For the latest information on climate-related disclosure rules and their impact on major meat and dairy companies, view the Meat and Dairy Emissions Dashboard.
In 2023, California became the first U.S. state to pass climate-related disclosure laws, which impose climate-related reporting obligations on businesses operating in the state. With this move, California joined a growing number of more than a dozen jurisdictions around the world taking legislative action to hold companies accountable for their climate impact. Climate-related disclosure laws like the ones in California provide crucial information on mounting climate risk to investors so they can make more informed investment decisions. The agriculture sector is particularly exposed to climate risk and contributes an outsized share of global greenhouse gas (GHG) emissions, particularly the potent GHG methane. As the period for public feedback on the implementation of California’s climate-related disclosure laws ends this Friday, March 21, this article explores the laws’ implications for the agriculture sector and highlights what is at stake as the state moves toward implementation.
Overview of California’s climate disclosure laws
California’s Climate Corporate Data Accountability Act (SB 253) requires companies with annual revenues exceeding $1 billion that conduct business in California to report their GHG emissions annually. Companies must disclose Scope 1 and Scope 2 emissions starting in 2026, and by 2027 they must also report Scope 3 emissions which include emissions from the full supply chain. California’s Greenhouse Gases: Climate-Related Financial Risk Act (SB 261) applies to companies with annual revenues over $500 million operating in California. These companies must prepare and publicly disclose biennial reports on their climate-related financial risks starting in 2026. According to an analysis of 2022 data conducted by Ceres and S&P Global, almost 2,000 companies are likely to report under SB 253 and almost 2,700 companies are likely to report under SB 261. Jointly, SB 253 and SB 261 are the Climate Accountability Acts.
The California Air Resources Board (CARB) is the regulatory body tasked with implementing California’s climate-related disclosure laws. Months after the passage of the Climate Accountability Acts, another bill was passed which made key changes to the timeline of implementation. Briefly, SB 219 extends the deadline for implementation by six months, gives CARB the power to set a timeline for Scope 3 emissions disclosures and allows large companies to report emissions at the parent level for easier compliance.
How do the Climate Accountability Acts impact food and agriculture companies?
Agriculture is a significant source of GHG emissions in California. CARB has estimated that agriculture is responsible for the emission of 32 million metric tons of carbon dioxide equivalent, making it the fifth largest source of GHG emissions in California in 2019. About 70% of agricultural emissions in California are methane emissions from livestock.
According to our research, many of the world’s major meat and dairy companies have operations in California and are estimated to fall under the scope of the Climate Accountability Acts. Companies with at least one qualifying subsidiary that meets the threshold for reporting in California include Arla Foods, Danone, Fonterra, Le Groupe Lactalis, Nestle, Saputo, and WH Group. Companies that would have to report at the consolidated parent level — meaning that they would have to report GHG emissions and climate-related risk information for all subsidiaries — include Tyson Foods, JBS and Dairy Farmers of America. Interact with the network graph below to see which companies are likely to report under the Climate Accountability Acts, and at what level.[1]
By adhering to widely adopted reporting standards such as the GHG Protocol (SB 253) and ISSB standards (SB 261), the cost of compliance with the laws for companies is low. Many companies already use these standards in their reporting or will have to use them to report GHG emissions and climate-related risk in other jurisdictions. Of the 10 meat and dairy companies likely to report under California’s climate-related disclosure rules, eight will have to report under the EU Corporate Sustainability Reporting Directive (CSRD) anyway. Furthermore, seven of the companies likely to report under California’s rules are already reporting GHG emissions, including Scope 3, in their annual reports.[2] Therefore, California’s climate-related disclosure rules are not overly burdensome for companies but provide much-needed standardization and clarity for investors and the public.
