Supply Chain Sustainability Statistics: Packaging, Scope 3 and Circularity
Scope 3 is where most of a company's footprint lives and where the data is weakest. Here are the definitions, the disclosure deadlines, the packaging waste and pallet lumber numbers, and what they add up to for a supply chain leader.

Key findings
- Scope 3 averages 75 percent of a company's total emissions (CDP), and supply chain emissions ran 26 times operational emissions in 2023 (CDP and BCG). Only 15 percent of disclosing companies have a supply chain target.
- California's first SB 253 Scope 1 and 2 reports are due November 10, 2026, moved from August 10; Scope 3 starts in 2027. SB 261 was still enjoined by the Ninth Circuit as of October 2026.
- U.S. containers and packaging generated 82.2 million tons of waste in 2018, 28.1 percent of all MSW; 58.8 percent of wood packaging, over 90 percent of it pallets, was landfilled (EPA).
- The U.S. pallet industry used an estimated 17.9 billion board feet of lumber in 2021, 38.6 percent of all sawn softwood and 37.6 percent of sawn hardwood; only 23 percent was knowingly certified (Virginia Tech).
- Recycled HDPE carries 71 percent lower greenhouse gas emissions than virgin HDPE (Franklin Associates for APR), which is why a 100 percent recycled pallet running 100 to 200-plus trips changes the Category 1 math.
Picture the Tuesday outbound schedule at one of your distribution centers. Twenty-two trailers leave before noon, each carrying 26 pallets of product, burning diesel you did not buy, through a carrier you do not own, to a warehouse you have never seen. Every one of those emissions is yours to report. Almost none of them are yours to measure.
That is Scope 3 in a sentence: the emissions a company is responsible for but does not control. For most companies it is also the bulk of the footprint. CDP puts Scope 3 at 75 percent of total emissions on average, and its 2024 report with Boston Consulting Group found supply chain emissions running 26 times operational emissions. The regulators have noticed. So have the auditors. Every figure below is sourced and dated, and where the sources disagree, we say so.
What Scope 1, 2 and 3 Emissions Mean
The GHG Protocol Corporate Standard sorts a company's greenhouse gas emissions into three scopes. In its words, Scope 1 emissions are direct emissions from owned or controlled sources; Scope 2 emissions are indirect emissions from the generation of purchased energy; and Scope 3 emissions are all indirect emissions, not included in Scope 2, that occur in the value chain of the reporting company, upstream and downstream. Everything from the lumber in the pallet you bought to the landfill it ends up in is Scope 3.
The Corporate Value Chain (Scope 3) Standard, published in 2011, breaks that bucket into 15 categories, eight upstream and seven downstream. One early road-tester, Kraft Foods, found value chain emissions were more than 90 percent of its total.
The Scope 3 Categories a Pallet Lands In
| Category | What it counts | Where the pallet shows up |
|---|---|---|
| 1. Purchased goods and services | Cradle-to-gate emissions of goods you buy | Every wood pallet you buy: harvest, sawing, nailing, heat treatment |
| 4. Upstream transportation and distribution | Freight you pay for | Inbound lanes, including the pallet's dead weight |
| 8. Upstream leased assets | Operating assets you lease; manufacturing them is optional for the lessee | A leased pallet fleet, reported by the lessee |
| 12. End-of-life treatment of sold products | Disposal of what you sold | Pallets shipped with product and discarded by the receiver |
| 13. Downstream leased assets | Operating assets you own and lease out, reported by the lessor | The lessor's category, where a leased pallet's footprint is carried |
Categories 8 and 13 are the pair that matter when you weigh a lease against a purchase. For a lessee, the minimum boundary is the lessor's Scope 1 and 2 emissions while the asset is in use; manufacturing emissions are optional. For a lessor, Category 13 covers assets it owns and leases out. A pallet burns no fuel while it works, so the manufacturing footprint of a leased pallet sits with the lessor. A purchased pallet is a fresh Category 1 entry every time, and white wood gets bought often.
