Introduction
Environmental performance is increasingly treated as a measurable supplier attribute rather than a general corporate ambition. For pharmaceutical manufacturers, the near-term focus is carbon and resource use across the value chain, with a growing expectation that claims can be evidenced through standardised accounting methods, product-level footprinting, and independent assurance. These expectations interact with circular economy requirements, particularly for packaging, where regulatory compliance and procurement expectations can converge into practical conditions of supply.
Carbon accounting as a supplier requirement
Most procurement-facing carbon requirements start with organisational greenhouse gas (GHG) accounting, typically structured around the Greenhouse Gas Protocol (GHG Protocol) scopes and categories. Scope 1 emissions cover direct emissions from owned or controlled sources, Scope 2 covers purchased energy, and Scope 3 captures indirect emissions across the value chain such as purchased goods and services, transport, and downstream use and end-of-life. The Corporate Accounting and Reporting Standard and the Corporate Value Chain (Scope 3) Standard are widely used reference points for defining boundaries, data quality expectations, and reporting logic.
Where health systems and public procurement bodies signal “net zero supplier” expectations, the practical implication is that access, contracting, and supply functions increasingly need evidence that corporate inventories exist, that reduction plans are documented, and that the reporting method is consistent across geographies and supplier tiers.
From corporate targets to measurable plans
Carbon requirements increasingly extend beyond reporting to target-setting and transition plans, often aligned to widely recognised target frameworks. The Science Based Targets initiative (SBTi) Corporate Net-Zero Standard is a common reference for defining near-term and long-term targets and for clarifying how organisations should treat residual emissions and the role of neutralisation.
Separately, some procurement frameworks treat the presence of a documented carbon reduction plan as a qualification condition. In the United Kingdom, Procurement Policy Note 06/21 sets an approach for taking account of Carbon Reduction Plans in major central government procurement, creating a template logic that can be re-used by other public purchasers.
Product carbon footprints and life cycle assessment
Where procurement moves beyond corporate reporting, product carbon footprints and life cycle assessment (LCA) become relevant. ISO 14067 provides principles and requirements for quantifying and reporting the carbon footprint of a product, aligned with LCA standards. ISO 14064-1 provides organisational-level requirements for quantification and reporting and is often used to support consistent inventory design and verification.
Product-level work typically requires decisions on system boundaries, allocation approaches, primary versus secondary data, and the treatment of packaging, cold chain, and distribution. The operational burden is often greatest where product portfolios are broad, manufacturing networks are complex, or suppliers are concentrated in tiers with limited reporting maturity.
Evidence, assurance, and certification mechanisms
Procurement-facing environmental evidence increasingly relies on auditable management systems and assurance of reported data, rather than narrative descriptions. ISO 14001 defines requirements for environmental management systems (EMS), which can provide an auditable control framework for compliance, monitoring, and continual improvement across sites and functions.
In parallel, some organisations use product footprint labels or verified claims as an externally communicable assurance mechanism, particularly where product-level emissions are being discussed in customer-facing contexts. The Carbon Trust describes product carbon footprint labelling approaches that link measurement to verification and claims.
Circular economy and packaging regulation as a cost driver
Circular economy requirements increasingly translate into material design constraints, recycled content rules, reuse and waste prevention expectations, and documentation obligations. In the European Union, the Packaging and Packaging Waste Regulation (EU) 2025/40 sets lifecycle-oriented requirements for packaging and labelling and aims to prevent unnecessary packaging and promote reuse and recycling.
For medicines, these requirements can affect packaging specifications, supplier qualification, documentation practices, and packaging redesign timelines. Even where medicinal product packaging is subject to sector-specific constraints, the direction of travel is towards more formal sustainability and waste-management requirements across packaging categories, which can affect both manufacturer cost structures and supply continuity planning.
Regional signals: EU and Nordics, USA, and Japan
In Europe and the Nordic countries, sustainability objectives are increasingly discussed in the context of public procurement and supply chain accountability, with attention to how environmental criteria can be incorporated in tendering and supplier management.
In the United States, federal procurement policy includes sustainability-related acquisition provisions under the Federal Acquisition Regulation (FAR) Part 23. A proposed rule that would have required certain major federal suppliers to disclose GHG emissions and climate-related financial risk was withdrawn in January 2025, illustrating that procurement-facing climate disclosure expectations may evolve through a combination of rulemaking, agency policy, and sector purchasing practices rather than a single stable federal requirement.
In Japan, green procurement is supported through the Act on Promotion of Procurement of Eco-Friendly Goods and Services and associated Basic Policy documents, which set expectations and categories for public procurement of environmentally preferable goods and services.
Summary
Carbon, resource use, and circular economy expectations increasingly translate into measurable supplier obligations supported by standardised accounting, product footprinting, and assurance mechanisms. Corporate GHG inventories typically follow the GHG Protocol structure, while target-setting and transition planning may be aligned to frameworks such as the SBTi Corporate Net-Zero Standard. Product-level carbon footprinting and LCA approaches are increasingly relevant where procurement expects evidence at product or category level, supported by standards such as ISO 14067 and ISO 14064-1. Evidence expectations are reinforced by auditable control systems, including ISO 14001 environmental management systems, and by external verification approaches for selected claims. Circular economy requirements, particularly under EU packaging rules, can create direct redesign, documentation, and compliance costs that interact with procurement expectations. Regional approaches vary, with EU and Nordic developments often led through public procurement practices, the United States shaped through FAR sustainability provisions alongside changing disclosure initiatives, and Japan supported through a formal green procurement policy framework.
Links
European Union: Regulation (EU) 2025/40 on packaging and packaging waste. 22 January 2025.
Greenhouse Gas Protocol: Corporate Accounting and Reporting Standard.
Greenhouse Gas Protocol: Corporate Value Chain (Scope 3) Standard.
International Organization for Standardization: ISO 14001:2015 Environmental management systems.
International Organization for Standardization: ISO 14064-1:2018 Greenhouse gases.
International Organization for Standardization: ISO 14067:2018 Carbon footprint of products.
Scientific publications
Chen Z, Lian JZ, Zhu H, Zhang J, Zhang Y, Xiang X, Huang D, Tjokro K, Barbarossa V, Cucurachi S, Dong B. Application of life cycle assessment in the pharmaceutical industry: A critical review. J Clean Prod. 2024;459:142550. https://doi.org/10.1016/j.jclepro.2024.142550
Jahre M, van Oorschot K, Årdal C, Sverrisson E, Pettersen MS, Wangen A. Sustainable pharmaceutical procurement: Environmental tendering criteria for better or worse? J Purch Supply Manag. 2025;101081. https://doi.org/10.1016/j.pursup.2025.101081
Lavoie DCT, Maraj A, Wong GYC, Parascandalo F, Sergeant M. Healthcare procurement in the race to net-zero: Practical steps for healthcare leadership. Healthcare Management Forum. 2024;37(5):384-389. doi:10.1177/08404704241258152
Mackillop N, Shah J, Collins M, et al. Carbon footprint of industry-sponsored late-stage clinical trials. BMJ Open 2023;13:e072491. doi: 10.1136/bmjopen-2023-072491
Saldaña-Pierard C, Mai Nguyen P, Debeaufort F et al. Impact of emerging packaging regulations on international trade and product safety with emphasis on plastic reuse and recycling in Europe and North America. J Ind Ecol. 2025;29(5):1473-1504. doi:10.1111/jiec.70079