Picture a dairy processor or ingredients company with more than $1 billion in revenue and a warehouse, sales team or customers in California. By 10 November 2026 it files its first Scope 1 and 2 report with the California Air Resources Board (CARB). From 2027, CARB's proposal adds Scope 3 purchased goods and services: the category that holds farm, feed and ingredient emissions.
This post covers what SB 253 requires today, what CARB has proposed for 2027, and what CARB staff told food and agriculture companies at their sector listening session on 21 August 2026. Facts come from CARB documents and sessions.
Updated 19 October 2026.
SB 253 at a glance
- Who reports: US-formed public and private companies with total annual revenue above $1 billion that do business in California.
- First deadline: 10 November 2026, for Scope 1 and 2 emissions from the preceding fiscal year. CARB's Initial Regulation is final and sets this date.
- How to file: through CARB's 2026 intake platform or by email to climatedisclosure@arb.ca.gov. CARB's 2026 reporting template is voluntary.
- Assurance in 2026: CARB accepts first-cycle reports with or without assurance.
- First-year enforcement: CARB applies enforcement discretion to the first report. Companies with no data collection under way when CARB issued its December 2024 enforcement notice can file a statement of non-reporting on company letterhead.
- Scope 3: required from 2027 under the statute. CARB is writing the detailed 2027 rule now.
- SB 261 (climate risk reports, $500 million revenue threshold): CARB has paused enforcement while a court injunction is in place.
For thresholds, penalties and the full timeline, see our SB 253 explainer.
What CARB has proposed for 2027
CARB presented these concepts at its July 2026 public workshop. They are proposals: CARB expects to publish formal regulatory text with a 45-day comment period this autumn.
- Scope 3 categories: five, subject to materiality: 1 (purchased goods and services), 3 (fuel- and energy-related activities), 5 (waste), 6 (business travel) and 7 (employee commuting).
- What each category discloses: a CO2e total, the calculation method, the data type, any exclusions and the share calculated from primary data.
- Assurance: limited assurance on Scope 1 and 2. CARB proposed five accepted assurance standards: AA1000AS v3, AICPA AT-C 210, ISAE 3410 or 3000, ISSA 5000 and ISO 14064-3.
- GHG Protocol versions: fixed at the 2004 Corporate Standard, the 2015 Scope 2 Guidance and the 2011 Scope 3 Standard. Later GHG Protocol updates apply only after a new CARB rulemaking.
- Annual deadline: 10 November each year, open for comment.
What CARB told food and agriculture companies
On 21 August 2026 CARB held a listening session for agriculture, food, beverage and forestry. Staff answered five questions that shape an agri-food inventory.
- Land Sector and Removals Standard (LSRS): staff said their current proposal leaves the LSRS optional. CARB treats it as one quantification method among several, and reporters disclose which methods they used.
- Biogenic emissions: biogenic CO2 is reported in its own line, separate from the Scope 1, 2 and 3 totals. Methane and nitrous oxide stay inside the scope totals. Removals are optional and reported separately from gross emissions.
- Scope 3 methods: CARB accepts both spend-based and activity-based methods. Supplier engagement and product-specific emission factors are optional; reporters disclose the share of emissions calculated from primary data.
- Recalculation: CARB proposed recalculating prior years when a method change moves the base year by more than 5%. Food sector commenters said ingredient emission factors move with weather, tariffs and product mix, so a 5% threshold would mean rebaselining most years. CARB said it is open to a different threshold.
- Timing: staff confirmed the formal 2027 proposal, economic analysis and regulatory text are due this autumn, followed by 45 days of public comment.
Five reasons agri-food companies should care
- Farm emissions arrive in year two. Scope 3 Category 1 - Purchased goods and services - is on CARB's proposed list for 2027. In food and agriculture it holds farm, feed and ingredient emissions, usually the largest share of the footprint.
- Suppliers below $1 billion receive the data requests. Reporters disclose their primary data share. To raise it, they ask growers, processors and ingredient suppliers for their own emissions data.
- One inventory feeds two reporting bases. Companies with SBTi FLAG targets, or that describe their inventory as GHG Protocol conformant from 1 January 2027, apply the LSRS. California's rule follows the Corporate Standard view. Keeping land data disaggregated lets the same inventory produce both outputs.
- Emission factors move every year. Versioned emission factors and a log of method changes let you show an assurance provider why a number moved, and rerun prior years if CARB's recalculation threshold is triggered.
- Assurance reaches the farm gate. Limited assurance covers Scope 1 and 2, including the biogenic CO2 line. Owned farms, livestock and biomass boilers all sit inside that scope.
What to do before the 2027 rule is final
- File your Scope 1 and 2 report, or a statement of non-reporting, by 10 November 2026.
- Build a spend-based category 1 baseline now and record its primary data share. Raise that share each year with your largest suppliers.
- Keep versioned emission factors and a dated log of every method change.
- Store land use change, land management and biogenic data at the level SBTi FLAG and the LSRS ask for, so one dataset serves every framework.
- Recheck your plan the day CARB publishes the formal 2027 text.
FAQs
How Terrascope helps
Terrascope is a carbon accounting platform built for Scope 3 and land-based emissions. Agri-food teams use it to map emissions across the value chain, start with spend-based data and move to supplier and activity data over time, apply region- and crop-specific emission factors, and track data confidence category by category. Every calculation keeps its source, method and emission factor version, so an assurance provider can trace any number back to the input.
Preparing for assurance? Download our climate audit guide with SB 253 supplementary guidance from the SB 253 explainer, or talk to our team.
Sources
- California Health and Safety Code section 38532 (SB 253): leginfo.legislature.ca.gov
- CARB, Final Regulation Order, California Greenhouse Gas Reporting and Climate Related Financial Risk Disclosure Initial Regulation: PDF
- CARB, 2026 SB 253 Reporting Guidance (1 September 2026): PDF
- CARB, SB 253 Public Workshop slides (21 July 2026): PDF
- CARB news release, Board approval of the Initial Regulation: ww2.arb.ca.gov
- CARB SB 253 listening session for agriculture, food, beverage and forestry (21 August 2026)
- GHG Protocol, Land Sector and Removals Standard v1.1, Requirement 1