Key Takeaway
Scope 3 is 15 categories, not one number, and a pallet touches at least five of them. Knowing which is the difference between a defensible disclosure and a spreadsheet of averages.
How Much of the Footprint Sits in Scope 3
CDP's technical note on Scope 3 relevance, built on its 2021 corporate responses and updated in June 2024, found that across all sectors Scope 3 accounts on average for 75 percent of total Scope 1, 2 and 3 emissions. CDP's June 2024 report with Boston Consulting Group went further: in 2023, reported supply chain emissions were on average 26 times emissions from direct operations.
The same report explains the gap. The more than 23,000 companies disclosing to CDP in 2023 were twice as likely to measure operational emissions as supply chain emissions, and 2.4 times more likely to set a target for operations. Only 15 percent had a supply chain target. The upstream emissions of the manufacturing, retail and materials sectors alone were 1.4 times the EU's total CO2 in 2022, a carbon liability the authors priced above $335 billion at $75 a metric ton.
The World Economic Forum's 2021 Net-Zero Challenge report, written with BCG, found that eight supply chains, food, construction, fashion, fast-moving consumer goods, electronics, automotive, professional services and freight, account for more than 50 percent of global emissions. Around 40 percent of those emissions could be abated at under 10 euros a metric ton, and a net-zero supply chain would raise consumer prices by 1 to 4 percent at most. Food and freight are pallet businesses from end to end.
The meters you own measure the smallest part of the footprint you report.
Scope 3 Disclosure Rules: SB 253, CSRD and ISSB
Our post California Just Changed the Rules covered SB 253 and SB 261 when the first deadline was August 2026. Here is the state of play as of October 2026.
California SB 253 and SB 261
CARB's September 2025 preliminary list named roughly 4,160 entities that may fall under SB 253, SB 261 or both. CARB approved the SB 253 regulation on February 26, 2026, then deferred the first Scope 1 and 2 report from August 10 to November 10, 2026; Scope 3 begins in 2027. No assurance is required for 2026. Limited assurance on Scope 1 and 2 becomes required in 2027 and reasonable assurance in 2030, with a good-faith safe harbor for Scope 3, and CARB's preliminary fee estimate is $3,000 to $4,000 per entity.
The court case is the asterisk. On November 18, 2025 the Ninth Circuit enjoined SB 261 pending appeal and declined to do the same for SB 253. The appeal was argued January 9, 2026. As of October 2026 no ruling had been reported; late September compliance updates still showed the appeal pending and the SB 261 injunction in place. SB 253 is moving regardless.
| Rule | Who | What and when | Penalty |
|---|---|---|---|
| California SB 253 | Revenue over $1B, doing business in CA | Scope 1 and 2 due Nov 10, 2026; Scope 3 from 2027; limited assurance from 2027 | Up to $500,000 a year |
| California SB 261 | Revenue over $500M | Biennial climate-risk report; enforcement enjoined Nov 18, 2025 | Up to $50,000 a year |
| New York S9072A | Revenue over $1B, doing business in NY | Passed Senate Feb 10, 2026; Scope 1 and 2 from 2028, Scope 3 from 2029 | Up to $500,000 a year |
| EU CSRD after Omnibus I | Over 1,000 employees and EUR 450M turnover | Directive (EU) 2026/470, Feb 26, 2026; first reports on FY2027 | Set by member states |
| ISSB IFRS S2 | Set by each jurisdiction | 22 finalized jurisdictional profiles, 14 pending; 12 reporting from FY2025 | Set by each jurisdiction |
New York, Washington and Brussels
New York's S9072A passed the State Senate on February 10, 2026 and sits in Assembly committee, mirroring SB 253: revenue over $1 billion, Scope 1 and 2 from 2028, Scope 3 from 2029, penalties up to $100,000 a day capped at $500,000 a year. Washington went the other way: on May 29, 2026 the SEC proposed rescinding its 2024 climate disclosure rules, and the comment period closed August 3, 2026. The states did not wait for Washington.
