Carbon Emission Accounting for Packaging Printers: 3 Scope Boundaries and 4 Response Paths When Clients Ask for Scope 3 Data

A packaging printer in Wuxi that does export business was asked last year by a German client: "What is the Scope 3 carbon emission of your packaging boxes? Our ESG report needs the printer to provide carbon footprint data for upstream raw materials (paper, ink, adhesive)."

The printer boss spent half a day researching, then roughly calculated a version of data using the ISO 14067 method and sent it over. Two months later, when the German client's ESG auditor arrived, they found that in the printer's Scope 3 data: the paper portion used the Chinese paper mill industry average (0.93 tCO₂e per ton of paper), but this data was based on an old 2022 version; the ink portion used numbers from a supplier brochure without third-party verification; the adhesive portion directly borrowed a European similar product figure. The auditor ultimately judged the Scope 3 data "unreliable," demanded resubmission—and suspended this printer's supplier qualification.

This was not a case of "the printer producing poor data," but rather "the printer fundamentally not knowing to what extent Scope 3 should be calculated." These are the 3 boundary pitfalls printers most easily fall into when doing carbon emission accounting.

Boundary 1: Scope 1 Direct Emissions—3 Emission Sources Printers Can Calculate but Easily Underestimate

Scope 1 direct emissions are emission sources owned or controlled by the enterprise. For printers, these are mainly:

• Natural gas combustion—RTO burners, workshop heating, boilers
• Gasoline/diesel combustion—in-plant forklifts, generators, delivery vehicles
• Refrigerant leakage—print shop air conditioning, refrigeration equipment
• Solvent volatilization—organic solvent evaporation during printing, lamination, coating processes

Printers most easily underestimate "solvent volatilization." Reason: many printers believe that because solvent has been treated by RTO, the emissions after treatment fall under Scope 1 direct emissions—this is actually incorrect. Scope 1 "direct emissions" refers to emission sources owned by the enterprise—the stack emissions after RTO treatment do belong to the printer's own Scope 1. But the prior process—solvent volatilizing from the printing press, transferring to the workshop, then being captured by RTO—is also Scope 1 direct emissions (fugitive emissions).

When printers actually calculate Scope 1, the formula is: solvent consumption − RTO removal = fugitive emissions. For example: if a printer uses 8 tons of ink solvent per month with an RTO removal rate of 98%, then fugitive emissions are 0.16 tons of solvent, equivalent to 0.16 × 2.5 = 0.4 tCO₂e (solvent converted based on xylene density and carbon content). This figure must be counted into Scope 1.

Many printer bosses only count natural gas and gasoline when calculating Scope 1, overlooking refrigerant leakage (Freon GWP is 1300-2300 times that of CO₂) and solvent fugitives—resulting in Scope 1 data being understated by 30-50%.

Boundary 2: Scope 2 Electricity/Heat Indirect Emissions—3 Calculation Methods Yield Numbers Differing by 60%

Scope 2 refers to indirect emissions from purchased electricity, heat, and steam. For printers, this is mainly purchased electricity.

When printers calculate Scope 2, the 3 calculation methods yield dramatically different results:

• Location-based—uses the average emission factor of the regional grid where the enterprise is located. Data published by China's NDRC in 2024: Jiangsu grid 0.5879 kgCO₂e/kWh
• Market-based—uses the emission factor of the electricity the enterprise actually purchases. If the printer buys green electricity (with green certificates), the factor is 0; if it buys thermal power, the factor is the grid average
• Supplier-specific—uses the actual emission factor of the power plant. China currently mainly uses the first two

For the Wuxi printer located in the Jiangsu grid, the 2024 Location-based figure is 0.5879 kgCO₂e/kWh. If calculated using Market-based—the printer did not buy green electricity and uses grid electricity—the result is the same 0.5879. But European clients prefer Market-based and will ask "Did you purchase renewable energy?" If the printer answers "no," the Scope 2 data is the grid average; if "yes," the Scope 2 data is 0.

Common mistakes when printer bosses calculate Scope 2:

• Using the wrong grid factor—applying the 2019 old factor (around 0.7) to 2026, causing inflated data
• Not distinguishing between Location-based and Market-based—reporting Location-based data when the client asks for Market-based
• Ignoring self-generated and self-used electricity—electricity generated by the printer's rooftop PV should be deducted from purchased electricity

It is recommended that printers report both numbers in the ESG report, letting the client choose.

