At the latest with the entry into force of the CO2 Border Adjustment Mechanism (CBAM) on 1 January 2026 and the second CSRD wave, which covers financial years from 2027 onwards, sustainability is no longer an image issue for medium-sized warehouse operators but a tangible obligation with direct consequences for procurement, balance sheets and operating costs. Anyone replacing a forklift fleet, modernising a hall heating system or procuring new racking today is making decisions that will appear in Scope 1 and Scope 3 data from the next reporting cycle onwards – and that will feed through to credit terms, supplier ratings and tender opportunities. At the same time, industrial electricity prices remain in the range of 30–42 cents/kWh, while natural gas is becoming steadily more expensive due to CO2 pricing and grid charges. This article shows where your warehouse really generates CO2, which measures pay for themselves in under two years and which data you need for robust reporting under ESRS E1.
Why 2026 is the mandatory year for sustainability data
The regulatory landscape has shifted several times in recent months – but remains relevant for medium-sized warehouses with significant construction depth or supply chains. Three building blocks interlock:
CSRD – postponed, but not abolished. Directive (EU) 2026/470 of 26 February 2026 has significantly streamlined the scope of the Corporate Sustainability Reporting Directive: in future, only companies with more than 1,000 employees and more than 450 million euros in net turnover will be subject to reporting requirements. Wave 1 (large capital-market-oriented companies >500 employees) remains obliged for financial years 2024–2026; all other large companies start for the first time with financial year 2027. For many medium-sized businesses this means: the direct obligation falls away – the indirect obligation via supplier and bank enquiries remains (source: Rödl & Partner, February 2026; IHK Frankfurt).
LkSG/CSDDD – restructuring under way. The German Supply Chain Due Diligence Act (LkSG) is being replaced by the EU CSDDD; the transposition deadline was extended to 26 July 2027 by the “stop-the-clock” directive. Relevant for warehouse operators: even those not directly subject to reporting requirements are increasingly being obliged by customers to provide energy consumption and emissions data (source: Fieldfisher, January 2026; BMAS, the German Federal Ministry of Labour and Social Affairs).
CBAM – now in force. Since 1 January 2026, importers of steel, aluminium, cement, fertilisers, hydrogen and electricity have had to purchase CBAM certificates. For a warehouse, this specifically means: racking, workbench frames, steel platforms and heavy-duty racking from third countries will become more expensive via the supplier – between 4 % and 12 % depending on the carbon intensity of the manufacturing plant (source: DIHK CBAM dossier; EU Commission, Taxation and Customs Union).
For medium-sized businesses not directly subject to reporting requirements, the rule is: the data must be in place anyway. Banks check it for credit conditions, large customers demand it as a supplier prerequisite, insurers scale premiums accordingly. Anyone who does not start recording energy and emissions data cleanly in 2026 will find themselves struggling to explain in 2027.
Scope 1, 2, 3: where your warehouse really generates CO2
The GHG Protocol standard, which ESRS E1-6 also references, distinguishes three emission areas. For a typical medium-sized warehouse with 2,000–8,000 m² of hall space, the CO2 footprint is roughly distributed as follows:
| Scope | Typical share of total emissions | Main sources in the warehouse |
|---|---|---|
| Scope 1 (direct) | 15–25 % | Hall heating with gas/oil, LPG/diesel forklifts, company vehicles |
| Scope 2 (electricity/district heating) | 20–30 % | Lighting, compressed air, chargers, IT, refrigeration, conveyor systems |
| Scope 3 (upstream and downstream) | 50–70 % | Purchased goods (racking, packaging), transport, commuter traffic, disposal |
Scope 1: heating, forklifts, workshop vehicles
Natural gas hall heating systems and LPG/diesel forklifts are the two biggest Scope 1 drivers. According to Destatis (the German Federal Statistical Office), natural gas accounted for 29.2 % of the manufacturing sector’s total energy consumption of 3,343 petajoules in 2024. Per 1,000 m² of heated hall space, 80–180 MWh/year of heating energy is required depending on the insulation standard – equivalent to 16–36 tonnes of CO2e.
