Product End-of-Life Reporting for Consumer Goods: CSRD Circular Economy Requirements

Whether you’re a consumer brand, manufacturer, or retail-led business, product end-of-life is now a visible part of sustainability reporting. Some organisations report under CSRD directly; others use VSME voluntarily to respond to customer, investor, or distributor requests.

Either way, CSRD brings greater focus on what happens after a product is sold—how it is disposed of, recycled, repaired, or reused. For consumer goods companies, this is central to circular economy disclosures and closely linked to Scope 3 emissions.

This guide explains how to approach end-of-life reporting in a practical, proportionate way.

Why End-of-Life Matters Under CSRD

Under ESRS E5 (Resource use and circular economy), companies must explain how their products contribute to resource efficiency and waste reduction across the value chain. For consumer goods, the use and disposal phase is often a material impact area.

End-of-life information is used to:

• Assess circularity and waste prevention
• Support claims about recyclability or durability
• Estimate Scope 3 emissions from product disposal

Many businesses first encounter these requirements through broader CSRD compliance expectations rather than standalone waste reporting.

Assessing Product Recyclability

Recyclability assessments do not need to be overly technical at the outset.

Common approaches include:

• Identifying main materials (plastic, paper, metal, mixed)
• Assessing whether components are widely recyclable in EU markets
• Flagging elements that prevent recycling (mixed materials, coatings)

Good practice is to document:

• Percentage of product weight that is recyclable
• Key assumptions used (e.g. “widely recyclable in EU municipal systems”)

These assessments often feed directly into broader waste and circular economy disclosures, as described in the resource use & circular economy topic hub.

Take-Back, Collection, and Extended Producer Responsibility

Where take-back schemes or producer responsibility systems apply, CSRD expects transparency rather than perfection.

Relevant disclosures may include:

• Participation in national EPR schemes
• Voluntary take-back or return programmes
• Partnerships with recyclers or refurbishers

Even if schemes are managed by third parties, companies should document:

• Which products are covered
• Countries where schemes apply
• Approximate volumes collected, if available

If no take-back programme exists, explaining why and outlining future plans is acceptable.

Repair, Refurbishment, and Reuse Options

Repairability and reuse are increasingly relevant for durable consumer goods.

Examples of proportionate reporting:

• Availability of spare parts
• Repair services or authorised partners
• Design choices that extend product life

Narrative disclosures are often sufficient, supported by simple indicators (e.g. average product lifespan or warranty period). These measures also help demonstrate alignment with circular economy principles beyond waste management.

Calculating Scope 3 Disposal Emissions

End-of-life emissions fall under Scope 3, Category 12 (End-of-life treatment of sold products).

For most small and mid-sized companies, estimation is acceptable. Typical steps include:

1. Estimating total product weight sold
2. Applying average disposal routes (recycling, landfill, incineration)
3. Using standard emission factors

Assumptions should be documented clearly and applied consistently year-on-year. A broader explanation of Scope 3 estimation approaches is available in Scope 3 emissions for consumer goods suppliers.

Reporting End-of-Life Information Clearly

In practice, end-of-life data is usually reported as part of:

• Circular economy disclosures
• Waste and materials narratives
• Scope 3 emissions tables

Many organisations align this structure with VSME to keep reporting manageable, even when CSRD is not mandatory. This makes the information reusable across sustainability reports and customer questionnaires.

Frequently Asked Questions

Do all consumer goods companies need to calculate end-of-life emissions?

Only if end-of-life is material to your products’ impacts. Many consumer goods companies include high-level estimates rather than detailed calculations, especially in early reporting years.

How accurate do recyclability percentages need to be?

CSRD prioritises transparency over precision. Reasonable estimates with clear assumptions are acceptable, particularly for small and growing businesses.

What if we don’t control disposal behaviour?

You are not expected to control consumer behaviour. Reporting should be based on typical or average disposal routes in your main markets, using recognised data sources.

Can this be reported without specialist software?

Yes. Many companies use spreadsheets and public emission factors. The key is consistency and documentation, not complex tooling.

Key Terms

• CSRD – Corporate Sustainability Reporting Directive
• ESRS E5 – Resource use and circular economy standard
• Scope 3 – Indirect value-chain emissions
• End-of-life – Disposal, recycling, or reuse of sold products
• EPR – Extended Producer Responsibility

Next Steps

Start by mapping your main product categories and materials. Assess recyclability at a high level, document any take-back or repair options, and estimate disposal emissions using standard assumptions.

With a structured and proportionate approach, end-of-life reporting becomes a manageable part of circular economy compliance—supporting both CSRD readiness and more sustainable product design over time.