Spend-based emission factors estimate a data center GPU at roughly 7,500 kg CO₂e. WSP & NVIDIA published the actual product carbon footprint. It's closer to 160.
That's roughly a 45x gap. And it's baked into a lot of Scope 3 inventories right now.
Here's how it happens. EEIO models assume dollars spent correlate with physical production — more spend, more materials, more energy, more emissions. The EPA's supply chain factors for semiconductor manufacturing (NAICS 334413) are 0.215 kg CO₂e per dollar. Apply that to a $35,000 H100 SXM card and you get roughly 7,500 kg CO₂e.
But product-level gross margins on these GPUs are high, almost 90%. Roughly nine out of every ten dollars reflects design IP, market positioning, and scarcity — not silicon, energy, or materials in the fab. EEIO doesn't distinguish between a dollar of copper and a dollar of semiconductor IP. It just multiplies.
The published PCF for the HGX H100 baseboard — ISO 14067-conformant, based on over 90% primary supplier data — is 1,312 kg CO₂e for the full 8-GPU baseboard. Closer to 160 kg per card once you account for the shared components. Not 7,500.
And the gap shifts depending on which NAICS code a company uses. Classify GPU purchases under "Electronic Computer Manufacturing" (334111) instead of semiconductors and the factor drops to 0.058 — but you still get a 12x overestimate. The classification isn't standardized, so two companies buying identical hardware can report very different Scope 3 numbers.
As more product carbon footprints become available for GPUs, memory, and servers, companies that switch from EEIO to LCA-based emission factors will likely see their IT hardware Scope 3 decrease significantly. That's not greenwashing — in this instance it's what happens when you replace a dollar proxy with actual manufacturing data.
Worth noting: this distortion is strongest for high-margin tech hardware. For commodity materials like steel or chemicals, EEIO factors can be reasonably close. The breakdown is specific to products where price has decoupled from physical production intensity.
