CSRD Reporting for Manufacturing SMEs: Energy, Waste, and Pollution Explained

Manufacturing businesses are under pressure to show how they use energy, manage waste, and prevent pollution. With the Corporate Sustainability Reporting Directive (CSRD) and the Voluntary Sustainability Reporting Standard for SMEs (VSME), even smaller manufacturers are being asked for reliable data.

This guide explains what to report, how to keep it simple, and how to use the VSME Basic Module to get started.

Why This Matters for Manufacturers

• Energy: Machinery, heating, and compressed air systems are energy-intensive.
• Waste: Offcuts, packaging, and hazardous residues are part of production.
• Pollution: From paint booths, boilers, or chemical storage.

Large companies must report under CSRD, and they will expect sustainability data from their suppliers. Small and growing businesses (SMEs) that prepare now will stay competitive and build trust with customers, banks, and regulators.

Step 1: Tracking Energy Use

What to record:

• Electricity: from utility bills.
• Fuels: gas, diesel, LPG, heating oil.
• Renewable vs. non-renewable: if you know the mix.

Emissions explained simply:

• Scope 1 = fuel you burn yourself (e.g., natural gas boiler).
• Scope 2 = electricity you buy.
• Intensity = total emissions ÷ turnover (€). Learn more about what counts as Scope 1 vs Scope 2 and our step-by-step guide to reporting Scope 1 and 2 emissions.

Quick win for small and growing businesses (SMEs): Keep last year’s bills in one place. Some suppliers already provide annual usage summaries — perfect for your report. If you buy green electricity, mention it.

Step 2: Managing and Reporting Waste

Report on:

• Total waste (tonnes or kg) - see our guide on waste and recycling reporting for manufacturers.
• Split into hazardous (e.g., solvents, oils) and non-hazardous (e.g., cardboard, scrap metal).
• How much goes to recycling or reuse - learn more about how to track recycling and reuse.

Why it matters: Waste reporting shows efficiency and compliance with national rules.

Quick win: Ask your waste contractor for an annual report. Track obvious streams like packaging, scrap, and hazardous containers. Mention reuse initiatives like sending pallets back to suppliers.

Step 3: Reporting Pollution

Types of pollution:

• Air: fumes, dust, VOCs.
• Water: process wastewater.
• Soil: leaks from oil or chemical storage.

If you already report pollutants under an environmental permit, reuse that data. If your processes have little or no emissions, say so — honesty is valued more than silence.

Quick win: If you’ve installed filters, switched to water-based paints, or invested in closed-loop water systems, highlight these improvements.

Step 4: Using the VSME Standard

The VSME Basic Module is designed for small and growing businesses (SMEs) and covers:

• B3: Energy and emissions.
• B4: Pollution.
• B7: Waste and circular economy.

This gives your customers and lenders the essentials without the heavy burden of full CSRD reporting. Larger manufacturers may ask suppliers to use these datapoints.

Step 5: Keep It Simple

Here’s a lightweight system:

1. Collect: Energy bills, waste invoices, permit data.
2. Record: Use a spreadsheet with three tabs — Energy, Waste, Pollution.
3. Report: Once a year, aligned with your financial reporting.
4. Improve: Note small actions like LED lighting, reduced packaging, or machine efficiency upgrades.

Benefits for Your Business

• Stay in supply chains: Larger customers will prefer suppliers who can show sustainability data.
• Cut costs: Tracking energy and waste often reveals easy savings.
• Finance-ready: Banks are asking for ESG information.
• Reputation: Local communities and employees value transparency.

Frequently Asked Questions

Do small manufacturers need to report under CSRD?

Most small manufacturers are not directly required to report under CSRD, which applies to large companies (250+ employees, €40M turnover, or €20M assets). However, many manufacturers need to provide sustainability data to large buyers, corporate clients, or banks who are CSRD-compliant. The VSME Standard offers a simplified, voluntary framework for manufacturers to meet these supply chain requirements efficiently.

Check if CSRD applies to your business →

What are the most important CSRD topics for manufacturers?

The key topics for manufacturers are: (1) energy use and emissions from production and equipment (VSME B3), (2) pollution including VOC emissions and waste (VSME B4, B7), (3) water use for production processes (VSME B6), and (4) workforce health and safety (VSME B9). These align with the CSRD’s focus on environmental and social impacts and are most relevant to manufacturing operations.

Learn about VOC emission reporting →

How do I track energy use from multiple production lines or sites?

Collect energy data from each production line or site separately (using utility bills, sub-meters, or equipment monitoring), then aggregate the totals across all locations for your annual report. You can also report intensity metrics (e.g., kWh per unit produced or per € turnover) to normalize for production volume. This allows you to identify which lines or sites are most energy-intensive and where efficiency improvements would have the biggest impact.

Can I use existing ISO 14001 or environmental permit data for CSRD reporting?

Yes! You can reuse data from your ISO 14001 environmental management system, environmental permits, waste transfer notes, and any existing compliance documentation. The VSME Standard is designed to work with data you’re already collecting for regulatory compliance. Just organise your existing compliance data into the VSME Basic Module format (B1–B11) for your sustainability report.

Key Terms

• CSRD: EU law requiring large companies and listed SMEs to report sustainability data.
• VSME: Voluntary Sustainability Reporting Standard for SMEs.
• Basic Module: Minimum SME disclosures (energy, waste, workforce basics).
• Comprehensive Module: Adds detail on climate risks, governance, and social issues.
• ESRS: EU Sustainability Reporting Standards used by large firms.
• Scope 1: Fuel you burn directly.
• Scope 2: Electricity you buy.
• Turnover: Total annual sales.