Managing Hazardous Materials Under CSRD: Compliance for Manufacturers

Whether you operate a small workshop, a specialist production line or a multi-process facility, hazardous materials form part of daily manufacturing reality. Some organisations now report under CSRD directly, while many others use the VSME Standard voluntarily to provide accurate information to larger customers. In both cases, chemical handling, storage, waste and reporting procedures increasingly influence supplier qualification, customer audits and risk assessments.

CSRD strengthens expectations around pollution, chemical use and safe business conduct. It requires large companies to disclose their impacts on air, water and soil (ESRS E2), and many rely on supplier-level hazardous material data to complete their reporting. The VSME Standard mirrors this by requiring SMEs to disclose pollutants emitted if already reported to regulators or environmental management systems (B4) . CSRD also recognises that value-chain partners — including small suppliers — contribute essential sustainability information that large undertakings must incorporate into their disclosures .

This guide explains how small manufacturers can meet hazardous material reporting expectations, build safe and compliant processes, and align CSRD practices with mandatory chemical regulations such as REACH, CLP, and sector-specific requirements.

1. Why Hazardous Materials Matter Under CSRD

Hazardous materials are relevant to CSRD for three main reasons:

1. Pollution disclosures

Facilities that emit regulated pollutants into air, water or soil must report those quantities under VSME B4 when already submitting them to authorities or environmental management systems . For manufacturers, this can include:

• VOCs from coatings, adhesives or printing
• Particulates or solvents from machining, finishing or cleaning
• Metal compounds used in plating or surface treatment
• Wastewater contaminants from rinsing or etching

2. Resource use & waste management

Manufacturing processes using hazardous materials also generate hazardous waste, which must be tracked under VSME requirements for waste by type (hazardous vs non-hazardous) and recycling or reuse volumes (B7) .

3. Business conduct and compliance

CSRD emphasises transparent, lawful operation. Hazardous substances are directly linked to compliance duties under EU laws such as REACH, CLP and Seveso. Manufacturers must be able to demonstrate safe handling, worker protection and supply-chain due diligence.

For foundational compliance topics, the pollution topic hub and resource use & circular economy hub offer deeper frameworks that complement this guide.

2. Building a Manufacturing Chemical Inventory for CSRD

A complete chemical inventory helps your organisation comply with REACH and directly supports CSRD pollution and waste disclosures. Small factories often maintain this in a spreadsheet, but the structure should be consistent and updated annually.

What your chemical inventory should include

Aligning the inventory with VSME and CSRD

VSME expects SMEs to disclose relevant pollutants if legally required or already reported (B4) and to describe practices and policies that reduce environmental impact (B2) . A well-maintained chemical inventory allows you to:

• Identify which materials generate reportable pollutants
• Track hazardous waste quantities by type
• Demonstrate responsible sourcing and handling practices
• Provide evidence to customers during supplier assessments

3. Safe Handling and Storage Practices for Manufacturing Facilities

Manufacturing environments create multiple exposure pathways — heat, pressure, aerosols, open processes, spraying and welding. Clear procedures reinforce compliance with both CSRD expectations and mandatory worker-safety legislation.

Core practices to document and disclose if relevant to your operations

1. Safety Data Sheet (SDS) management

• Maintain up-to-date SDS for all chemicals.
• Ensure operators can access the most current versions.
• Review SDS Sections 8, 9 and 13 for CSRD-relevant information (exposure, stability, disposal).

2. Labelling and CLP compliance

• Apply correct pictograms and hazard statements.
• Replace worn or damaged labels immediately.

3. Engineering controls

• Local exhaust ventilation for solvents, fumes, mists or particulates
• Explosion-proof ventilation for flammable substances
• Enclosed dispensing systems for high-risk processes

4. Personal protective equipment (PPE)

• Chemical-resistant gloves, respirators or masks depending on the substance
• Annual PPE suitability review, documented for audits

5. Spill response and containment

• Maintain suitable absorbents, neutralisers and waste containers
• Train workers on spill response and reporting

These practices reflect VSME B2 expectations, which allow organisations to describe policies and initiatives for reducing negative environmental and social impacts .

4. Hazardous Waste Management for Manufacturers

Waste generated from hazardous materials is a key CSRD disclosure area.

What you must track under VSME

VSME B7 requires manufacturers to disclose:

• Total hazardous waste generated
• Total waste diverted to recycling or reuse
• Material flows for sectors with significant material use (e.g., machining, coating, plating)

Waste types common in manufacturing

• Spent solvents and solvent-containing wipes
• Paint sludge, overspray and contaminated filters
• Acid/alkali baths from metal finishing
• Contaminated absorbents from spills
• Heavy-metal solids or sludge from wastewater treatment
• Contaminated PPE

Documentation to maintain

• Waste transfer notes or consignment documentation
• EWC (European Waste Catalogue) codes
• Weights, containers, treatment routes, recycling data
• Invoices or certificates from licensed waste contractors

By maintaining complete waste documentation, manufacturers simplify annual CSRD or VSME reporting and demonstrate transparent waste control.

