Packaging Waste Obligations for Food Businesses: CSRD & EPR Compliance
Whether you’re a small food producer, beverage brand, or private-label supplier, packaging waste is now a core compliance topic. Some businesses report under CSRD directly; others use VSME voluntarily while meeting Extended Producer Responsibility (EPR) rules and retailer requirements.
Either way, food packaging sits at the intersection of circular economy, waste regulation, and sustainability reporting. This guide explains how CSRD and EPR fit together in practice, what food businesses are expected to document, and how to manage obligations without specialist teams.
Why Packaging Waste Matters Under CSRD and EPR
Food packaging is highly visible, highly regulated, and closely linked to environmental impacts such as waste, litter, and pollution.
Under CSRD (particularly ESRS E5):
- Companies must explain how resources are used and waste is prevented
- Packaging design and recyclability are key circular economy topics
- Data is often reused in Scope 3 and supplier disclosures
Under EPR:
- Producers are legally responsible for packaging placed on the market
- Registration, reporting, and fees apply at national level
- Retailers increasingly require proof of compliance
Many food businesses first encounter this through customer or retailer requests, similar to those described in CSRD supplier requirements: what small businesses should expect in 2025.
Understanding Food-Specific EPR Obligations
Who Is Responsible?
In most EU countries, the producer is the entity that:
- Places packaged food on the market under its own brand, or
- Imports packaged food into a country
This often includes:
- Small food brands
- Contract manufacturers selling under their own label
- Beverage producers
Even very small volumes can trigger EPR registration.
What Packaging Is Covered?
Food businesses typically need to report:
- Primary packaging (in direct contact with food)
- Secondary packaging (grouping, multipacks)
- Tertiary packaging (transport, pallets, wrap)
Materials commonly tracked include:
- Plastics
- Paper and cardboard
- Glass
- Metal
- Composite or multilayer materials
Clear material breakdowns are essential for both EPR and CSRD.
Recyclable Packaging Design: What “Good Practice” Looks Like
CSRD does not mandate specific packaging materials, but it does expect companies to explain how packaging choices support circularity.
Typical disclosures include:
- Use of recyclable or widely recyclable materials
- Reduction of mixed or hard-to-recycle components
- Packaging light-weighting or volume reduction
You do not need to redesign all packaging immediately. Explaining current design choices and future improvements is acceptable and often expected.
Waste Reduction Targets and Metrics
Under CSRD, food businesses may disclose:
- Total packaging placed on the market (by weight and material)
- Year-on-year changes
- Any reduction or redesign initiatives
Targets can be:
- Quantitative (e.g. % reduction in plastic weight)
- Qualitative (e.g. phase-out of non-recyclable formats)
What matters most is that targets are clearly defined and monitored, even if modest.
Registering with National EPR Schemes
EPR is implemented nationally, so requirements vary by country.
Most schemes require:
- Registration before placing packaging on the market
- Periodic reporting of packaging volumes
- Payment of eco-modulated fees
Food businesses operating in multiple EU countries may need multiple registrations. Keeping a simple register of:
- Countries
- Scheme names
- Registration numbers
helps both compliance and retailer audits.
Documentation Retailers Commonly Request
Retailers increasingly act as compliance gatekeepers.
Typical requests include:
- Proof of EPR registration numbers
- Packaging material breakdowns
- Confirmation of recyclability claims
- Short sustainability or packaging statements
This documentation often overlaps with CSRD disclosures on waste and circular economy. For broader circular reporting context, see the resource use & circular economy topic hub.
Aligning CSRD Reporting with EPR Data
One of the biggest efficiency gains comes from reusing EPR data for CSRD.
Good practice includes:
- Using the same material categories
- Aligning reporting periods
- Explaining differences between legal EPR data and sustainability narratives
This avoids double work and reduces inconsistencies between regulatory and sustainability reporting.
Frequently Asked Questions
Do small food businesses really need to register for EPR?
Yes. In most EU countries, even small volumes of packaging trigger EPR obligations if you place packaged food on the market under your brand.
Is EPR compliance enough for CSRD packaging reporting?
No. EPR focuses on legal responsibility and fees, while CSRD focuses on transparency, circularity, and strategy. However, EPR data is a strong foundation for CSRD disclosures.
Do compostable or bio-based packages remove EPR obligations?
Usually not. Most EPR schemes still require registration and reporting for compostable or bio-based packaging, and recyclability claims must be carefully documented.
Can this be managed without consultants?
Yes. Most small food businesses manage packaging compliance using spreadsheets, invoices, and scheme portals. Structure and consistency matter more than complexity.
Key Terms
- CSRD – Corporate Sustainability Reporting Directive
- EPR – Extended Producer Responsibility
- Packaging waste – Discarded packaging materials after use
- Circular economy – Designing out waste and keeping materials in use
- Eco-modulation – Fee adjustments based on packaging design
Next Steps for Food Businesses
Start by listing all packaging types and materials you place on the market, then confirm where EPR registration is required. Gather existing EPR reports, invoices, and registrations, and organise them centrally.
With a clear structure and consistent data, packaging waste obligations under CSRD and EPR become manageable—and can even support better packaging design and stronger retailer relationships over time.