CSRD Reporting for Construction SMEs: Material Use and Waste

The construction and real estate sectors are major contributors to material consumption and waste generation in Europe. For small and medium-sized enterprises (SMEs) operating in these sectors, the Corporate Sustainability Reporting Directive (CSRD) and the Voluntary Sustainability Reporting Standard for SMEs (VSME) provide a structured way to disclose environmental impacts — particularly around material use and waste management.

This guide explains how SMEs in construction and real estate can meet these requirements step by step, using simple data already available from project records, invoices, and site management systems. For related guidance, see what waste categories you must report and how to track recycling and reuse.

Why Material Use and Waste Matter Under CSRD

The CSRD — and by extension, the European Sustainability Reporting Standards (ESRS) — identifies resource use, circular economy, and waste management as key environmental topics for all sectors.

For construction, these topics are crucial because:

• Buildings and infrastructure account for around 50% of all raw material use in the EU.
• Construction and demolition generate over one-third of total EU waste.
• Material efficiency and recycling directly reduce emissions and costs.

Under the VSME Standard (Basic Module, B7), SMEs are expected to report:

• Whether they apply circular economy principles.
• The total annual generation of waste (hazardous and non-hazardous).
• The proportion of waste that is recycled or reused.
• For material-intensive sectors like construction, the annual mass-flow of materials used (e.g., tonnes of cement, steel, timber).

These disclosures align with ESRS E5 (Resource Use and Circular Economy) for larger companies, ensuring comparability across the value chain.

Step-by-Step: How Construction SMEs Can Report

1. Identify Relevant Materials and Flows

Start by listing the main materials your projects use. For most SMEs, these include:

• Concrete, bricks, and cement-based materials
• Metals (steel, aluminium, copper)
• Timber and engineered wood
• Insulation, plasterboard, tiles, plastics

Your procurement or project management software can usually provide this data through invoices or material delivery records.

Tip: Focus on high-volume or high-impact materials first — like cement and steel — as they drive both cost and emissions.

2. Estimate Annual Material Use

If exact quantities are unavailable, use:

• Bill of quantities (BoQ) or supplier invoices for major projects.
• Conversion factors (e.g., kg per m² of building area).
• Average material intensity ratios available from national building databases or life-cycle assessment tools.

Example:

A small construction firm building 3,000 m² of housing per year can estimate concrete use at ~250 kg/m², totalling 750 tonnes annually.

3. Track and Categorise Waste

The VSME Standard (B7b) asks for total waste by type:

• Non-hazardous waste (e.g., concrete rubble, wood offcuts, packaging)
• Hazardous waste (e.g., paint residues, adhesives, insulation with hazardous components)

Use your waste transfer notes, skip hire invoices, or municipal waste declarations to gather data. Even if quantities are approximate, consistent reporting is more valuable than perfect precision.

Then, indicate:

• Tonnes sent to recycling or reuse (e.g. crushed concrete reused as fill)
• Tonnes sent to landfill or incineration

4. Describe Circular Economy Practices

The CSRD encourages transparency on how materials are kept in use longer. Examples relevant to construction SMEs include:

• Reusing formwork, scaffolding, and site materials
• Designing buildings for deconstruction
• Using recycled aggregates or reclaimed bricks
• Partnering with waste recyclers for take-back schemes

Include short narratives such as:

“We separate wood, metal, and concrete waste on-site for collection by certified recyclers. Around 65% of our construction waste was recycled in 2024.”

5. Set Simple Targets and Track Progress

CSRD reporting is not only backward-looking. SMEs can set achievable annual goals, such as:

• Reducing waste per m² by 10% in two years
• Increasing recycled content in materials by 20%
• Ensuring 80% of construction waste is diverted from landfill

Track these using project-level data and report progress year-on-year in your sustainability report.

6. Disclose Using the VSME Template

Under VSME Basic Module – Resource Use, Circular Economy and Waste (B7), include a simple table like:

Narrative explanation (optional):

“Waste reduction achieved through improved sorting at demolition sites and supplier take-back of pallets.”

Linking Waste Data to Other CSRD Topics

Reporting on materials and waste connects with other CSRD and VSME areas:

This integrated approach reflects the double materiality principle — how environmental issues affect your business and how your business affects the environment.

Practical Example: SME Construction Firm

Company: EcoBuild Ltd (UK-based SME) Sector: Residential refurbishment and small commercial builds Employees: 35 Reporting scope: Basic Module (VSME)

Highlights:

• Material use (2024): 1,100 tonnes (mainly concrete, bricks, timber)
• Total waste: 260 tonnes (80% recycled)
• Waste intensity: 2.5 tonnes per 100 m² built
• Policy: Zero landfill by 2027 through reuse partnerships

This format meets VSME Basic Module expectations and provides usable data for clients subject to the CSRD.

Common Pitfalls to Avoid

• ❌ Ignoring subcontractor waste — include main site contractors and demolition works.
• ❌ Double-counting reused materials — only count waste once when it leaves your control.
• ❌ Overly technical language — keep disclosures clear for non-experts and financiers.
• ❌ Missing year-on-year comparison — always show previous-year data once available.

Making It Work for SMEs

You don’t need complex software to comply. Use:

• Excel-based trackers or free carbon calculators
• Waste management invoices
• Site diaries and monthly reports

VSME allows proportionality — report only what’s relevant and feasible, but be consistent and transparent.

Key Terms

• CSRD: Corporate Sustainability Reporting Directive (EU 2022/2464)
• VSME: Voluntary Sustainability Reporting Standard for non-listed SMEs (EFRAG, 2024)
• Basic Module: The minimum VSME reporting framework, including environmental, social, and governance metrics
• Comprehensive Module: Additional disclosures for SMEs with more data or investor needs
• ESRS: European Sustainability Reporting Standards
• SME: Small and medium-sized enterprise
• Scope 1 and 2 emissions: Direct and indirect emissions from owned and purchased energy sources
• Turnover: Total income from sales or services