The rules of climate reporting are shifting under corporate leaders’ feet. For companies that provide daily meal programs, the stakes are higher than they look on the plate.
In September, the U.S. Environmental Protection Agency proposed effectively scrapping its Greenhouse Gas Reporting Program, which has been in place since 2009 and covers roughly 85–90% of U.S. emissions, according to the EPA’s own program documentation and analysis. If finalized, the change would remove federal reporting requirements for most large facilities and fuel suppliers, dramatically weakening a core data set that many companies, investors, and state regulators rely on.
At first glance, you could read this as a green light to de-prioritize emissions accounting. For leaders responsible for food programs, that would be a serious misread of the moment.
While Washington pulls back, California and New York are moving in the opposite direction. California’s Climate Corporate Data Accountability Act (SB 253) requires companies with more than $1 billion in annual revenue that “do business” in the state to report Scope 1, 2, and 3 emissions. Under the law, Scope 1 and 2 reporting begins in 2026, with Scope 3 following in 2027. California lawmakers have been explicit that Scope 3 includes emissions tied to purchased goods and services—categories that cover corporate catering, food procurement, packaging, and waste.
New York is lining up behind a similar model. Its proposed Climate Corporate Data Accountability Act would require large companies operating in the state to annually disclose Scope 1, 2, and 3 emissions to a public registry. While still under legislative consideration, the bill closely mirrors California’s framework and signals where policy is headed in large U.S. markets.
For any employer running daily meal programs—and for the caterers who serve them—this is not an abstract policy story. Corporate food sits squarely in Scope 3: purchased goods and services, upstream logistics, ingredient sourcing, transportation, and food waste. Under California, New York, and similar regimes, those emissions will need to be measured and reported, whether or not the EPA continues to collect its own data.
Across the Atlantic, the European Union is moving further and faster. The EU’s Corporate Sustainability Reporting Directive (CSRD), which starts phasing in between 2024 and 2026, requires large companies, listed small and mid-sized enterprises, and non-EU companies with significant European operations to disclose standardized ESG data, including full Scope 3 greenhouse gas emissions. Guidance tied to CSRD makes clear that food, hospitality, and catering emissions—including upstream agricultural impacts and downstream waste—are considered material and must be reported.
If you’re a global company feeding teams in London, Berlin, and New York, there is no “opt-out” button. EU rules will demand high-quality, auditable value-chain emissions data; California and New York are building state-level analogues; and the federal rollback mainly ensures a more fragmented and complex compliance landscape, not a lighter one.
So what does responsible leadership look like in this environment?
First, it means treating daily food programs as part of the climate balance sheet, not a rounding error. That starts with basic measurement: understanding how many meals you’re serving, what’s on the menu, where ingredients come from, how food is transported, and how much is thrown away. For most companies, that data sits with their caterers. The days when a catering contract was just about price and punctuality are ending; climate-ready partners will need to provide emissions estimates, ingredient transparency, and waste reporting as standard.
Second, it means designing for regulation that hasn’t fully arrived yet. The most forward-thinking companies are building a single, Greenhouse Gas Protocol–aligned dataset they can use to satisfy California, New York, and EU requirements, rather than reacting piecemeal as new rules come online. For meal programs, that often translates into plant-forward menus, lower-impact proteins, seasonal sourcing, and rigorous waste reduction—all levers known to materially affect Scope 3 emissions.
Finally, it means seeing stewardship as more than compliance. Even if federal reporting rules go dark, investors, employees, and customers are not retreating from climate expectations. In the food domain, climate competency is unusually tangible. When leaders can see that shifting menu design reduces emissions, food waste, and cost simultaneously, sustainability stops being abstract and becomes operational.
The EPA may be dimming one of the brightest lights in America’s emissions-data landscape. But for companies feeding people every day—and for the caterers who serve them—the future is still pointing in one direction: more transparency, more accountability, and more climate-aware decisions. The question isn’t whether the carbon footprint of corporate food will matter. It’s whether you’ll be ready when someone asks to see it.
Editor’s note: At Sifted, we work with companies that are thinking deeply about food—not just as a workplace benefit, but as part of a broader system that touches culture, cost, and environmental impact. As climate reporting requirements evolve across states and global markets, daily meal programs are becoming an increasingly visible part of corporate Scope 3 emissions. We believe thoughtful menu design, operational efficiency, and transparency aren’t just compliance tools—they’re opportunities to do better by people and the planet at the same time. Read more here and here.