Europe trimmed its rules and kept them. The Omnibus I Directive, Directive (EU) 2026/470, was published in the Official Journal on February 26, 2026. CSRD now applies to EU companies with more than 1,000 employees and net turnover above EUR 450 million, and to non-EU parents with more than EUR 450 million of EU turnover and an EU subsidiary or branch above EUR 200 million. A value chain cap limits what reporters can demand from partners under 1,000 employees.
The ISSB is the quiet one. The IFRS Foundation's September 2026 update lists 22 finalized jurisdictional profiles, 18 targeting full adoption of IFRS S1 and S2, plus 14 still finalizing, including Canada, China, Switzerland and the UK, with more than 45 jurisdictions moving to adopt. Twelve, among them Australia, the EU, Hong Kong and Singapore, have ISSB-based or ISSB-aligned requirements in effect from the 2025 reporting year, and IFRS S2 asks for Scope 3 by category.
Corporate Climate Target Statistics
Regulation is the floor; voluntary targets are where most large companies sit. The Science Based Targets initiative announced on January 22, 2026 that companies with validated science-based targets had passed 10,000. More than 2,800 were validated in 2025 alone, up from about 7,200 in early 2025 and roughly 4,200 in 2023. They represent more than 40 percent of global market capitalization across more than 90 countries, with Japan leading at over 2,000.
The detail that matters for suppliers is in the rules. SBTi requires targets to cover Scope 1 and 2, and for companies whose Scope 3 is more than 40 percent of the combined total, targets must cover Scope 3 as well, with at least 67 percent of Scope 3 inside the near-term target. Given CDP's 75 percent average, that clause catches nearly everyone. SBTi's dashboard in January 2026 showed 10,051 companies with validated targets and 12,647 with targets or commitments.
Translate that into procurement. Ten thousand companies have promised, in public and with a validator's stamp, to cut emissions they do not own, and the only way to do that is to ask suppliers for data, then for reductions. CDP alone requested disclosure from more than 45,000 suppliers in 2025. If you ship on pallets to any of those companies, their Scope 3 target is your sales requirement.
Packaging Waste and Landfill Statistics
Sustainable packaging starts with knowing what is in the waste stream. The EPA's most recent Facts and Figures year, 2018, remains the national baseline: 292.4 million tons of municipal solid waste, 32.1 percent recycled or composted, 11.8 percent combusted, and 50 percent, more than 146 million tons, landfilled.
Containers and packaging were the largest product category. The 53.9 percent recycling rate looks respectable until you split it by material. Plastic containers and packaging came to 14.5 million tons with a 13.6 percent recycling rate. Wood pallets and other wood packaging came to 11.5 million tons, and pallets are over 90 percent of that wood. EPA put wood pallet recycling at 3.1 million tons, chipped for mulch or bedding; 14.3 percent was combusted and the remaining 58.8 percent was landfilled.
Landfills received 12.2 million tons of wood in 2018, 8.3 percent of everything landfilled, and the wood keeps working against you once it is there. EPA reports that MSW landfills are the third-largest source of human-related methane in the United States, about 14.4 percent in 2022, that landfill gas is roughly 50 percent methane, and that methane traps at least 28 times as much heat as CO2 over 100 years. A pallet rotting in a landfill is a Category 5 or 12 entry that keeps emitting after you stopped counting. EPA counts tons with models; the pallet industry counts pallets at landfill gates, and tells a different story.
Wood Pallet Lumber and Recycling Statistics
Virginia Tech has surveyed the U.S. pallet industry with the U.S. Forest Service and the National Wooden Pallet and Container Association since the early 1990s; the latest survey, covering 2019 through 2021, went to 2,319 companies. In 2021 the industry produced an estimated 919 million new pallets, up from 513 million in 2016, plus 280 million repaired or remanufactured ones, against roughly 2.6 billion in circulation. Lumber use nearly doubled from about 9.1 billion board feet in 2016, and softwood's share climbed from 55 to 81 percent. Only 23 percent of the lumber was knowingly certified, and 48 percent of respondents did not know whether theirs was certified.
