New California climate rules are coming. We help you get ready.
SB 253 names companies over $1B. A large retailer cannot compute its own figure without its suppliers’, so the law arrives at a smaller company as a form from its biggest customer. This page is who is covered, when, and what the form asks for.
STATUS AS OF 2026-09-04 · show the sources
What the law requires
US companies doing business in California with total annual revenue over one billion dollars report directly. Below that line, the statute never names you.
SB 261 would ask companies over five hundred million dollars in revenue to publish a climate financial risk report every two years. Enforcement was enjoined by the Ninth Circuit on Nov 18, 2025, ahead of the first Jan 1, 2026 deadline. The court heard argument on the merits on Jan 9, 2026 and has not ruled. Until it does the requirement is not in force, and no date attaches to it. SB 253 was not enjoined and is unaffected. The SB 261 brief carries the detail and the sources.
Direct emissions and purchased energy, on 2025 data. CARB moved this from Aug 10 to Nov 10, 2026. No standardized template and no assurance are required in the first year.
Full value-chain emissions — suppliers, transport, product use — due no later than 180 days after each Scope 1 and 2 disclosure. This is the part that reaches your business.
Up to five hundred thousand dollars per reporting year for companies that fail to file. The California Air Resources Board administers the program.
Third-party assurance moves from limited to reasonable for Scopes 1 and 2, and limited assurance begins for Scope 3.
The Ninth Circuit declined to halt SB 253 in Nov 2025 when it enjoined SB 261, and implementing regulations were adopted in Feb 2026. The merits appeal is still pending, so this row is the one to watch.
How it reaches companies it never names
A large retailer cannot compute its Scope 3 number from its own books — the emissions live in its supply chain. So the rule arrives at smaller companies not as a regulation with a threshold, but as a data request from their biggest customer: a questionnaire with a deadline.
Where a supplier number is missing, the retailer fills it with an industry average rather than leaving the line blank. A measured number from you replaces that estimate in their filing. We prepare it with you.
- California SB 253 applies to companies over $1B doing business in the state.
- Costco, with $240B in FY2024 revenue, is firmly in scope and must report Scope 3.
- Costco needs a Category 1 emissions figure for the goods it buys — including your SKUs.
- Retailer supplier questionnaires are already asking for this data. Accurate answers help you; missing ones get estimated for you.
The 15 Scope 3 categories
SB 253 asks for disclosure across all 15 Scope 3 categories where they are material. For food, beverage, and wine producers, a handful carry most of the footprint. Here is where each one lands.
For food and beverage brands this is almost always the largest category — raw ingredients, packaging, agricultural inputs. Grapes, grain, dairy all live here. Your retailers need this number from you.
Freight from field to facility, bulk transport, cold-chain logistics. Regional sourcing keeps this low; importing internationally raises it.
Pomace, lees, wastewater treatment, solid waste to landfill. Often underestimated — organic waste carries measurable methane potential when landfilled.
Glass bottles are heavy and energy-intensive to make and recycle; aluminum cans fare better. Almost no winery in the scored dataset discloses this — it is the common gap in the wine category.
Equipment, tanks, barrels, facility investment — typically one-time events amortized over asset life. Material for fast-expanding producers, lower for stable operations.
Upstream emissions from producing the energy you use, calculated as a multiplier of Scope 1 and 2 consumption. Renewable energy purchasing reduces it.
Flights, hotels, ground transport for staff. Typically low for small producers, but increasingly tracked in retailer questionnaires.
Staff travel to work. Relevant for large seasonal harvest workforces; usually tracked with a short employee survey.
Downstream leased assets, processing of sold products, use-phase emissions, franchises, investments. Most do not apply to independent wine and food producers — disclose as N/A with a short reason.
How to get ready
The sequence below is the order the filing accepts, not the order the work occurs to you. Each step names what it needs and how long it takes.
Utility bills, natural gas and propane invoices, fuel for owned vehicles and equipment, refrigerant logs. This is the foundation, and it is nearly always in your existing records. Most producers finish it in an afternoon with their bookkeeper.
List everything you buy that becomes product — grapes or fruit, glass, closures, labels, secondary packaging — with rough annual tonnage. The input list comes before the emissions factors, and procurement records almost always have it.
Convert physical inputs to CO2e using published factors from the GHG Protocol, EPA EEIO tables, the Wine Institute, and ADEME. This is where we help most — we have mapped the relevant factors for food, beverage, and wine, so you are not starting from scratch.
Glass end-of-life is the largest untracked category for wine producers. Estimate it from volume sold, bottle weight, regional recycling rate, and a landfill factor — usually reachable with annual case sales and bottle-weight specs.
A one-page supplier emissions summary: total Scope 1+2, the Scope 3 categories covered, a methodology statement, and the data year. This is what retailers actually need — defensible, cited numbers they can pull in without estimating for you.
Science Based Targets initiative approval moves a brand from disclosing to committed, the highest tier in retailer evaluations and in YKO scoring. Assurance by a qualified third party adds defensibility as enforcement tightens.
What YKO provides
We do not run audits. We do the analysis that makes an audit unnecessary at the small-brand scale, and we show you exactly where you stand relative to your category.
- Where you stand. A gap map across all 15 Scope 3 categories — which apply to you, what data you already have, and what is missing — delivered as a working document you can hand to buyers.
- Category emission-factor library. Pre-mapped factors for food, beverage, wine, dairy, and apparel, drawn from the GHG Protocol, EPA EEIO, Wine Institute LCA data, and ADEME. You start from our templates, not a blank page.
- Buyer-ready disclosure package. A formatted supplier emissions summary — the artifact retailer questionnaires ask for — with a methodology statement, data year, and category coverage map.
- Competitive benchmarking. Your score placed against your category across all 6 areas, with the single change that would move it most.
The number is how progress gets measured. It is not the product. What sits underneath it is where the work is, and that is what you act on.
What's coming: producer-level data
Brand-level compliance is the first step. The harder problem is producer-level data across the global supply chain — the vineyard, farm, and facility behind each input, each with its own emissions profile. YKO is building that layer, starting with North American wine regions and California agriculture, then major producing regions in Europe, South America, and Oceania.
Start with a readiness check
5 questions gives you a first read on where you stand and which gaps to close first.
The sources
- SB-253 bill text — California Legislative Information · 2023-10-07
- CARB defers initial SB 253 reporting deadline — Proskauer Rose · 2026-06-26
- CARB adopts initial SB 253/261 regulations — Miller Nash · 2026-03-30
- Ninth Circuit enjoins SB 261, declines to enjoin SB 253 — Jones Day · 2025-11
- Why SB 253 reshapes supplier relationships — UL Solutions