-List companies exceeded 70 in 2024 — among the highest in the world — with major manufacturers including Panasonic, Toyota, Fujitsu, and Asahi Kasei. In contrast, A-List companies are almost entirely absent among mid-cap manufacturers with market capitalizations below ¥50 billion, underscoring the sharp gap in ESG disclosure maturity between large companies and the mid-tier.
The Difference Between CDP-Responding and Non-Responding Companies
A-List and High-Score Respondents (A–B)
Scope 1, 2, and 3 calculation infrastructure is well established, with third-party verified data disclosed. These companies often align with SBTi certification and renewable energy procurement targets, positioning them as advanced practitioners of ESG disclosure. In procurement evaluation, they can be treated as the highest-reliability providers of ESG data, though for smaller transaction volumes, participation in large-company engagement programs may be difficult.
Mid-Range Score Respondents (C–D)
Typically Scope 1 and 2 are tracked but Scope 3 is undeveloped, or there are inconsistencies in calculation accuracy. The presence of a response history confirms that basic data collection infrastructure exists. Confirming areas with room for improvement with the supplier is worthwhile. Whether the score trend is improving or flat provides additional information about ESG infrastructure maturity.
Non-Responding Companies
Non-response does not necessarily indicate poor ESG performance, but it often signals undeveloped data collection infrastructure or an organizational posture where disclosure is a low priority. In procurement evaluation, setting up additional verification questions to directly inquire about disclosure preparation status is effective. The quality of responses to the question 'do you plan to begin CDP responses?' allows inference about organizational commitment to ESG action.
Reading CDP Scores — Key Points Procurement Professionals Should Know
CDP scores evaluate the "quality and quantity" of disclosure — they do not directly measure actual emissions reductions. Even an A-List company with large emissions may be highly rated for disclosure transparency and the clarity of its reduction plans. Common blind spots for procurement professionals include:
- Score and actual emissions are not directly linked: A high CDP score does not mean a company has low emissions. Scores measure the quality of disclosure infrastructure.
- Response vs. response quality: Even companies that respond may have significant differences in data reliability depending on calculation methodologies, boundary definitions, and whether third-party verification exists.
- Sector-specific differences: The burden of CDP response differs between manufacturing, retail, and financial sectors, meaning equivalent scores may reflect different levels of infrastructure maturity.
Confirm the Scope 2 calculation method
Whether 'location-based' or 'market-based' methods are used can result in significantly different figures. Companies using the market-based method and purchasing renewable energy certificates may appear to have low Scope 2 figures. In a procurement context, it is recommended to confirm the actual means of renewable energy procurement and the type of certificates used.
Confirm the scope of Scope 3 category disclosures
Scope 3 covers 15 categories, and companies vary in how many they disclose. For manufacturing companies, check whether at least Category 1 (purchased goods and services) and Category 11 (use of sold products) are being disclosed. Disclosure of Category 1 is also a signal that the company has begun seeking Scope 3 data from its own suppliers.
Confirm SBTi alignment status
Check whether CDP B or A-scoring companies have SBTi commitments. SBTi-certified companies have scientifically grounded reduction targets, lending higher credibility to long-term decarbonization commitments. SBTi information is disclosed in the 'Targets' section on CDP.
Using CDP Information in Procurement Evaluation
Leverage the CDP Supply Chain Program
By participating in CDP Supply Chain, companies can request supplier responses by sending questionnaires through CDP. Major Japanese manufacturers are strengthening supplier engagement through this program. Participation costs (approximately ¥1 million per year) apply, but the program enables cost-efficient, simultaneous questionnaire distribution to hundreds of suppliers.
Regular monitoring of published scores
Since scores are published on the CDP Japan website, monitoring annual score trends for major suppliers enables early identification of risk. Score declines or withdrawn responses may signal significant changes in the company's situation. It is recommended to register major suppliers in a monitoring list for annual tracking.
Combining with EcoVadis
While CDP focuses specifically on climate, water, and forest environmental disclosures, EcoVadis covers a broader ESG assessment including labor, ethics, and procurement practices. Combining both information sources allows for a more accurate, multidimensional understanding of a supplier's ESG profile. Companies with scores in both CDP and EcoVadis can be assessed as having higher ESG infrastructure maturity.
Responding to Non-Responding Companies — Next Steps
Beginning CDP responses typically requires a 6–12 month preparation period. For suppliers that have not yet responded, asking "do you plan to respond in the next annual CDP cycle?" is a practical question for gauging preparation status.
When a supplier has no CDP response, alternative evaluation methods include:
- Checking Scope 1 and 2 data in the sustainability information section of annual securities reports (disclosure has been mandatory since 2023)
- Sending proprietary supplier questionnaires asking for Scope 1 and 2 figures and calculation methodologies
- Checking "mandatory energy efficiency report" data provided by the Ministry of Economy, Trade and Industry and the Ministry of the Environment (publicly available for some companies)
Since CDP questionnaires are sent based on requests from major institutional investors in the West, Prime Market-listed companies will ultimately be compelled to engage. For mid-cap manufacturers, building response infrastructure early represents an opportunity to differentiate in supplier evaluations.