Product carbon footprint in packaging: what your clients will ask for

A few years ago, sustainability was a conversation about image. Today it is a conversation about data. And for many companies in the packaging sector, that conversation is arriving in the form of a spreadsheet, a form, or a call from a client's procurement manager asking for "the product carbon footprint of the items you supply us".

That is how regulatory pressure works. It does not hit the whole market at once: it starts with the largest accounts and trickles down, supplier by supplier, until it reaches your company. If you have not received that request yet, you are probably already on the list.

Why this is happening now

Large manufacturers in automotive, consumer goods, electronics and food have spent years working to reduce their emissions. But when they measure their corporate footprint using the most widely adopted standard, the GHG Protocol, they find that Scopes 1 and 2 (direct emissions and own energy consumption) account for only a fraction of the total impact. Most of it sits in Scope 3: what happens upstream and downstream, across the supply chain and in the use of their products.

Packaging falls squarely in that category. The materials that protect a product, the manufacturing process of the container, the transport of the packaging from the supplier's plant to the client's production line: all of that is Scope 3 for the buyer. And to measure that impact accurately, they need data from those who make it. In other words, your data.

The regulation behind it

The pressure is not only commercial: there is regulation pushing it.

• CSRD: it requires large European companies to report the emissions of their entire value chain, which leads them to ask their suppliers for data.
• Regulation (EU) 2025/40 (PPWR): the new packaging and packaging waste regulation entered into force in February 2026 and applies generally from 12 August 2026. Among other things, it sets requirements on recyclability, minimum recycled content, labelling and a declaration of conformity in order to place packaging on the market. This pushes companies to document the environmental performance of packaging from the outset.
• Royal Decree 1055/2022: in Spain it regulates extended producer responsibility for packaging. The PPWR applies directly and prevails in the event of conflict, while the Spanish framework is adapted.
• Ecodesign Regulation (ESPR): it pushes towards products and packaging that can justify their environmental impact, relying on tools such as the digital product passport.

To this you can add the decarbonisation targets that many consumer brands have made public, which they cannot meet unless their suppliers measure and reduce in turn.

What they will specifically ask for

The way this requirement arrives varies, but the substance is the same: they need to know how many kilograms of CO₂ equivalent are emitted in the manufacture of a specific product or reference. Sometimes they call it a product footprint, sometimes a PCF (product carbon footprint), sometimes they ask for a life-cycle assessment or an environmental product declaration (EPD).

In practice, what the supplier has to be able to answer is what emissions are generated from raw-material extraction through to the product leaving the factory gate (a cradle-to-gate scope). That means tracing the input materials, the production processes, the energy consumed and the inbound transport, and documenting it in a way the client can incorporate into their own calculation.

The problem is that many companies in this sector do not have this process in place. They have the data (somewhere in the ERP, in purchasing records, in energy invoices), but they do not have it organised to respond to this kind of requirement quickly, traceably and repeatably.

The real cost of not being ready

When the request comes in and there is no structured response, the cost is not just the time spent hunting for data. The real cost shows up as a contract renewal that stalls because environmental documentation is missing, a qualification process blocked while other suppliers have already responded, or a tender where the client moves forward with whoever can provide that information.

Competitive positioning is starting to differentiate not just on price or quality, but on the ability to respond to these requirements with agility. The sectors where this is already standard practice, such as automotive, electrical components and consumer goods, foreshadow what will reach packaging sooner than many companies expect.

Where to start

The good news is that you do not need to have everything figured out to start responding. What makes the difference is not having perfect data from day one, but having a process that lets you build a solid first response, document it and repeat it when the next request comes in.

The starting point is not the calculation. It is understanding exactly what your client is asking for, defining a reasonable scope for the first deliverable and organising the information you already have before looking for what you are missing.

If you have already received the first request, or you know it is coming, there is a structured path to tackling it without disrupting operations. We have put together a specific guide for suppliers that explains, step by step, how to respond to these product footprint requirements: how to interpret what you are being asked, which data is essential, how to build a first calculation that holds up with the client and how to lay the groundwork so this does not depend on a one-off effort every time.

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When the life-cycle calculation and the documentation are automated, responding stops being a project and becomes a routine task: that is the idea behind Manglai's product footprint solution.