Boundary 3: Scope 3 Value Chain Emissions—4 Response Paths for "Whether to Calculate" and "To What Extent to Calculate"

Scope 3 includes 15 categories of value chain emissions. The categories relevant to printers are mainly:

• Category 1—Purchased goods (paper, ink, adhesive, auxiliary materials)
• Category 4—Upstream transportation (raw material inbound logistics)
• Category 9—Downstream transportation (finished products delivered to customer)
• Category 11—Product use phase (packaging box itself being used/discarded by consumer)
• Category 12—End-of-life treatment (packaging box being recycled/incinerated/landfilled)

When printers are asked by clients "Can you provide Scope 3 data," there are 4 response paths:

Path 1: Refuse to provide—highest risk but compliant

Printers have legitimate reasons to refuse: Scope 3 is not the printer's own direct responsibility but indirect emissions across the value chain. Printers cannot independently account for Scope 3 because upstream data (paper carbon footprint) is held by suppliers.

But printers that refuse may be removed from client supplier lists—a German client removed 12 "refused to provide Scope 3 data" printers from their qualified supplier list last year.

Path 2: Report industry average data—easy but prone to trouble

Printers use industry association or industry database (Ecoinvent, CEENE) "average printing and packaging industry Scope 3" data to fill in reports. This was the path taken by the Wuxi printer, and the auditor judged the data "unreliable."

The problem with industry average data is—it represents "industry average level," not "your printer's actual level." When the client uses your data in their ESG report, they will disclose externally based on "printer's actual level." If your actual level is far higher than the industry average (using high-carbon paper/solvent), it constitutes "greenwashing" risk.

Path 3: Have suppliers provide data—most compliant but hardest to drive

Printers require upstream suppliers (paper mills, ink manufacturers) to provide actual Scope 3 Category 1 data. If suppliers have their own carbon footprint reports (PCR) or Environmental Product Declarations (EPD), use them directly; if not, have suppliers conduct LCA (Life Cycle Assessment).

This path is the most compliant, but supplier cooperation is low—many small and medium paper mills and ink manufacturers have no LCA data. Printers may not obtain data after 3 months of effort.

Path 4: Report actual consumption × industry factors—the most feasible compromise path for printers currently

Printers collect their own actual data:

• How many tons of paper used per year (broken down by supplier and paper type)
• How many tons of ink used per year (broken down by ink type)
• How many tons of adhesive used per year (broken down by adhesive type)
• Ton-kilometers for upstream and downstream transportation (according to data provided by logistics companies)

Then multiply actual consumption by "industry average factors" from public databases such as Ecoinvent, CEENE, and IPCC. Under this approach:

• The data is the printer's "own" (not someone else's average level)
• The factor uses industry averages (not precise to supplier)
• It is considered "medium credibility" by auditors—acceptable but requires "gradual replacement with supplier-specific factors within 3 years"

This is the compromise path currently taken by 70% of printers. It is recommended that printers use Path 4, and clearly annotate in the ESG report "data based on actual consumption × industry average factors."

3 Verification Checklists for Printers Responding to Scope 3 Inquiries

First checklist: Verify 3 things when the client inquires

1. Does the client want "printer-level Scope 3" or "Product Carbon Footprint (PCF)"? The former is calculated by the printer, the latter must be calculated per order
2. Which Scope 3 category does the client want? Category 1 (raw materials), Category 9 (downstream transport), or Category 11 (product use)?
3. Does the client accept compromise data "based on industry average factors"? Or must it be exact numbers?

Second checklist: Verify 3 types of basic data when preparing data

1. Scope 1—natural gas consumption, gasoline/diesel consumption, refrigerant charging volume, solvent consumption
2. Scope 2—purchased electricity (distinguishing whether green electricity), purchased heat
3. Scope 3—paper/ink/adhesive/auxiliary material consumption + upstream/downstream transportation ton-kilometers

Third checklist: Verify 3 types of compliance when reporting data

1. Has Location-based and Market-based Scope 2 been distinguished?
2. Does Scope 3 annotation include data source (actual consumption × industry factor / supplier data)?
3. Has raw data + calculation formulas + factor sources been retained for at least 5 years?

Further Reading

• 3 Carbon Emission Accounting Methods for Packaging Enterprises
• 3 Real Data Boundaries in Packaging Printing Carbon Footprint
• How Printers Should Handle First CBAM Carbon Tariff Client Inquiries in 2026
• 3 Mandatory Disclosure Calibers in Printer ESG Reports