Packaging & Waste Compliance for Small Consumer Brands

Whether you’re a small consumer brand placing products on the EU market or a manufacturer producing packaged goods, packaging and waste compliance is becoming a visible part of sustainability reporting. Some businesses report directly under CSRD; others follow the VSME standard voluntarily to meet customer and investor expectations.

Either way, packaging is no longer just an operational issue. Under CSRD, large retailers and brand owners must disclose how packaging materials are used, how waste is managed, and how circular design principles are applied across the value chain.

This guide explains what small and growing consumer brands need to understand about packaging and waste under CSRD—focusing on practical steps, proportionate data, and how brand responsibilities differ from retail operations.

Why Packaging Matters Under CSRD

Packaging sits at the intersection of resource use, waste, and pollution—all key disclosure areas under ESRS. For consumer brands, packaging often represents the most material environmental impact outside of manufacturing itself.

Retailers reporting under CSRD increasingly ask brands for structured information to support disclosures on:

• Packaging materials and recyclability
• Waste prevention and reduction
• Compliance with Extended Producer Responsibility (EPR) schemes

This links directly to broader CSRD expectations explained in the CSRD for SMEs: the complete 2025 guide.

Brand Responsibility vs Retail Operations

Understanding where responsibility sits helps avoid confusion.

Consumer Brand Perspective

As a brand placing packaged products on the EU market, you are typically responsible for:

• Packaging material choices
• Recyclability and design decisions
• EPR registration and reporting
• Providing packaging data to retailers

Retailer Perspective

Retailers focus on:

• Aggregated packaging impacts across suppliers
• Store-level waste handling
• Demonstrating due diligence in sourcing

This means brands are usually expected to provide packaging-level data, even if retailers handle waste collection in stores.

What Small Consumer Brands Need to Track

CSRD does not require enterprise-level detail from SMEs. What matters is relevance, consistency, and documentation.

Packaging Materials and Volumes

Retailers and regulators typically ask for:

• Packaging material types (paper, plastic, glass, metal)
• Weight per unit or per product category
• Primary vs secondary packaging

This data supports disclosures under resource use and waste and can usually be derived from packaging specifications or supplier invoices.

Recyclability and Circular Design

You may be asked:

• Is the packaging recyclable in typical EU systems?
• Are recycled or renewable materials used?
• Have unnecessary components been removed?

Documenting design choices is as important as metrics. Short explanations of why materials were selected—and what trade-offs exist—are often sufficient.

Extended Producer Responsibility (EPR)

Most EU countries require brands to:

• Register with national EPR schemes
• Report packaging volumes by material
• Pay fees linked to recyclability and weight

Under CSRD, retailers increasingly request confirmation that suppliers are EPR-compliant. Keeping registration confirmations and annual declarations on file is usually enough.

Waste and Pollution Considerations

Although packaging is the focus, CSRD also links to broader pollution topics.

For small brands, this usually involves:

• Avoiding hazardous substances in packaging
• Ensuring inks, coatings, or adhesives meet regulatory standards
• Describing measures to reduce packaging-related waste

This supports disclosures aligned with pollution topics without requiring laboratory-level data.

How to Document Packaging Compliance for CSRD

The biggest challenge for SMEs is not compliance itself, but presenting information clearly.

Create a Simple Packaging Register

A basic register can include:

• Product or SKU
• Packaging components
• Material type and weight
• Recyclability notes
• EPR scheme references

This forms the backbone of most retailer and CSRD-related requests.

Link Packaging Data to Reporting Narratives

CSRD values explanation alongside numbers. Be prepared to describe:

• How packaging decisions are made
• How waste reduction is considered
• What improvements are planned

This aligns well with structured reporting and disclosure expectations and reduces follow-up questions.

Common Pitfalls for Small Brands

Many brands overcomplicate packaging compliance. Typical issues include:

• Tracking every minor component with no material impact
• Assuming recyclability claims without documentation
• Confusing retailer waste handling with brand responsibility

Focusing on material packaging impacts and clear documentation is usually enough.

Frequently Asked Questions

Do small consumer brands need to report packaging under CSRD?

Most small brands are not required to report CSRD themselves, but they are often asked to provide packaging data to retailers that are in scope. Preparing structured information makes these requests manageable.

Is EPR compliance enough to meet CSRD expectations?

EPR compliance is a strong foundation, but retailers often ask for additional explanations on recyclability and design choices. Combining EPR data with short narratives works best.

How detailed does packaging data need to be?

Retailers generally accept reasonable estimates and averages from SMEs. Consistency across products and years is more important than perfect precision.

Can we manage packaging compliance without consultants?

Yes. Most small brands manage packaging data internally using specifications, invoices, and simple registers. Clear processes matter more than specialist tools.

Key Terms

• CSRD – Corporate Sustainability Reporting Directive
• EPR – Extended Producer Responsibility
• Recyclability – Ability of packaging to be processed in standard waste systems
• Circular Design – Packaging designed to minimise waste and maximise reuse or recycling
• ESRS – European Sustainability Reporting Standards

Conclusion and Next Steps

For small consumer brands, packaging and waste compliance under CSRD is less about complex reporting and more about clarity. Knowing your packaging materials, meeting EPR obligations, and documenting circular design choices puts you in a strong position with retailers.

By building a simple packaging register and linking it to clear explanations, you can respond confidently to CSRD-driven requests, reduce administrative burden, and demonstrate that your brand takes resource use and waste seriously. With a clear structure and consistent effort, packaging compliance becomes a practical part of sustainable growth.