Pulp & paper spans two emissions worlds — the mill and the forest. SBTi requires a target for each. A practitioner summary of how the energy-and-industry and FLAG targets fit together.
Pulp & paper sits across two emissions worlds. The mill side burns fossil natural gas in package boilers and lime kilns and draws purchased grid electricity — conventional energy-and-industry emissions that the SBTi treats under its Corporate Net-Zero Standard. The fibre side reaches back into forests and plantations, where land use, land-use change, and forest management drive a different category of emissions and removals — the Forest, Land and Agriculture (FLAG) emissions with their own SBTi pathway and rules.
Because both sets of emissions are material, the SBTi requires companies in this sector to set both a FLAG target and an energy-and-industry (non-FLAG) target. The two are accounted for and validated separately, but together they form the company's full science-based commitment.
The one-line version
Science-based targets in pulp & paper are not a single number. They are two coherent, separately validated targets — one for the mill, one for the forest — that together describe a 1.5°C trajectory.
The corporate framework asks companies to commit to two layers: a near-term target (5–10-year horizon) and a long-term net-zero target (2050). Both cover Scope 1 and Scope 2. Near-term Scope 3 targets are required only when Scope 3 is 40% or more of total Scope 1+2+3; long-term Scope 3 targets are required for every company, with 90% minimum coverage.
Near-term Scope 1+2 targets must align with 1.5°C and be achieved within 5 to 10 years. The default method — the cross-sector absolute contraction approach (ACA) — requires a minimum linear annual reduction of 4.2% from the base year, covering at least 95% of combined Scope 1+2. For Scope 2, SBTi requires renewable-electricity procurement of 80% by 2025 and 100% by 2030.
Type of target. Pulp & paper has no finalised SBTi sector standard (SDA), so the energy-and-industry side defaults to ACA at 4.2%/yr. The land side is different: inside FLAG, the timber & wood fiber commodity pathway is sector-specific intensity convergence at 2.80%/yr.
Scope 2. SBTi accepts a renewable-electricity method (Annex B.4): 80% renewable electricity by 2025 and 100% by 2030 via RECs or virtual PPAs — the natural method for most mills.
Scope 3. Non-fibre Scope 3 (chemicals, packaging, equipment, transport) uses physical intensity (≥7%/yr), economic intensity, or supplier/customer engagement. Fibre-related Scope 3 (purchased pulp, wood fibre, recovered fibre) sits in the FLAG target on the timber & wood fiber pathway — reported and validated as a separate sub-target.
Long-term targets must align with 1.5°C with a target year no later than 2050. Coverage rises to at least 95% of Scope 1+2 and 90% of Scope 3; the end-state is an absolute reduction of approximately 90% across all scopes, with any small residual neutralised by durable carbon dioxide removals. One asymmetry: there is currently no long-term FLAG pathway for timber and wood fiber, so long-term submissions must footnote the gap and resubmit within six months of SBTi releasing the missing pathway.
Black liquor and biomass typically supply 60–80% of mill steam. Under most compliance regimes (OBPS, EU ETS, WCI) the CO₂ from these biogenic streams is zero-rated. Under SBTi the rule is different.
A special case for pulp & paper
Section 4.3.3 of the Corporate Net-Zero Standard, with criterion C11, requires bioenergy users to include the direct CO₂ from biomass combustion, processing, and distribution — with the land-use emissions and removals of the feedstock — inside the SBTi target boundary. The recovery boiler and biomass boiler are not zero-rated under SBTi the way they are under compliance regimes.
Validation and review. Targets are submitted through the SBTi Validation Portal, validated against the published criteria, and published on the SBTi website. Companies must report inventory and progress every year and review targets at least every five years.
FLAG is SBTi's dedicated framework for emissions and removals from land use, land-use change, and land management — biomass and soil carbon losses, agricultural and forest methane and nitrous oxide, and the CO₂ removals that working forests and improved land management can deliver.
Under criterion FLAG-C1, a company must set a FLAG target if it is in an SBTi-designated FLAG sector (regardless of FLAG share) or has FLAG-related emissions of 20% or more of total Scope 1+2+3. Forest and Paper Products is a designated sector — so forestry companies, integrated kraft producers, market-pulp producers, non-integrated converters, tissue producers, paperboard manufacturers, and paper merchants all must set a FLAG target, whether or not they own forest land or run a mill.
