Packaging Printers' "Dual Carbon" Goal: Real Boundaries of Scope 1/2/3 Data Collection — The Untold Struggles of Small and Mid-Sized Printers When Clients Demand Carbon Reports

Under the "Dual Carbon" goal, an increasing number of brand clients (especially European and American ones) require printers to provide carbon emission data. However, the real boundaries of collecting the three types of data — Scope 1 (direct emissions), Scope 2 (indirect emissions from electricity), and Scope 3 (supply chain emissions) — make it virtually impossible for small and mid-sized printers to deliver. It is not that printers refuse to comply; the cost and difficulty of data collection far exceed expectations. This article clarifies the collection difficulty for each scope, what data clients actually demand, and how printers should respond.

Definitions and Numbers for the Three Scopes

Carbon emission data is divided into three categories under the GHG Protocol:

• Scope 1 (Direct Emissions): Carbon emissions directly produced by facilities, equipment, and vehicles owned by the printer. Typical sources: gas boilers, diesel generators, and the printer's own delivery trucks.
• Scope 2 (Indirect Emissions from Electricity): Carbon emissions from electricity and heat purchased by the printer. Typical sources: production electricity, air conditioning, and lighting.
• Scope 3 (Supply Chain Emissions): Carbon emissions generated across the printer's upstream and downstream supply chain. Typical sources: raw material procurement (paper, ink, adhesives), logistics transportation, employee commuting, and waste disposal.

The numerical share of the three scopes (taking a small or mid-sized printer with an annual output value of 50 million RMB as an example): Scope 1 accounts for 5-15%, Scope 2 accounts for 15-30%, and Scope 3 accounts for 60-75%. In other words, the bulk of carbon emissions lies in the supply chain — not within the printer's direct control.

Scope 1 Data — Printers Can Capture It All, but at a Non-Trivial Cost

Theoretically, printers can capture 100% of Scope 1 data because it involves their own facilities. Three real boundaries:

1. Boundary 1: Gas/diesel consumption of gas boilers and diesel generators. Printers usually keep monthly logs, which can be checked directly. However, some printers do not maintain monthly records and need to backfill them — this takes 2-4 weeks.
2. Boundary 2: Diesel consumption of the printer's own delivery trucks. Printers usually have fuel purchase records, but the truck mileage specifically tied to "printer delivery" needs separate accounting — a 3-5% margin of error is unavoidable.
3. Boundary 3: Refrigerant (AC coolant) fugitive emissions. 80% of printers do not record this at all, because fugitive coolant volumes are small and management is loose. Yet the GHG Protocol mandates that it be included. Backfilling this item requires hiring a specialized agency, costing 20,000-30,000 RMB.

Real Case: A Brand Required Scope 1 Data, and It Took a Printer 2 Months to Compile

In November 2024, a brand client in Shanghai asked a printer to provide Scope 1 data (carbon footprint report). The printer owner thought it was straightforward and would be done in 2 weeks. It turned out that: ① the gas boiler had no monthly log; ② self-owned truck mileage was unrecorded; ③ AC coolant fugitive emissions had zero data. In the end, the printer spent 2 months backfilling logs, hiring a third-party agency to measure coolant, and installing GPS on trucks, with direct costs of 58,000 RMB.

Lesson: Theoretically, printers can capture all Scope 1 data, but in practice, "backfilling historical data" takes 2-3 months, with direct costs of 30,000-60,000 RMB. Before accepting orders requiring Scope 1 data, small and mid-sized printers should factor this cost into their quotations.

Scope 2 Data — Printers Can Calculate It, but Numbers Are Usually Overestimated

Scope 2 data covers the carbon emissions from electricity purchased by the printer, sourced from utility bills. Three real boundaries:

1. Boundary 1: Production electricity, domestic electricity, and air conditioning electricity must be separated. Printers typically only have a total electricity bill, with production and domestic usage unseparated. This affects Scope 2 attribution — production electricity belongs to the printer; domestic electricity belongs to employees.
2. Boundary 2: Electricity carbon emission factors are dynamic. Since 2021, China's electricity carbon emission factor dropped from 0.58 kg CO₂/kWh to 0.55, and the figure varies by province (Inner Mongolia 0.75, Sichuan 0.40). Using the wrong factor can cause a 20-30% deviation in the data.
3. Boundary 3: Impact of green electricity procurement. If the printer purchases green electricity (wind, solar, hydro), Scope 2 data can be deducted — but green electricity purchase certificates must be provided. 90% of small and mid-sized printers do not purchase green electricity.