Scope 2: electricity – the lever with the fastest ROI
Lighting, compressed air and conveyor technology account for 60–80 % of electricity consumption. Those who work here with LED, variable-speed compressors and peak-load management reduce Scope 2 measurably – and the electricity bill along with it.
Scope 3: the biggest chunk – and the most difficult
Storage racking, workbench tops, steel platform constructions, packaging, consumables and the entire commuter traffic of your warehouse staff fall under Scope 3. This is exactly where CBAM takes effect and exactly where ESRS E1-9 (impacts of financial assets) applies. One tonne of newly produced rolled steel causes around 1.9 tonnes of CO2e in the classic blast furnace process; from scrap in an electric arc furnace it is only about 0.4 tonnes – a difference of 1.67 tonnes of CO2 per tonne of steel (source: Recyclingportal/bvse, EU-Recycling).
Energy efficiency: LED, heat, doors
The four most effective levers for an existing warehouse are, in order of their typical cost-effectiveness: LED hall lighting, high-speed doors, heat recovery and photovoltaics.
LED hall lighting – 70 % savings are realistic
According to calculations by the German Energy Agency (dena), commercial businesses can save up to 70 % of lighting costs. In combination with presence and daylight controls, savings of up to 80 % have even been documented in warehouse halls (source: dena; Fraunhofer Institute on lighting systems in businesses). A 6,000 m² hall with a former connected load of 220 kW of fluorescent tubes is reduced to 60–80 kW with LED high-bay luminaires; at 4,000 operating hours per year and 30 cents/kWh, that is around 170,000–190,000 euros less in electricity costs per year. Payback periods are typically between 18 and 30 months.
High-speed doors – up to 90 % less ventilation heat loss
The biggest energy waster at a hall door is the open standing time. Studies at TU München show: high-speed doors with shortened opening times reduce energy demand by up to 30 %; when combined as an airlock system, up to 90 % of ventilation heat losses can be avoided (source: ingenieur.de; dhf-magazin.com). For a hall with five constantly used sectional doors, this corresponds to 4,000–9,000 euros in heating costs per door per heating season.
Hall heating with heat recovery
Classic gas radiant tube heaters operate at efficiencies of around 85 %; modern hybrid systems with heat pumps and heat recovery from compressed-air compressors or process exhaust air achieve seasonal performance factors >3, which at the current electricity mix corresponds to a real emissions reduction of 50–65 % compared with natural gas. Compressed-air compressors release over 90 % of their absorbed energy as heat – this waste heat can be fed almost entirely into hall heating or domestic hot water.
Photovoltaics on the hall roof
Few facilities are as predestined for photovoltaics as warehouse halls: large, shade-free roof areas, high daytime consumption, a typical load profile that correlates well with solar yield. For 2026, the payback period for commercial rooftop systems with self-consumption rates >50 % is 7–10 years; the return is typically between 5 % and 10 % per year (source: solaranlage-ratgeber.de, gruenes.haus, as of 2026). A 500 kWp system on 4,000 m² of hall roof generates around 500,000 kWh/year in southern Germany and, with the German electricity mix, avoids about 200 tonnes of CO2e per year.
Material choice for racking and workbenches
The lion’s share of Scope 3 sits in purchases that many warehouse managers have so far judged only in terms of price and load capacity. Three levers have the greatest effect:
Steel with a high recycled content
Steel is by far the most common material in storage racking and workbench frames. The difference between blast furnace primary steel and electric arc furnace recycled steel is considerable: every tonne of steel scrap in the steelworks saves 1.67 tonnes of CO2; for stainless steel scrap it is as much as 4.3 tonnes (source: bvse Bundesverband; Recyclingportal). Ask your racking supplier explicitly about the recycled content and about EPDs (Environmental Product Declarations) to EN 15804. Brands such as ArcelorMittal XCarb, Salzgitter SALCOS or thyssenkrupp bluemint supply steel with certified CO2 reductions.
Powder coating instead of wet paint
Unlike classic wet paint, powder coating contains virtually no solvents (VOC), the overspray can be recycled at over 95 %, and energy input per m² of coated surface is 20–30 % lower. For workbenches, heavy-duty racking, drawer cabinets and shelving units, powder coating is standard today – for older stock, switching is worthwhile at the next reinvestment.