Not everyone agrees on the lumber volume. Fastmarkets, blending the Virginia Tech surveys with its own data, puts pallet lumber at 9.3 billion board feet in 2021, 11.0 billion in 2022 and an estimated 9.9 billion in 2025, with nearly 1 billion pallets produced in 2025. The figures on our Sustainability page come from the Virginia Tech survey.
How Many Pallets Actually Reach a Landfill
The wood industry's pallet recycling story is real and deserves a fair hearing. Virginia Tech's survey of municipal solid waste facilities, published in BioResources in 2021, found 13.1 million pallets landfilled at MSW facilities in 2016, over 90 percent fewer than the 138 million of 1998, with 15.9 million recovered or reused; including construction and demolition landfills, 25.39 million were landfilled against 178.5 million in 1998. The 2021 follow-up, published in 2024, found 76.8 million pallets, 8.4 percent of the new pallets built that year, reaching a landfill, 4 percent recovered into mulch and 4.4 percent buried, and put wooden pallets repaired, used for parts or converted into by-products at 95 to 97 percent.
Read those numbers the way an auditor would. Ninety-five percent recovery is a recycling statistic, not a reuse statistic: a pallet ground into mulch after five trips is recovered, and it still took new lumber to replace it. The Scope 3 exposure in wood is in Category 1, in the 919 million new pallets built every year. Our Scope 3 Exposure Calculator is built on that split; its default model attributes about 95 percent of a wood fleet's pallet-related Scope 3 to Category 1 manufacturing.
Why It Matters
The pallet industry recovers most of its wood and still builds more than 900 million new pallets a year from new lumber. For a Scope 3 inventory the second fact outweighs the first.
Recycled Plastic, HDPE and Circular Packaging Statistics
If wood's problem is volume, plastic's problem is reputation. EPA's 2018 data put plastics at 35.7 million tons of MSW, 12.2 percent of generation, with an 8.7 percent recycling rate and 27 million tons landfilled, 18.5 percent of everything landfilled. Bottles do far better: HDPE natural bottles, the milk-jug kind, were recycled at 29.3 percent and PET bottles at 29.1 percent. That bottle stream is the feedstock for recycled plastic pallets.
The case for recycled content is not sentimental. Franklin Associates' life cycle study for the Association of Plastic Recyclers, reported in January 2019, found that recycled HDPE in place of virgin cuts greenhouse gas emissions by 71 percent and energy use by 88 percent. The 2024 U.S. Post-Consumer Plastic Recycling Study from APR and the U.S. Plastics Pact counted at least 5.1 billion pounds of post-consumer plastic recovered in 2024, 2.3 percent more than in 2022, though PET and HDPE bottle collection fell by 89.3 million pounds over those two years. Recycled HDPE is finite, so the pallets built from it belong in a closed loop.
What the Life Cycle Studies Actually Say
We will be fair here, because the pallet LCA literature is fair to nobody. A 2019 review in Sustainability by Deviatkin and colleagues examined 16 studies covering 43 pallets, 32 of them wooden, and concluded that a trip-based functional unit is the right way to compare pallets and that the underlying data varied significantly. A virgin-resin pallet that leaks out after 20 trips does not beat wood. A 100 percent recycled HDPE pallet that runs 100 to 200-plus trips and is ground back into the next pallet is a different object. Our Why Plastic page lays that out trip by trip. Reuse rules now say the same thing in law: the EU's Regulation (EU) 2025/40, applying since August 12, 2026, requires at least 40 percent of transport packaging, pallets included, to be reusable from 2030.