5. Controlling Air, Water and Soil Emissions

Manufacturers often have legally defined permit limits for emissions. Where these emissions are already reported to authorities, VSME B4 requires SMEs to disclose pollutants and their quantities in CSRD-aligned reporting .

Common manufacturing emissions

• Air: VOCs from coatings, particulates from machining, fumes from welding
• Water: Heavy metals, oils, suspended solids, acids, alkalis
• Soil: Rare, but can occur through outdoor handling, spills or fuel storage leaks

How to integrate this into CSRD reporting

• Map each emission source to its chemical inventory
• Ensure evidence (lab results, monitoring reports, permits) is stored with other CSRD documentation
• Identify pollution-reduction initiatives to report under VSME B2, such as closed-loop cleaning systems or low-VOC product substitution

For more detail, the pollution topic hub explains broader ESRS expectations.

6. Linking CSRD Requirements With REACH and CLP

Although CSRD is a reporting framework and REACH is a regulatory scheme, the two complement each other:

REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals)

REACH obligations help you demonstrate lawful and safe business conduct — a key CSRD theme. Manufacturers must:

• Ensure all substances are registered by suppliers
• Check if substances are on the Candidate List (SVHC)
• Evaluate whether Authorisation or Restriction applies
• Maintain exposure scenarios and risk management measures

CLP (Classification, Labelling and Packaging)

CLP classifications provide hazard categories that feed directly into:

• Pollution risk assessments
• Chemical inventory structuring
• Worker health and safety training
• Downstream customer notifications

How this ties into CSRD

The CSRD Directive emphasises transparency, legal compliance and value-chain accountability. It recognises that business partners — such as manufacturers handling hazardous materials — supply essential information for sustainability disclosures . Combining REACH/CLP processes with VSME reporting allows SMEs to respond confidently to customer requests.

7. Practical Templates for Small Manufacturers

A basic hazardous-materials management system typically includes:

Chemical Inventory

• Substance name, CAS, CLP classification
• Annual use and storage volume
• REACH status
• Compatible PPE and handling rules
• Disposal method and EWC code

Emissions & Waste Log

• Pollutant type
• Monitoring results or estimates
• Waste volumes by type
• Contractor documentation

Incident Record

• Spills, leaks or near misses
• Corrective actions
• Follow-up training

These templates can be adapted to your VSME reporting, especially if customers request annual sustainability information.

For broader resource management guidance, see the resource use & circular economy hub.

Frequently Asked Questions

Do small manufacturers need to measure all chemical emissions for CSRD?

Not unless you are already required by law or environmental permits. VSME B4 requires SMEs to disclose pollutants only when these emissions are already reported to authorities or established through an environmental management system. For factories with solvent use, metal finishing or water discharge, this typically includes VOCs, metals, acids or particulates.

How does REACH compliance support CSRD reporting?

REACH records — especially SDS, exposure scenarios and SVHC notifications — provide the foundation for your pollution, hazardous waste and business-conduct disclosures. They demonstrate that substances are lawfully sourced and safely managed. For waste and material tracking guidance, see the resource use & circular economy hub.

What documentation should I keep for hazardous waste?

SMEs should retain waste transfer notes, EWC codes, disposal certificates, and annual summaries of hazardous vs non-hazardous volumes. This information supports VSME B7 disclosures and helps customers evaluate your environmental management practices.

Do I need expensive software to track chemicals for CSRD?

No. Most small manufacturers maintain compliant chemical inventories and waste logs using spreadsheets and contractor records. Software becomes valuable only when multiple sites, complex processes or customer audits increase. The pollution topic hub provides additional guidance on structuring this data.

Key Terms

• Hazardous material: Any chemical or substance classified under CLP as dangerous to health, environment or safety.
• REACH: EU regulation governing registration and safe use of chemicals.
• CLP: EU classification and labelling system for hazardous substances.
• Pollutant: A substance released to air, water or soil that may require reporting under VSME B4.
• EWC code: European Waste Catalogue classification for waste materials.
• SVHC: Substances of Very High Concern under REACH.

Conclusion

Managing hazardous materials under CSRD is less about creating new systems and more about integrating existing compliance obligations — REACH, CLP, waste documentation, monitoring reports — into a structured reporting process. For small manufacturers, a well-maintained chemical inventory, clear handling procedures and consistent waste tracking provide a strong foundation. These practices protect workers, reduce environmental impact and equip your organisation to respond confidently to customer sustainability requests.

With a clear structure and consistent effort, CSRD becomes an advantage — not an obstacle.