Modularity and longevity
A heavy-duty racking system that lasts 25 years and can, if required, be extended with additional bays or dismantled as a complete system and reassembled at a second site beats any “bio coating”: the longest service life per tonne of installed material is always the most sustainable solution. When procuring, check whether the system is certified to DIN EN 15635 (regular inspection provided for) and whether spare parts will still be available in 15 years’ time.
Packaging and shipping optimisation
For warehouses with outgoing goods flows, packaging and shipping are often the second-largest Scope 3 item. Three starting points:
Reusable systems in B2B shipping
Foldable reusable shipping boxes save up to 76 % of CO2 emissions and 94 % of waste compared with single-use cardboard – provided the return rate is above 90 % (source: hey circle GmbH; circular-technology.com). The prerequisite is a fixed delivery/return relationship with your most important customers. At a unit price of 40 euros per reusable box and 50 circulation cycles, packaging costs come to around 0.80 euros per shipment – compared with about 1.20 euros for a sturdy single-use carton.
Carton optimisation and volumetric weight
Shipping tariffs of the major carriers (DHL, UPS, GLS) are based on volumetric weight; an oversized carton with air cushions pays twice: in material and in freight costs. Automatic carton height adjustment (e.g. CMC CartonWrap, B+ Equipment) reduces carton consumption by 25–40 % and volume by 30–50 %.
Void fill: paper instead of plastic
Recycled void-fill paper or honeycomb paper replaces bubble wrap and polystyrene chips, can be used in parallel with the same cardboard packaging in many operations, and ends up as waste paper in an established material cycle.
Employees and mobility
Electric forklifts instead of diesel/LPG
In an industrial facility with 20 forklifts, switching to electric can save 50,000–100,000 kWh of energy annually, reducing CO2 emissions by up to 40 tonnes (source: Toyota Material Handling, industry analysis). Energy costs are typically 40–50 % lower than for diesel; maintenance effort drops by 30–50 % because wear parts such as the injection system, clutch and exhaust are eliminated. Lithium-ion batteries (instead of lead-acid) enable opportunity charging during breaks – the need for battery-swap charging disappears, and the space required for charging stations decreases.
Ergonomic routes as a CO2 lever
Short picking routes save not only time but also energy: every avoided forklift kilometre corresponds to about 0.2 kWh of electricity or 0.07 litres of diesel. ABC classification and slotting optimisation of storage locations typically reduce forklift travel by 10–20 %.
Commuting and company bicycle leasing
Your employees’ commuting falls under Scope 3.7 (Employee Commuting) and is subject to reporting under ESRS E1-6. Company bicycle leasing, job tickets and carpooling platforms are documentable measures – and at the same time attractive employee benefits in a tight labour market.
Data collection and reporting
The data requirements under ESRS E1 to E5 are more extensive than many medium-sized businesses assume. Even those not directly subject to reporting requirements will need the core data for supplier questionnaires:
| ESRS | Topic | Specifically to be recorded in the warehouse |
|---|---|---|
| E1 Climate change | Scope 1/2/3 emissions, energy mix, transition plan | kWh electricity, m³ gas, litres diesel, km driven by forklifts/cars |
| E2 Pollution | Solvents, refrigerants, microplastics | VOC quantities, F-gas logbook for refrigeration systems |
| E3 Water | Water withdrawal/discharge | m³ drinking/process water, infiltration |
| E4 Biodiversity | Surface sealing, land use | sealed m², retention areas |
| E5 Resource use | Material flows, waste, recycled content | tonnes of cardboard, film, steel – each with recycled content |
Practicable tools for medium-sized businesses are the ecoinvent database for emission factors, Plan A or ClimatePartner for carbon accounting, the BAFA (German Federal Office for Economic Affairs and Export Control) guide “Wegweiser Energieeffizienz im Unternehmen” and the DIN ISO 50001 energy management system (sensible anyway from an electricity consumption of >500 MWh/year). Make sure your figures are traceable: electricity and gas figures from your energy supplier’s invoices, forklift consumption from fleet management, packaging quantities from goods-in accounting.