This is the circularity we built APS around. Every APS pallet is 100 percent recycled HDPE, post-consumer and post-industrial, as we described in Milk Jugs, Snowboards, and Shampoo Bottles. Our manufacturing partner processes roughly 60 million pounds of recycled plastic a year. The pallets run roughly 100 to 200-plus trips, against about 3 to 5 for white wood and about 15 for pooled hardwood, and at end of life they come back to us, get shredded, and go into the next one. HDPE doesn't retire. It changes jobs.
What the Numbers Mean for a Supply Chain Leader
Here is what we would tell a VP of supply chain who has to sign a Scope 3 number in 2027.
- Know Your Categories Map every pallet flow to its Scope 3 category before anyone estimates. Purchased pallets are Category 1, freight is 4 and 9, disposal is 5 or 12, and a leased fleet is Category 8 for you and 13 for the lessor.
- Count Trips, Not Pallets A pallet that makes 5 trips and one that makes 150 are not the same purchase. Your Category 1 line is the number of pallets you buy.
- Measured Beats Estimated Industry-average emission factors pass a good-faith first filing. They get harder to defend as assurance tightens in 2027 and 2030.
- Expect the Questionnaire Ten thousand companies hold validated targets that mostly must cover Scope 3, and CDP asked 45,000 suppliers for data in 2025. You will be asked for your pallet footprint.
Here is where we think sustainable pallets fit. The pallet is present at every point in your chain, and for most companies it contributes an industry-average emission factor and nothing else. An APS pallet is a 100 percent recycled HDPE platform whose manufacturing emissions sit in our Category 13 rather than your Category 1, up to 30 percent lighter than wood, roughly 2,200 pounds less per truckload and 1 to 2 percent lower fuel use per trip on your Category 4 and 9 lines, with an embedded cellular sensor module built in rather than bolted on. Pulse logs timestamped, geolocated events on an exception basis, the raw material for a measured transport number instead of an estimated one. It is designed to price at or below your wood pallet program, in one flat monthly lease; our Sustainability page has the lifecycle comparison.
Scope 3 is going to be disclosed, assured and compared whether the data is good or not. The companies with a defensible number at the end of this decade will be the ones that started measuring where the goods move. The pallet has been there the whole time. It is finally worth listening to.
Sources
- GHG Protocol, “Corporate Value Chain (Scope 3) Accounting and Reporting Standard,” 2011
- GHG Protocol, “Scope 3 and Product Standards FAQ,” 2011
- CDP, “Technical Note: Relevance of Scope 3 Categories by Sector,” v3.0, 2024
- CDP and BCG, “Corporates’ Supply Chain Scope 3 Emissions Are 26 Times Higher Than Their Operational Emissions,” 2024
- CDP, “Supply Chain,” 2025
- World Economic Forum and BCG, “Net-Zero Challenge: The Supply Chain Opportunity,” 2021
- California Air Resources Board, “California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Programs,” 2026
- Davis Polk, “CARB Defers Initial SB 253 Reporting Deadline from August 10 to November 10,” 2026
- Sidley Austin, “SB 253 Update: CARB Delays Reporting Deadline to November 2026,” 2026
- Cooley, “Ninth Circuit Stays SB 261 as CARB Announces First-Year Expectations,” 2025
- Foley & Lardner, “Ninth Circuit Hears Oral Argument in Challenge to SB 261 and SB 253; No Ruling Yet,” 2026
- Persefoni, “California SB 253 and SB 261: What Businesses Need to Know,” 2026
- Good Lab, “California Climate Disclosure Updates from CARB,” September 2026
- Obsidian Regulatory Intelligence, “CARB SB 253 Reporting Guidance Ahead of Nov 10 Deadline,” 2026
- New York State Senate, “S9072A, Climate Corporate Data Accountability Act,” 2026
