Auto Repair: How to Track Waste Oil, Tyres, and Hazardous Materials for CSRD

Auto repair and service workshops handle several forms of hazardous and regulated waste — from used engine oil to brake fluids, tyres, and chemical cleaners. Under the Corporate Sustainability Reporting Directive (CSRD) and the Voluntary Sustainability Reporting Standard for SMEs (VSME), small and medium-sized garages are expected to demonstrate responsible management of these materials.

This guide walks you through a practical, step-by-step process to track, record, and report waste oil, tyres, and hazardous materials in line with VSME Basic Module B7 – Resource Use, Circular Economy and Waste Management. For broader guidance, see the CSRD guide for auto repair shops and what waste categories you must report.

1. Why Tracking Workshop Waste Matters

Even small garages generate significant quantities of oil residues, tyres, filters, and brake fluids — all of which fall under environmental regulations. Proper tracking:

• Ensures legal compliance with national waste handling laws
• Demonstrates environmental responsibility under CSRD or VSME reporting
• Builds trust with customers and large fleet partners
• Reduces costs through efficient recycling contracts

Under CSRD: Larger companies must report on their value-chain impacts. If your workshop services fleets or corporate clients, they may ask you for your waste management data.

2. What You Need to Track

According to the VSME Basic Module (B7), every SME should disclose:

• Total annual waste generated, broken down by type (hazardous / non-hazardous)
• Waste diverted to recycling or reuse
• Material use and circularity practices, such as reusing parts or recycling fluids

For auto services, this typically includes:

3. Step-by-Step: How to Track and Record Workshop Waste

Step 1 – Identify Waste Streams

Walk through your workshop and list all activities that produce waste:

• Oil changes → used oil, filters
• Tyre replacements → used tyres
• Brake service → brake fluid, pads, metal parts
• Cleaning → solvent containers, cloths

Group them under hazardous or non-hazardous categories.

Step 2 – Set Up Simple Collection Points

Use labelled, sealed containers:

• Waste oil – metal drums with bunded storage to prevent leaks
• Filters and absorbents – closed bins or boxes
• Tyres – stack in a clean, dry area
• Chemical containers – stored in separate fire-resistant cabinets

💡 Tip: Most EU countries require certified waste carriers. Keep your waste carrier licence number on file.

Step 3 – Keep Disposal and Collection Records

For each waste collection or disposal, record:

• Date of collection
• Waste type (e.g., oil, tyre, coolant)
• Quantity (litres, kg, or units)
• Carrier or recycler’s name and permit number
• Final destination (recycling, recovery, or disposal site)

Store copies of waste transfer notes or receipts — these serve as your audit trail.

Step 4 – Summarise Monthly and Annual Totals

At the end of each month:

• Add up quantities for each waste category
• Convert units if needed (e.g., 1 litre = 0.9 kg for waste oil)
• Note any recycling percentages or reuses

Use this table to report your annual data in your VSME sustainability statement or your CSRD-aligned supplier form.

Step 5 – Work with Certified Recyclers

Always use approved recyclers or waste management partners who can provide:

• Waste transfer documentation
• Certificates of recycling or disposal
• Annual summaries (many can export directly to Excel)

This not only meets compliance but also simplifies your CSRD reporting.

4. Example: Simple Workshop Waste Report

Company: EcoGarage Services Ltd Year: 2024 Employees: 8 Report Type: VSME Basic Module B7

This table can be attached to your sustainability report or client documentation.

5. Reporting Under VSME and CSRD

Under VSME (B7 – Waste Management)

You must disclose:

• Total waste generated (hazardous vs non-hazardous)
• Recycling rates or evidence of circular economy practices

Under CSRD/ESRS (E5 – Resource Use and Circular Economy)

Larger firms must show how suppliers (like garages) manage:

• Hazardous materials safely
• Waste disposal and recycling percentages
• Compliance with EU waste and chemical regulations

Providing structured data — even on a voluntary basis — helps your customers meet their own value-chain reporting duties.

6. Common Pitfalls and How to Avoid Them

7. Quick Wins for Greener Workshops

• Switch to bulk oil delivery systems to cut packaging waste.
• Encourage tyre retreading or recycling schemes.
• Replace solvent cleaners with water-based alternatives.
• Join a local waste co-operative to share recycling costs.
• Train staff on waste segregation and spill prevention.

Frequently Asked Questions

Do I need to track every small quantity of waste oil and tyres?

For VSME reporting, you should track all waste that’s material to your operations. While you don’t need to measure every single drop, you should have reasonable estimates based on waste transfer notes, invoices from waste collectors, or purchase records (e.g., if you buy 100 litres of oil, track how much becomes waste). Keep a simple logbook or spreadsheet to record waste quantities monthly or quarterly.

What happens if I mix hazardous and non-hazardous waste?

Mixing hazardous and non-hazardous waste can create legal compliance issues and makes proper disposal more difficult. Use separate containers with clear labelling, and ensure your waste carrier is licensed to handle each type. For CSRD reporting, you need accurate data on waste types to report properly under VSME B7. If you’ve mixed waste, work with a licensed carrier to properly separate and dispose of it.

See the complete auto repair guide →

Can I report waste recycling even if I don’t have receipts?

While receipts and waste transfer notes are the best evidence, you can still report recycling if you have other documentation like invoices from recycling companies, records from waste management contracts, or data from waste tracking systems. The key is having verifiable data. If you’re missing receipts, start collecting them going forward and note any data limitations in your disclosure.

How do I calculate emissions from waste disposal?

Waste disposal emissions typically fall under Scope 3 (indirect emissions from waste treatment). You can estimate these using standard emission factors based on waste type and disposal method (landfill, incineration, recycling). For example, waste oil sent for recycling has lower emissions than landfill disposal. Many waste carriers can provide emission data, or you can use national or EU average factors for your waste types.

Key Terms

• CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464) setting sustainability disclosure rules.
• VSME – Voluntary Sustainability Reporting Standard for SMEs, EFRAG 2024.
• Basic Module (B7) – Waste and circular economy disclosure under VSME.
• Hazardous Waste – Waste posing risk to human health or the environment (e.g., oil, chemicals).
• Waste Transfer Note – Document proving proper disposal by a licensed carrier.
• Scope 3 Emissions – Indirect emissions from waste treatment, logistics, or product end-use.
• Circular Economy – Practice of reusing, recycling, and minimising waste.