For the modernisation itself, the following funding programmes are currently available: the German federal funding programme for energy and resource efficiency in industry (EEW) via BAFA subsidises individual measures such as compressed air, pumps and waste heat utilisation; Module 4 (energy- and resource-related optimisation) reimburses small companies 15 % and medium-sized companies 10 % of eligible investment costs from 10,000 euros per measure. From 2026, some programmes will additionally require a transformation plan describing the strategic path to greenhouse gas neutrality (source: BAFA, energieeffizienz-und-prozesswaerme).
Quick start: 10 measures with ROI < 2 years
- LED conversion of hall lighting with presence and daylight sensors. Payback 18–30 months, 60–80 % electricity savings.
- High-speed doors to replace heavily used sectional openings. Payback 12–24 months via heating costs.
- Compressed-air leakage programme: ultrasonic testing, marking and sealing leaks. Typical savings 15–25 %, payback <6 months.
- Variable-speed compressors instead of fixed speed. Payback 18–24 months.
- Waste heat utilisation from compressed-air compressors → hall heating/domestic hot water. Payback 12–36 months.
- Electric forklifts at the next fleet reinvestment, Li-ion with opportunity charging. Life-cycle costs 20–30 % lower than diesel.
- ABC slotting in WMS master data: A-items to the picking front. 10–20 % less travel, no investment.
- Peak-load management with electricity load-profile analysis. Reduces the capacity charge by 5–15 %.
- Carton height adjustment or right-sizing per shipment. 25–40 % less carton material, similar reduction in shipping costs.
- Reusable boxes for regular customers with a fixed return rate. 50–70 % less packaging CO2 per shipment.
Frequently asked questions
My company is not subject to CSRD – do I still have to report?
Formally no, in practice yes. As soon as you have a directly reporting-obliged customer or a bank as your main banking relationship, you will be asked for Scope 1/2 data. The same applies to insurers and to public-sector clients, who increasingly ask for DIN ISO 14001 or comparable evidence.
Is photovoltaics worthwhile on a hall with low electricity consumption?
Yes, if the self-consumption share remains above about 40 % – otherwise the return drops, because the feed-in tariff of approx. 7–8 cents/kWh is far below the electricity purchase price. For shift operations or warehouses with high daytime electricity demand (refrigeration, compressed air), the economics are almost always favourable.
Does it make sense to replace old racking just to increase the recycled content?
No. The embodied energy in racking that is already installed is spent – the CO2 lever lies in extending its service life, not in premature replacement. Inspect annually in accordance with DIN EN 15635, repair instead of replacing. The material criteria only come into play at the next reinvestment.
How precisely do I have to record Scope 3 data?
ESRS E1 allows sector-negotiated estimates as long as the calculation methodology is disclosed. For steel products, use the manufacturer’s EPD values, or alternatively sector-negotiated industry values (ecoinvent, GEMIS); for packaging, the carton-specific value according to FEFCO. What matters is consistency over the years – not the last decimal place.
What does an ESRS-compliant initial data compilation cost?
For a medium-sized warehouse with 50–200 employees, external consulting costs for the initial assessment range between 15,000 and 40,000 euros, depending on the data situation. With a BAFA energy audit (Module 1 cross-cutting energy consulting), part of this is eligible for funding of up to 80 %, capped at 6,000 euros for SMEs.
Are reusable boxes realistic for small shippers?
Only for fixed delivery/return relationships with B2B regular customers. For scattered customers in online shipping, the return rate is rarely high enough; there, switching to better-dimensioned cardboard packaging and recycled material is more worthwhile.
Conclusion
Sustainability in the warehouse in 2026 is neither a marketing topic nor an end in itself. CBAM is making primary-material-intensive racking and workbench frames more expensive with immediate effect; the second CSRD wave will bring data requirements by 2027 at the latest that are already hitting medium-sized businesses today via bank enquiries and supplier ratings. At the same time, the economic levers are as clear as rarely before: LED, high-speed doors, compressed-air optimisation and electric forklifts pay for themselves in 1–3 years through lower energy costs – completely independently of the carbon footprint. Anyone who, in the same logic, also asks about recycled content and EPDs at the next racking purchase reduces their Scope 3 footprint along the way without spending additional money. Start with the three core data points of electricity, gas and fuel – everything else builds on this foundation. You will need the data anyway; and once you have it, most measures with a positive net present value identify themselves.