- DLA Piper, “SEC Published a Proposal to Formally Rescind Its 2024 Climate-Related Disclosure Rules,” 2026
- Covington & Burling, “EU CSDDD/CSRD Omnibus Published in Official Journal,” 2026
- Latham & Watkins, “EU Sustainability Omnibus Published in the Official Journal,” 2026
- IFRS Foundation, “Adoption of IFRS Sustainability Disclosure Standards,” World Standard-setters Conference, September 2026
- ESG Today, “SBTi Passes 10,000 Companies with Validated Science-Based Climate Targets,” 2026
- ESG Dive, “Companies with Validated Science-Based Climate Targets Hit 10,000,” 2026
- Science Based Targets initiative, “FAQs,” 2026
- U.S. EPA, “National Overview: Facts and Figures on Materials, Wastes and Recycling,” 2018 data
- U.S. EPA, “Containers and Packaging: Product-Specific Data,” 2018 data
- U.S. EPA, “Wood: Material-Specific Data,” 2018 data
- U.S. EPA, “Plastics: Material-Specific Data,” 2018 data
- U.S. EPA Landfill Methane Outreach Program, “Basic Information about Landfill Gas,” 2024
- Hobbs, S., Virginia Tech, “Investigation of New and Recovered Wood Shipping Platforms in the United States,” 2023
- Fastmarkets, “US Pallet Market: Trends and Future Projections,” 2026
- Shiner, Horvath, Araman and Gething, “An Investigation of Wood Pallets Landfilled and Recovered at US Municipal Solid Waste Facilities,” BioResources 16(1), 2021
- Pallet Enterprise, “Landfill Survey Proves Positive Recycling Story for Wood Pallets,” 2018
- Mansharamani, Y., Virginia Tech, “Investigation into the Landfilling and Recovery of Wood and Wooden Pallets at U.S. Landfills in 2021,” 2024
- Waste Dive, “APR: Recycled Plastics Reduce Energy Consumption, GHG Emissions,” on Franklin Associates’ “Life Cycle Impacts for Postconsumer Recycled Resins: PET, HDPE, and PP,” 2019
- Waste Dive, “Bottle Recycling Rates Dropped in 2024,” on the APR and U.S. Plastics Pact 2024 U.S. Post-Consumer Plastic Recycling Study, 2026
- Deviatkin, Khan, Ernst and Horttanainen, “Wooden and Plastic Pallets: A Review of Life Cycle Assessment (LCA) Studies,” Sustainability 11(20), 2019
- Trans.info, “PPWR Puts Pallets Under Stricter Reuse Rules,” on Regulation (EU) 2025/40, 2026
FAQ
What Are Scope 3 Emissions?
Scope 3 emissions are all the indirect greenhouse gas emissions in a company's value chain not already counted in Scope 2, from purchased goods and inbound freight to outbound freight, product use and end of life. The GHG Protocol splits them into 15 categories, and CDP finds they average about 75 percent of a company's total emissions.
What Is the Difference Between Scope 1, Scope 2 and Scope 3 Emissions?
Scope 1 is direct emissions from sources a company owns or controls, such as boilers and vehicles. Scope 2 is indirect emissions from purchased electricity, steam, heat or cooling. Scope 3 is every other indirect emission in the value chain, from the lumber in a purchased pallet to a contracted carrier's diesel, and it depends on other companies' data.
Are Plastic Pallets More Sustainable Than Wood Pallets?
It depends on the resin, the number of trips and the end of life, which is why the life cycle literature compares pallets per trip. A virgin-resin pallet lost after a few trips does not beat wood. A 100 percent recycled HDPE pallet, with about 71 percent lower emissions than virgin HDPE, that runs 100 to 200-plus trips in a closed loop avoids the repeated Category 1 purchases of new lumber. See Why Plastic for the trip-by-trip comparison.
When Does California SB 253 Require Scope 3 Reporting?
Scope 3 reporting under SB 253 begins in 2027, a year after the first Scope 1 and 2 reports due November 10, 2026. Companies with revenue above $1 billion doing business in California are covered, limited assurance on Scope 1 and 2 starts in 2027 and reasonable assurance in 2030, Scope 3 has a good-faith safe harbor, and penalties can reach $500,000 a year.
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