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:
- Collect: Energy bills, waste invoices, permit data.
- Record: Use a spreadsheet with three tabs — Energy, Waste, Pollution.
- Report: Once a year, aligned with your financial reporting.
- 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.
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.