ESG reporting for the practical packaging manager

In 2023 and 2024, the number of customers asking us for ESG-reporting data went from "a few each quarter" to "about one a week." The questions vary — annual diversion percentage, embodied carbon per box, chain-of-custody, recycled content. This post is the crash course we wish someone had given us when we started compiling answers.

Scope 3 and packaging

Scope 3 emissions are the indirect emissions in a company's value chain — including the materials going into and out of the company. Packaging falls squarely in Scope 3. The emissions of producing a new gaylord are upstream. The emissions of disposing of a used one are downstream. Both count.

Embodied carbon per box

The number we use for a new 40×48×36 double-wall gaylord is 7.2 lbs CO₂ equivalent. That's drawn from the U.S. EPA's WARM model plus the average transport from a Midwest mill to a Midwest customer. It's a defensible mid-range number, and we cite it on every customer-facing report.

For a reused gaylord, the upstream emissions are zero (they were already counted when the box was new). The transport-to-second-use emissions are real but small — typically 0.4–0.9 lbs per box per cycle.

Diversion rate

The diversion rate is the percentage of inbound material that leaves a facility reused or recycled, rather than landfilled or incinerated. Ours has been audited at 94.1% for 2024. We publish it annually because we'd rather have a third party verify the number than have our marketing department invent one.

If your CFO is asking for a diversion percentage on your packaging stream, you can pull it from your packaging vendor — assuming your vendor has one. If your vendor doesn't, you have a vendor problem.

Chain of custody

Forest Stewardship Council (FSC) and Sustainable Forestry Initiative (SFI) chain-of-custody certifications verify that the paper in your packaging came from sustainably managed forests. Not every customer needs this. Customers in regulated industries (food, pharma) almost always do.

If you're being asked for chain-of-custody documentation and your vendor doesn't have it, ask for the alternative — an EPA-aligned waste manifest with the receiving mill's name on it. That's a partial substitute that satisfies a lot of corporate ESG questionnaires.

What to ask your vendor

1. What's the embodied carbon of a new unit, and what's your source?
2. What's the avoided carbon of a reused unit, and how do you avoid double-counting?
3. What's your audited diversion rate?
4. Can you provide chain-of-custody on request?
5. Will the recycling stream be domestic, and can you prove it?

What to publish

Whatever you publish, document the assumptions. "Saves 50,000 tons of CO₂" with no source is greenwash. "Saves an estimated 50,000 tons of CO₂ based on EPA WARM model embodied carbon and our audited 2024 reuse rate" is reporting. The difference is two clauses and a citation, and it's the difference between credible and not.