Submission Number: 8438
Submission ID: 58711
Submission UUID: cbd26a19-c359-45b6-b095-4a8032b3b2d2

Created: Fri, 03/27/2026 - 11:40
Completed: Fri, 03/27/2026 - 11:47
Changed: Wed, 04/08/2026 - 13:11

Remote IP address: 155.190.20.5
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes


Submitted Comment
Emily Nowell
Mativ Holdings Inc.
Scope 3 Emissions Options

My suggestion for Scope 3 reporting would be to vary the requirements by sector in accordance with CDP guidance (see the attachment). For companies that fall outside of these sectors, the category phase-in option proposed by CARB (i.e., Option 3) could be applied instead.

Regardless of the approach taken, there will need to be some flexibility to exclude categories considered de minimis with appropriate explanation. The GHG Protocol offers a list of criteria for identifying relevant Scope 3 activities. A company could deem a category "irrelevant" based on any one of these criteria.

N/A