CSRD for Manufacturers: Energy, Waste and Pollution

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.

If you are wondering whether your factory must file a CSRD report itself: almost certainly not. Since the Omnibus I directive took effect on 18 March 2026, CSRD applies only to companies with more than 1,000 employees and net turnover above €450 million. What reaches a manufacturing SME instead is the data request — a large customer, export buyer, or bank asking for energy, waste, and pollution figures — and those requests are now legally capped at what the VSME standard defines.

This guide explains what to track, how to keep it simple, and how to use the VSME Basic Module to answer those requests.

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.

Once the figures are collected, keeping them in one place pays off: an ESG answer bank lets you reuse the same energy, waste, and workforce answers for every request, and a free VSME report tool generates the finished report from them at no cost.

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.

Frequently Asked Questions

Do small manufacturers need to report under CSRD?

No. CSRD applies only to companies with more than 1,000 employees and net turnover above €450 million, so no small or mid-sized manufacturer is required to report under it. Many manufacturers do need to provide sustainability data to large buyers, corporate clients, or banks with their own CSRD obligations. The VSME Standard is the voluntary framework for answering those requests — and since Omnibus I it also caps what those buyers may ask a sub-1,000-employee supplier for.

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 companies with more than 1,000 employees and net turnover above €450 million to report sustainability data. SMEs are not in scope.
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.

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