Burning pallets with energy recovery
Pallets sent with mixed trash to a waste-to-energy plant are combusted with energy recovery. EPA recorded 1.65 million tons of wood packaging handled this way in 2018. WARM credits it at −0.58 MTCO2E per short ton; EPA's Hub inventory factor is 0.05, because inventory figures leave out the displaced electricity.
Two factors, two purposes
Use the Hub factor in your inventory and keep the WARM-based comparison in a separate avoided-emissions note, as the GHG Protocol's Scope 3 Standard asks (Box 5.6). The ESG guide walks through it.
| Use | Factor (per short ton) | What it includes |
|---|---|---|
| Avoided-emissions estimate (WARM v16) | −0.58 MTCO2E | Transport, N2O, minus utility emissions displaced (Exhibit 12-13) |
| Scope 3 category 5 inventory (EPA Hub 2025, Table 9) | 0.05 MTCO2e | Transport and non-biogenic emissions only |
Mixed trash versus clean wood
Most pallets that reach a waste-to-energy plant arrive mixed with other trash. That differs from biomass fuel, where sorted, ground wood is sold to a boiler. Both use WARM's combustion factor, but only the second gives you a documented tonnage.
Massachusetts' wood ban covers landfills, not combustion facilities (310 CMR 19.017), and North Carolina's pallet ban is not on its incineration list (G.S. 130A-309.10(f1)). Neither law bans sending pallets to combustion.
Sources
- Containers and Packaging: Product-Specific Data (wood packaging, 1960–2018) U.S. EPA. Accessed October 27, 2026. Page last updated October 19, 2026; latest data year 2018.
- Documentation for Greenhouse Gas Emission and Energy Factors Used in WARM, Version 16: Construction Materials Chapters, ch. 12 Wood Products (EPA-530-R-23-020) U.S. EPA. Accessed October 27, 2026. Exhibits 12-3 (p. 12-3), 12-9, 12-13, 12-15 and 12-16 (p. 12-10).
- GHG Emission Factors Hub 2025, Table 9 (Scope 3 Category 5 and Category 12) U.S. EPA Center for Corporate Climate Leadership. Accessed October 27, 2026. The 2025 Hub is the latest listed on the Hub page on the access date.
- Corporate Value Chain (Scope 3) Accounting and Reporting Standard GHG Protocol (WRI/WBCSD). Accessed October 27, 2026. Box 5.6 and section 9.5 on avoided emissions; section 5.5 category descriptions.
- 310 CMR 19.017 Waste Bans Massachusetts DEP (text via Cornell LII). Accessed October 27, 2026.
- N.C. Gen. Stat. § 130A-309.10 (prohibited acts; disposal bans) North Carolina General Assembly. Accessed October 27, 2026.