Sustainable Sourcing Requirements for Consumer Brands: CSRD Compliance
Whether you’re a small consumer brand, a growing D2C business, or a subsidiary supplying larger retail groups, sustainable sourcing is now a core part of sustainability reporting. Some organisations report under CSRD directly; others use VSME voluntarily to meet customer and investor expectations.
Either way, CSRD has shifted the focus from broad commitments to documented, verifiable sourcing practices. For consumer brands, this means being able to show how products are sourced responsibly, how suppliers are selected, and how claims made to customers are supported by evidence.
This guide focuses specifically on consumer brands (rather than large FMCG manufacturers), with an emphasis on practical documentation rather than complex supply-chain modelling.
Why Sustainable Sourcing Matters Under CSRD
CSRD requires companies to disclose not only their own operations, but also material impacts and risks in their value chains. For consumer brands, sourcing is often where the most significant social and governance risks sit.
Key drivers include:
- Labour conditions at supplier sites
- Ethical business conduct and purchasing practices
- Credibility of sustainability claims made on products and packaging
Retail customers and distributors increasingly expect this information too. Many brands first encounter CSRD through customer requests, as explained in CSRD supplier requirements: what small businesses should expect in 2025.
Ethical Supplier Selection Criteria
Consumer brands are expected to show how suppliers are chosen, not just who they are.
Common criteria include:
- Compliance with labour and human rights standards
- Health and safety practices
- Absence of child or forced labour
- Anti-bribery and ethical business conduct
In practice, this is usually documented through:
- Supplier codes of conduct
- Contract clauses or onboarding checklists
- Self-assessment questionnaires
You do not need a complex scoring system. What matters is that criteria are defined, applied consistently, and reviewed over time.
Certifications: What CSRD Expects (and What It Doesn’t)
Certifications can support sustainable sourcing claims, but they are not mandatory under CSRD.
Common examples for consumer brands include:
- Fair Trade
- Organic (EU Organic, Soil Association, etc.)
- FSC or PEFC (for packaging or paper products)
- SA8000 or similar social standards
Under CSRD and VSME, certifications are treated as supporting evidence, not substitutes for disclosure. Brands should document:
- Which certifications are used
- Which suppliers or products they cover
- Any limitations or partial coverage
Over-reliance on logos without explanation can create reporting gaps or greenwashing risks.
Traceability Documentation That Actually Works
Traceability does not mean full blockchain-based tracking for most small brands.
Typical, proportionate documentation includes:
- Supplier lists by product or category
- Country of origin records
- Tier 1 supplier contracts and invoices
- Basic material or ingredient breakdowns
For many consumer brands, Tier 1 visibility is sufficient initially. Deeper tiers can be added gradually where risks are higher or where customers request it. A similar step-by-step approach is described in supply chain traceability for apparel SMEs.
Verifying and Supporting Sustainability Claims
CSRD places strong emphasis on verifiability. Claims made in marketing or on packaging should be traceable back to internal records.
Good practice includes:
- Keeping evidence centrally (certificates, policies, audits)
- Matching claims to actual supplier coverage
- Avoiding absolute language (“100% ethical”) unless fully substantiated
This is especially important as CSRD reporting becomes subject to assurance. Clear documentation reduces the risk of future corrections or reputational issues.
How Consumer Brands Report This Information
For small and growing brands, sustainable sourcing is usually reported as part of:
- Business conduct disclosures
- Value-chain workers disclosures
- Narrative explanations supported by metrics
Many brands structure this using VSME as a baseline, even if reporting is voluntary. This makes data reusable across customer questionnaires and future CSRD reports. For an overview of this approach, see CSRD for SMEs: the complete 2025 guide.
Frequently Asked Questions
Do small consumer brands need formal sustainable sourcing policies?
Not always, but having a simple written policy is strongly recommended. Even a two-page supplier code of conduct helps demonstrate consistency and intent under CSRD and VSME.
Are certifications required to be CSRD-compliant?
No. Certifications are helpful evidence, but CSRD focuses on transparency and documentation rather than labels. Brands should explain what certifications cover and where gaps remain.
How detailed does supplier traceability need to be?
For most consumer brands, Tier 1 supplier traceability is sufficient initially. Deeper tiers can be added for higher-risk products or where customers explicitly request it.
Can this be managed without external consultants?
Yes. Many brands manage sourcing documentation in-house using spreadsheets and shared folders. The key is structure and consistency, not expensive systems.
Key Terms
- CSRD – Corporate Sustainability Reporting Directive
- VSME – Voluntary Sustainability Reporting Standard for SMEs
- Value-chain workers – Workers employed by suppliers and contractors
- Business conduct – Ethical behaviour, anti-corruption, responsible purchasing
- Traceability – Ability to identify origin and movement of goods or materials
Next Steps for Consumer Brands
Start by documenting how suppliers are selected and what minimum standards apply. Gather existing evidence—contracts, certificates, invoices—and organise it centrally. Then align this information with VSME or CSRD disclosure logic so it can be reused across reports and customer requests.
With a clear structure and realistic scope, sustainable sourcing reporting becomes a practical business process rather than a compliance burden.