California SB 253: A Manufacturer’s Quick Start

SB 253 in a nutshell

SB 253 requires companies doing business in California with over $1 billion in total annual revenue to disclose Scope 1 and 2 emissions annually starting in 2026, with Scope 3 on a schedule set by CARB beginning in 2027. Limited assurance applies to Scopes 1 and 2 in 2026, reasonable assurance in 2030, and a Scope 3 limited‑assurance requirement can begin in 2030. Penalties can reach up to $500,000 per reporting year, with a safe harbor for good‑faith Scope 3 misstatements. (California HSC §38532, 2025) (California HSC §38532, 2025).

Who is actually in scope

CARB’s evolving scoping suggests only a slice of companies will file, yet they move a big share of the economy. Recent estimates point to roughly 2,600 entities in SB 253 and about 4,100 in SB 261 once duplicates are resolved. That is less than 1% of companies but a large portion of revenue flowing through California. (AP, 2025) (AP, 2025).

Deadlines and assurance, without the spin

CARB has floated a June 30, 2026 first due date for Scope 1 and 2, paired with limited assurance, and Scope 3 beginning in 2027. While rulemaking stretched into late 2025 and early 2026, the statute’s structure still points to 2026 activity, with CARB signaling discretion for good‑faith first‑year filings. (BDO, 2025) (BDO, 2025).

SB 253 and product EPDs: same data family, different jobs

Think of corporate emissions and EPDs like cousins at a reunion. Corporate numbers roll up facility energy, fleets, and purchased electricity to satisfy a law. EPDs translate a product’s cradle‑to‑gate or cradle‑to‑grave impacts for specifiers. The overlap is the data plumbing. Utility meters, production volumes, scrap, fuels, and supplier inputs are the backbone for both. When your plant data is clean enough for third‑party assurance, your LCAs run smoother and your EPDs stand taller in a bid.

For construction manufacturers, EPDs also reduce the “carbon penalty” buyers apply when product data is missing. With a verified EPD, a product is far less likely to be swapped for a competitor just because the project team must hit embodied‑carbon targets. That commercial edge is real even when two products perform the same in the field.

Why litigation headlines do not change the work

As of December 3, 2025, a federal appeals court paused SB 261 risk reporting for now, yet SB 253 emissions disclosure remains on track. Teams that wait for perfect certainty risk a bottleneck when customers and GCs ask for both corporate figures and product‑level EPDs during the same bid window. The smart move is to finalize a Scope 1 and 2 baseline while aligning LCA inputs so that product EPDs can be published on schedule. Waiting rarely saves effort, it just compresses it.

What this means for revenue teams

Corporate disclosure turns sustainability from a footnote into a search filter. Buyers in California and national accounts with California exposure will screen suppliers by reported emissions and by availability of product EPDs. If a competitor shows corporate reductions plus verified EPDs across core SKUs, they shorten the sales cycle and reduce swap‑out risk. Your goal is not a museum‑perfect inventory, it is a dependable, assured dataset that removes doubt at specification time.

Practical next moves that de‑risk the first filing

• Pick a reference year and lock the boundary, then map plant utilities, fuels, refrigerants, and on‑site generation into a single ledger. Tie each meter or fuel to a product family where feasible.
• Line up assurance readiness now. Document controls, who calculates what, and how you evidence activity data. Auditors test processes as much as numbers.
• Prioritize product lines where EPDs move specs. Start LCAs using the same metered data you will use for SB 253. Choose PCRs that mirror your competitive set and check expiry windows.
• Build a repeatable data pull. Monthly extracts from ERP, energy, and waste systems beat a year‑end scramble. Definately do not rely on ad‑hoc spreadsheets.

Data quality tips that pay off twice

Set allocation rules that both your LCA practitioner and assurance provider can accept. Keep supplier‑specific data where it improves accuracy and traceability, and clearly flag market‑average data where you use it. Use a single naming convention for sites, meters, and products so that corporate reporters and LCA modelers are never arguing about which plant is which. When in doubt, write the assumption, date it, and store the source.

Assurance, meet EPD verification

Assurance for SB 253 and third‑party verification for EPDs speak a common language: independence, traceability, and consistency. If your site utility files, fuel receipts, and production logs are organized to satisfy assurance, you can feed the same evidence pack to your LCA consultant and the program operator that will publish the EPD. That is how reporting work stops feeling like double‑work.

Watchlist for 2026 planning

Three facts matter for calendars. The statutory threshold remains $1 billion in revenue. Scope 1 and 2 reporting begins in 2026 with limited assurance, with penalties capped at $500,000 per year and a Scope 3 safe harbor for good‑faith misstatements through 2029. CARB discussed a June 30, 2026 concept for first filings in its workshops. (California HSC §38532, 2025) (California HSC §38532, 2025; BDO, 2025) (BDO, 2025).

Closing thought: turn compliance into competitive memory

Treat SB 253 like a season opener, not a one‑off game. The same clean ledger that supports assured corporate emissions will feed faster LCAs and fresher EPDs, which in turn keep products in the spec when carbon is a tiebreaker. Do the plumbing once, win twice.