Do Packaging Materials Count as “Material Flows” I Need to Disclose?
When preparing sustainability information under the Voluntary Sustainability Reporting Standard for SMEs (VSME) — or responding to requests linked to the Corporate Sustainability Reporting Directive (CSRD) — many small and medium-sized enterprises (SMEs) ask: do I need to report packaging as part of my “material flows”?
The short answer: yes, if packaging is a significant part of your business. For retail-specific guidance, see our guide on waste and packaging reporting for retail.
What Are “Material Flows”?
The VSME asks businesses in material-intensive sectors to disclose their use of key raw materials each year, usually measured in tonnes.
Typical examples include:
- Raw materials in manufacturing (e.g. metals, textiles, timber).
- Construction materials (e.g. cement, aggregates, steel).
- Agricultural inputs (e.g. fertiliser, animal feed).
This helps show how efficiently materials are being used, supporting the EU’s circular economy goals.
Where Packaging Fits In
Packaging can be part of your material flows if it makes up a large or visible share of what your business uses.
| When Packaging Counts | When It Usually Doesn’t Count |
|---|---|
| Food, e-commerce, or retail businesses using large volumes of packaging. | Professional services firms using only a few shipping boxes a year. |
| Manufacturers producing packaging as part of their products. | Small offices where packaging is negligible compared with other waste. |
| Businesses where packaging waste is a major environmental issue. | Businesses with little to no physical goods. |
If packaging is important to your operations or footprint, it’s best practice to include it in your disclosure.
How to Disclose Packaging
If packaging is relevant, you should:
- List main types of packaging — e.g. cardboard, plastics, glass, wooden pallets.
- Track usage data — invoices, supplier reports, or waste contractor records.
- Report totals in tonnes per year.
- Include recycling/reuse figures if available, to show progress towards circularity.
Example Disclosure (E-commerce SME)
In 2024, we used 25 tonnes of packaging material, mainly cardboard and plastic film. Of this, 18 tonnes (72%) were recycled or reused.
This gives a simple, factual statement that covers both usage and recycling performance.
Key Terms
- Corporate Sustainability Reporting Directive (CSRD) — EU law requiring large companies to report on environmental and social impacts. SMEs may be asked for CSRD-style data by banks or clients.
- Voluntary Sustainability Reporting Standard for SMEs (VSME) — A simplified reporting framework for SMEs aligned with CSRD themes.
- Basic Module — The minimum VSME reporting set, covering essentials like energy, waste, and workforce.
- Comprehensive Module — A more detailed version of VSME, sometimes requested by banks or larger customers.
- Material Flows — The key raw materials or packaging a business consumes, reported in mass terms (e.g. tonnes per year).
- Circular Economy — A system that keeps resources in use for longer through recycling, reuse, or repurposing.