Real Case: A Brand Used the Wrong Emission Factor, Resulting in a 30% Deviation in Scope 2 Data

In March 2025, a printer in Zhejiang calculated Scope 2 data for a brand client using the national uniform factor of 0.58 kg CO₂/kWh. The client questioned the result upon receipt, because Zhejiang's actual factor in 2024 was 0.45 (high hydro share). The client demanded recalculation using 0.45, dropping the printer's Scope 2 figure from 850 tons to 660 tons — the client accepted, but the printer spent 2 weeks recalculating, with engineer costs of about 15,000 RMB.

Lesson: Scope 2 data must use the carbon emission factor for the "target province + current year," not a national uniform factor. Printers can subscribe to the Ministry of Ecology and Environment's national standard factor table or engage a third-party agency for calculation.

Scope 3 Data — Printers Essentially Cannot Capture It and Can Only Estimate

Scope 3 data covers supply chain emissions. Printers essentially cannot capture real data and can only estimate. Three real boundaries:

1. Boundary 1: Supplier emission data for raw material procurement (paper, ink, adhesives). 90% of printers' suppliers do not disclose Scope 1+2 data, let alone Scope 3. Printers can only estimate based on "industry averages" — with 30-50% error margins.
2. Boundary 2: Distance and mode of logistics transportation (inbound raw materials, outbound products). Printers have order data and can calculate distances. But "secondary transportation from one client to another" is typically unavailable to the printer, and can only be estimated based on "average logistics distance" — with 20-40% error margins.
3. Boundary 3: Employee commuting and waste disposal. Printers essentially have no employee commuting data and can only estimate based on "number of employees × average commuting distance." Waste disposal is essentially estimated as "hazardous waste weight × industry average emission factor." Error margins exceed 50%.

Real Case: A Brand Required Scope 3 Data, and the Printer's Report Was Rejected

In May 2025, a brand client in Shenzhen asked a printer to provide Scope 3 data. The printer owner commissioned a third-party agency to produce the report, but 70% of the report was estimation. After review, the client rejected it on the grounds of "lack of data verifiability." The client eventually abandoned that printer and transferred the order to a large-scale printer.

Lesson: Scope 3 data can essentially only be estimated by printers. If clients require "verifiable Scope 3 data," small and mid-sized printers are largely unable to deliver — this is a physical boundary, not a question of printer capability. Before accepting orders requiring Scope 3 data, small and mid-sized printers must first align with clients: "Is estimation acceptable? Is a 30-50% estimation error margin acceptable?" Do not wait until report delivery to announce that "the data is estimated."

3 Questions Printers Must Ask When Clients Demand a "Carbon Footprint Report"

1. Question 1: Scope 1+2 or Scope 1+2+3? If only Scope 1+2 is needed, printers can typically capture it all for 30,000-50,000 RMB; if Scope 3 is needed, printers can only estimate, and clients must accept a 30-50% error margin.
2. Question 2: Verifiable data or estimates? If verifiable data is required, printers must commission a third-party agency (SGS, TÜV, CTI) for certification, costing 50,000-150,000 RMB; if estimates are acceptable, printers can do it in-house for 20,000-30,000 RMB.
3. Question 3: Which standard governs the report format? ISO 14067, PAS 2050, and GHG Protocol all have different report formats. Printers must clarify which one the client requires.

3 Strategies for Printers Responding to "Dual Carbon" Orders

1. Strategy 1: Markup. The direct cost of a carbon footprint report ranges from 30,000 to 150,000 RMB. Printers should add a 5-10% markup to the order to cover this cost. If clients refuse the markup, printers should decline the order — carbon footprint work requires heavy investment with limited returns and is not worth doing at a loss.
2. Strategy 2: Phased approach. Phase 1 covers only Scope 1+2 (fully capturable by the printer); Phase 2 expands to Scope 3 (estimation). If clients accept the phased approach, printer pressure is significantly reduced.
3. Strategy 3: Partner with third-party agencies. Small and mid-sized printers can team up with several peers to share a third-party consulting service and split the cost. For example, 5 printers sharing one SGS consultant can reduce individual costs from 100,000 RMB to 30,000-40,000 RMB.

The "Dual Carbon" goal is a major trend, but it is unreasonable to expect small and mid-sized printers to shoulder the full Scope 1+2+3 data set right now. Printers are advised to align with clients on data scope, verifiability, and report format before accepting carbon report orders — do not assume "if the client asks, we deliver," because a complete carbon report can cost 30,000-150,000 RMB, and this cost must be borne by someone.

Further Reading

• 3 Methods for Carbon Emission Accounting in Packaging Enterprises: ISO 14064 / GHG Protocol / National Standard GB/T 51316
• 3 Real Data Boundaries in Packaging Printing Carbon Footprint: The Untold Struggles of Scope 1/2/3 for Small and Mid-Sized Printers
• 3 Hard Metrics for VOC Treatment in Packaging Printing
• Interpretation of 5 Latest Regulations in the Packaging Printing Industry