Dive Brief:
- The California Air Resources Board this week published its preliminary list of thousands of entities that may be subject to upcoming reporting requirements under either or both SB 253, which covers GHG emissions, and SB 261, which covers climate-related financial risks. The laws passed in 2023.
- A mix of publicly and privately held packaging suppliers named on the list include Crown, Hood Container, International Paper, Menasha, Pactiv Evergreen, Printpack, Sappi, Sealed Air, Silgan, TransPak and Veritiv. The preliminary list is intended to support development of fee regulation, law firm Ropes & Gray noted in a brief analysis.
- CARB acknowledges the list may be incomplete and has posted a voluntary survey to collect more information about additional entities that might be subject to regulations or stakeholders that might qualify for an exemption. “Each potentially-regulated entity remains responsible for compliance with statutory requirements, regardless of whether it was included in staff’s preliminary list or outreach,” the agency states on its website.
Dive Insight:
Many packaging manufacturers already do their own versions of annual emissions reporting. SB 253 will require public and private companies with revenue exceeding $1 billion to disclose scope 1 and 2 emissions starting in 2026; CARB has proposed a reporting deadline of June 30. These emissions relate to operations and power consumption. They’ll later have to report scope 3 emissions, which reflect their value chain, come 2027.
California’s implementation is especially notable after the U.S. Securities and Exchange Commission effectively abandoned Biden administration-era efforts to require scope 1 and 2 disclosures from public companies. Colorado, Illinois, New Jersey, New York and Washington have also considered emissions disclosure laws.
As for SB 261, CARB outlined earlier this month that the regulation applies to U.S. companies operating in California with revenue exceeding $500 million. Initial reports disclosing climate-related financial risk, plus reduction or adaptation measures, are due Jan. 1, 2026. The agency said it will create a public docket on Dec. 1, 2025, for companies to post reports, open through July 1, 2026. “This public docket will help support transparency by providing one location for the public to review” all such reports, CARB said.
One option for a framework for these reports is the Task Force on Climate-related Financial Disclosures, or TCFD, reports, according to CARB. Some packaging companies have already voluntarily published TCFD reports.