FLAG offers a sector approach (absolute reduction for diversified land-use emissions) and a commodity approach (intensity convergence across eleven commodity tracks). For pulp & paper the relevant track is timber & wood fiber. Under criterion FLAG-C8, Forest and Paper Products companies — or any company with ≥10% of FLAG emissions in timber & wood fiber — must use this commodity pathway, calculated through the SBTi FLAG Tool.
Every FLAG target carries a mandatory no-deforestation commitment for primary deforestation-linked commodities (criterion FLAG-C4), with a target date no later than 31 December 2030 and a cutoff date no later than 2020, aligned with Accountability Framework initiative (AFi) guidance.
FLAG covers land-use change emissions, land-management non-LUC emissions, and land-management CO₂ removals. Two rules matter: FLAG and energy/industry targets must be kept separate — emissions and removals from one cannot be netted against the other; and removals cannot substitute for reductions inside the FLAG target. In the FLAG sector pathway, reductions account for ~62% of the mitigation potential and removals ~38%.
Climate Decode helps pulp & paper companies inventory FLAG and energy-and-industry emissions, choose pathways, and build the mill-level decarbonization plan that actually delivers the 4.2%/yr trajectory.
A Forest and Paper Products company's footprint splits across the two frameworks. Industrial activity lives in the energy-and-industry world (fossil NG at the package boiler and lime kiln, grid electricity, mobile diesel, process calcination). Fibre activity lives in the FLAG world (forest harvest and management on owned land for integrated producers, plus purchased pulp and wood fibre for everyone). Setting only one target would leave half the footprint out.
| Emission source | Target bucket | Method |
|---|---|---|
| NG package boiler, lime kiln, mobile diesel | Energy & industry (Scope 1) | Cross-sector absolute contraction |
| Purchased grid electricity | Energy & industry (Scope 2) | ACA + renewable-electricity target |
| Make-up chemical calcination, refrigerant leaks | Energy & industry (Scope 1) | Cross-sector absolute contraction |
| Forest harvest & management on owned land | FLAG (Scope 1) | Timber & wood fiber pathway |
| Land-use change in owned/managed land | FLAG (Scope 1) | Timber & wood fiber pathway |
| Purchased pulp, recovered fibre, wood fibre | FLAG (Scope 3) | Timber & wood fiber pathway |
| Forest-management CO₂ removals (owned land) | FLAG removals (separate line) | Reported separately; cannot net |
| Purchased goods (non-fibre): chemicals, packaging | Energy & industry (Scope 3) | ACA, supplier engagement, or intensity |
| Upstream & downstream transportation | Energy & industry (Scope 3) | ACA or intensity |
Both pathways are 1.5°C-aligned but require different minimum rates. Land-sector decarbonisation is constrained by persistent methane and nitrous oxide sources, so FLAG ambition is lower.
| Pathway | Type | Minimum rate (2020–2030) | Use |
|---|---|---|---|
| Cross-sector energy & industry | Absolute (LAR) | 4.2% / yr | Scope 1+2 default; Scope 3 where used |
| FLAG sector pathway | Absolute (LAR) | 3.03% / yr | Diversified FLAG emissions |
| FLAG commodity — Timber & Wood Fiber | Intensity convergence | 2.80% / yr | Forest & paper products; ≥10% of FLAG |
Data. The company must separate FLAG from energy-and-industry emissions across Scope 1, 2, and 3, in the base year and annually — requiring upstream lifecycle data for purchased fibre, traceability of owned forest land, and conventional fuel-and-energy data for the mill. Three streams that historically sit in different teams.
Sequencing. The 4.2%/yr energy-and-industry target is met through the mill-level decarbonization toolkit (efficiency first, then electrification, fuel switching, and BECCS). The FLAG target is met through a different toolkit (no-deforestation due diligence, improved forest management, restoration). The two stacks are planned in parallel but managed by different functions.
Governance. Because the two targets are validated separately, the company has two accountability lines that both have to deliver and be re-validated through the same five-year cycle. A failure on either sub-target is a failure of the whole commitment.
The clean way to deliver
Treat the two as one indivisible programme — sharing data, sequencing capital, and reviewing progress in one governance forum. That is the cleanest way to keep the mill and the forest on the same 1.5°C trajectory.
This briefing draws on the current SBTi standards and guidance.
Climate Decode helps pulp & paper companies build, validate, and deliver both the energy-and-industry and FLAG sides of their science-based commitment — from inventory to mill-level decarbonization plan.