California’s climate disclosure laws—SB 253 and SB 261—are changing the rules for cannabis beverage brands, co-packers, and packaging suppliers. In 2025, the pressure to comply with these new mandates is cascading down the value chain well before direct reporting deadlines, as major retailers and multi-state operators seek supplier data to safeguard their own climate risk disclosures. For cannabis beverage producers—especially those using aluminum cans, PET bottles, closures, and cold-chain logistics—the ability to quantify and reduce Scope 3 emissions is fast becoming a competitive necessity.
Overview: Why Cannabis Climate Disclosure Matters Now
Climate policy is no longer just a headline or investor concern. Under SB 253 (the Climate Corporate Data Accountability Act) and SB 261 (the Climate-Related Financial Risk Act), California is imposing mandatory reporting of greenhouse gas emissions (including Scope 3/supply chain emissions) and climate risk management for large companies. These laws represent the first such mandatory requirements in the United States, with wide-ranging impacts even outside California’s borders.
Who Must Comply?
- SB 253 applies to U.S.-based companies with over $1 billion in annual revenue operating in California. It mandates annual disclosure of Scope 1, 2, and (eventually) Scope 3 greenhouse gas (GHG) emissions.
- SB 261 covers U.S.-based companies with over $500 million in annual revenue doing business in California. It requires biennial reporting on climate-related financial risks and governance strategies.
While smaller cannabis brands, manufacturers, and packaging suppliers may not reach these thresholds themselves, they will nonetheless be drawn into the compliance web as major buyers and brands seek emissions and risk data throughout their supply chains.
Timelines: When Do These Rules Take Effect?
- January 1, 2026: First climate risk disclosures due under SB 261 (covering 2025 data).
- June 30, 2026: First Scope 1 and 2 emissions reports due under SB 253 (covering 2025 operations).
- 2027: First Scope 3 (value-chain) emissions reports due under SB 253 (based on 2026 data).
For more details, see the California Air Resources Board’s guidance. Also, review advice from Persefoni and Optera Climate.
Cannabis Climate Disclosure SB 253 261: Key Compliance Expectations
The Scope 3 Challenge: Packaging and Upstream Impacts
Scope 3 includes all indirect emissions in the value chain—including those generated by material suppliers, packaging vendors, ingredient growers, co-packers, and transportation partners. For cannabis drink makers, this means detailed GHG reporting on:
- Primary packaging (aluminum, PET, glass, closures, labels)
- Secondary packaging (cartons, trays, shrink wrap, pallets)
- Cold-chain transportation
- Upstream cultivation and cannabinoid extraction
- Retail logistics and product end-of-life (recycling/disposal)
Major cannabis MSOs and beverage marketers are already requesting GHG data and climate risk plans from contract manufacturers, co-packers, and even small-batch suppliers beginning in 2025, well ahead of the mandatory filings. If you manufacture or package infused drinks—even as a California-based supplier to out-of-state brands—you are likely to be drawn into these reporting flows.
Assurance and Third-Party Verification
- Scope 1 & 2 Emissions: Must be assured by an independent party according to standards established by the California Air Resources Board (CARB) starting right away.
- Scope 3 Emissions: Reasonable assurance will phase in by 2030, with limited assurance (less stringent) required sooner. Still, best practice in 2025 is to obtain independent verification or supplier declarations for high-impact categories like beverage packaging and cold-chain logistics.
Data Quality: Primary Data vs. Estimates
- Brands and MSOs are expected to collect primary GHG data from material and logistics suppliers—not just use industry averages.
- For THC beverage packaging, expect a focus on can and bottle suppliers’ own manufacturing footprint, recycled content, and energy sourcing.
Global Packaging Trends Impacting California Cannabis Beverages
The EU’s Packaging and Packaging Waste Regulation (PPWR) is pushing for radical reductions in plastic waste and carbon footprints across all consumer goods—including cannabis drinks. Companies shipping to both the EU and California will increasingly align specs to meet overlapping requirements.
California is also moving to restrict PFAS (per- and polyfluoroalkyl substances) in food and beverage packaging, affecting can linings, shrink sleeves, and closures. These restrictions may force a pivot to alternative coatings or materials, reshaping the GHG footprint of beverage products.
Extended Producer Responsibility (EPR)
California’s SB 54 creates an EPR program for packaging, mandating reductions in single-use plastics and increases in recyclable content. This could further pressure beverage brands and co-packers to document packaging reductions and changes for both climate and EPR compliance.
How to Prepare: GHG Inventory and Supplier Starter Kit
1. Define GHG Inventory Boundaries
- Map your entire product life cycle: seed to shelf.
- Focus on “hotspot” GHG sources: Primary packaging (by weight and material), co-packing operations, energy use, and logistics.
- Remember to include refrigeration emissions (coolers, transport) and disposal fate.
2. Collect Primary Supplier Data
- Request GHG inventory declarations from can/bottle/closure suppliers. Ask for facility-level and process data (energy use, recycled content, transport modes).
- Work with upstream partners (co-packers, cultivators) to gather energy and material usage data.
- Prioritize high-impact vendors for deeper data engagement—start with those providing the most aluminum, PET, or glass packaging.
3. Document and Screen for PFAS, Sustainability, and EPR Compliance
- Require material spec sheets with PFAS status and recycled content reported.
- Ask suppliers about their own EPR or climate disclosure preparations.
- Prepare to swap in new materials if laws change or PFAS bans take effect.
4. Scenarios: Adjust Packaging to Lower Scope 3
- Increase PCR (post-consumer recycled) content: Both CA and EU regulators reward higher PCR content with lower reported emissions.
- Switch from shrink sleeves to direct print where possible: Shrink sleeves can render otherwise recyclable cans or bottles non-recyclable.
- Optimize package sizes and shipping: Minimizing empty space and using lighter packs reduces both emissions and costs.
- Phase out PFAS linings: Anticipate regulatory shifts, as alternatives may have different GHG profiles.
For Cannabis Brands, Co-Packers, and Packaging Suppliers: Takeaways
- Act now: Even if you’re not directly above the revenue threshold for SB 253/261, climate disclosure pressure is rapidly moving down the supply chain as brands and buyers prepare for their own reporting.
- Start with your packaging specs and data: This is often the biggest—and most actionable—Scope 3 hotspot for cannabis drinks.
- Align with emerging global standards: EU regulations, California EPR, and PFAS restrictions are converging—futureproof your products with recyclable, low-emission, and PFAS-free packaging.
- Document everything: For GHG claims and compliance, robust documentation from suppliers (and periodic third-party review) is your best defense.
Need step-by-step support for cannabis climate disclosure SB 253 261, GHG inventory, or packaging compliance? Explore resources, tools, and compliance solutions at CannabisRegulations.ai. Stay ahead—make climate, packaging, and regulatory due diligence part of your competitive advantage.
