Do Health SMEs Need to Report on Hazardous Waste?

Many care homes, clinics, dental practices, and small laboratories ask the same question when preparing for CSRD or VSME sustainability reporting:

“Do we really have to report our hazardous or medical waste?”

The short answer is: yes — but proportionately. If your business produces hazardous waste as part of healthcare delivery, you should acknowledge it under the VSME B7 (Resource Use and Waste) disclosure. However, you don’t need to provide complex or quantitative data unless the quantities are large or legally regulated.

Let’s break down what counts as hazardous waste, when to report it, and how to do so simply and correctly. For a comprehensive overview, see the CSRD guide for care homes and clinics and what waste categories you must report.

What Counts as Hazardous Waste in Health and Social Care?

Hazardous waste includes any materials that pose a risk to people or the environment and require special handling or disposal. For healthcare SMEs, this often means:

These materials are already tracked under national health, safety, and environmental laws, so you can often use the same data for CSRD and VSME reporting.

What CSRD and VSME Require

Under VSME Basic Module B7, SMEs must disclose:

• Total waste generated (tonnes)
• How waste is handled (recycled, recovered, disposed)
• Any significant or regulated hazardous waste streams

The CSRD Directive (Article 19a) confirms that SMEs should report proportionately — meaning:

• If your hazardous waste is small and already handled safely by a licensed contractor, a qualitative statement is sufficient.
• If your organisation generates large or regulated quantities (e.g. a diagnostic lab or hospital facility), include approximate volumes or weights.

How to Report Hazardous Waste Simply

Step 1 – Identify What You Already Know

Most healthcare SMEs already have:

• Annual waste collection certificates from their hazardous waste provider
• Invoices or transfer notes for clinical or sharps waste
• Regulatory compliance records (for inspection purposes)

These can serve as evidence for your CSRD or VSME report.

Step 2 – Add a Qualitative Disclosure

If the volume is minor (e.g. a few bins per week or month), you can write a brief narrative:

“The clinic produces limited quantities of hazardous waste (mainly clinical and sharps waste), collected weekly by a licensed disposal contractor. No spills or incidents were recorded in 2024.”

This satisfies VSME B7 and aligns with the CSRD proportionality principle.

Step 3 – Include Quantitative Data (Optional)

If you have figures available from your waste partner, include them in your disclosure table:

Narrative:

“All hazardous waste is managed by certified contractors in compliance with national legislation. Reduction achieved through improved stock control and reusable materials.”

When Hazardous Waste Reporting Becomes “Material”

You should treat hazardous waste as a material topic if:

• You operate on a large scale (e.g. hospital, diagnostic lab).
• You handle infectious, radioactive, or chemical materials.
• Disposal costs or risks are financially significant.

In these cases, include a separate section under VSME B7 and B2 (Practices and Policies) describing management systems and staff training.

What You Can Exclude

You do not need to report:

• Minor amounts of cleaning products or domestic-type waste already covered by general waste data.
• Household-like materials produced by residents or staff (if disposed of as regular waste).
• Supplier or patient-side waste (e.g. packaging or at-home disposables), unless it is material to your business model.

Example Disclosure for a Care Home

Organisation: Silver Meadows Care Ltd Type: Residential care home (50 residents)

Narrative:

“Hazardous waste consists of gloves, dressings, and sharps collected by a licensed waste provider under national healthcare regulations. All disposal records are retained for inspection.”

This concise disclosure meets both VSME and CSRD expectations.

Practical Tips for Health and Care SMEs

• Use existing compliance data — no need to measure waste again.
• Keep disposal certificates from your waste provider for verification.
• Train staff on proper segregation and labelling.
• Review annually — update volumes or practices if operations expand.
• Don’t overcomplicate: a short narrative is fully compliant for most SMEs.

How It Aligns with CSRD and VSME

Key Terms

• CSRD: Corporate Sustainability Reporting Directive (EU 2022/2464)
• VSME: Voluntary Sustainability Reporting Standard for non-listed SMEs (EFRAG, 2024)
• Hazardous waste: Materials posing a risk to health or the environment (e.g. medical or chemical waste)
• Clinical waste: Waste produced from healthcare procedures
• Sharps waste: Needles, blades, or items capable of causing injury
• Materiality: The significance of an issue to your business and stakeholders