California’s climate disclosure laws face legal challenges
The U.S. Chamber of Commerce and California Chamber of Commerce filed a lawsuit claiming that the Climate Accountability Acts undercut federal authority and infringe upon the First Amendment by compelling speech. A motion for summary judgement on the First Amendment claim was denied but a partial motion to dismiss these claims is still pending. California has strong arguments to defend the laws and implementation will likely begin before the litigation process ends. However, there is strong industry interest in weakening the implementation of the laws.
Opportunity for stakeholder feedback on the implementation of the laws
Despite the legal challenge, California’s climate disclosure laws are still intact and CARB has begun the implementation process. In December 2024, CARB began soliciting feedback to help inform its implementation. IATP has joined partner organizations to submit a comment signaling support for CARB in implementing the Climate Accountability Acts. IATP has also submitted our own comment that specifically highlights the importance of California’s climate-related disclosure laws for the food and agriculture sector.
CARB has requested any feedback relevant to implementing the Climate Accountability Acts but specifically posed 13 key questions. These questions can be found in CARB’s solicitation for feedback. Briefly, the questions cover a range of topics including how to define “doing business in California,” how to track parent/subsidiary relationships and how to define “reasonable assurance” for third party assurance requirements. Some questions also ask for background information on GHG reporting including the appropriate timeframe for reporting, when data is available from prior years and what software is used for reporting. The deadline to submit a comment is March 21 — click here to submit a comment.
In IATP’s comment, we encourage CARB to require companies to separately report emissions from each GHG, including methane. Reductions in methane emissions are considered crucial for preventing the worst effects of climate change.[3] Agricultural livestock is the single largest source of methane emissions in the world, yet only one of the major meat and dairy companies reported methane emissions in 2023.[4] We also emphasize in our comment that CARB should require reasonable assurance[5] for full-scope emissions reporting. As more jurisdictions introduce climate-related disclosure rules like the Climate Accountability Acts, it is important that a high level of reporting accuracy is required to not create a gap in the quality of disclosures across jurisdictions. For example, New York’s proposed climate-related disclosure law would require reasonable assurance of Scope 1 and Scope 2 in 2031.[6] We believe that reasonable assurance for Scope 3 emissions is also important, particularly given the fact that 90% of agriculture companies’ total emissions are scope 3.
Preparing for pushbacks and moving forward
This is the first opportunity companies have had to comment on the California laws, so we anticipate many comments from industry giants and lobby groups pushing back against strong implementation. Opponents of the Climate Accountability Acts have already mischaracterized SB 253 as a “hidden tax on small business.”
California’s leadership on climate-related disclosure is time-sensitive, with additional time delays in the global energy transition directly correlated to increases in average global warming. Other U.S. states are also stepping up, with Colorado, New Jersey and Illinois joining New York as states with proposed climate-related disclosure laws. Given the SEC’s recent abandonment of the U.S. federal climate-related disclosure rule, other states are looking to California to set the standard. California, the world’s fifth largest economy, is positioned to be a U.S. and global leader in mandatory climate-related disclosure as it moves to implement the Climate Accountability Acts.
Footnotes
[1] Data is primarily derived from company reports and financial filings. See IATP’s previous research to learn more about our methodology for collecting data related to climate-related disclosure rules in all jurisdictions.
[2] Yow, L. (2025). Momentum in Mandatory Climate Disclosure: Impact on Meat and Dairy Giants. IATP. Momentum in Mandatory Climate Disclosure: Impact on Meat and Dairy Giants | IATP.
[3] IPCC, (2023). Climate Change 2023 Synthesis Report. https://www.ipcc.ch/report/ar6/syr/downloads/report/IPCC_AR6_SYR_LongerReport.pdf p. 95
[4] Danone was the only major meat and dairy company to voluntarily report methane emissions in 2023.
[5] Reasonable assurance as defined by MRR, meaning a “high degree of confidence that submitted data and statements are valid” See CARB’s solicitation for feedback for further information.
[6] Climate Corporate Data Accountability Act, no. A04282 (2025). https://nyassembly.gov/leg/?default_fld=&leg_video=&bn=A04282&term=2025&Summary=Y&Text=Y
