What Counts as “Hazardous Waste” for CSRD Reporting?

Introduction

If your company produces or handles materials like oils, paints, batteries, or chemical solvents, you may need to classify part of your waste as “hazardous” for CSRD reporting.

Under the Corporate Sustainability Reporting Directive (CSRD) and ESRS E5 (Resource Use and Circular Economy), companies must disclose waste data — including hazardous and non-hazardous types. This requirement applies to both large manufacturers and smaller suppliers reporting voluntarily under the VSME Standard (EFRAG 2024).

This guide explains what counts as hazardous waste in the EU, how to identify it in your operations, and how to report it accurately and proportionately.

1. The Legal Definition of Hazardous Waste

The term “hazardous waste” is defined in EU Directive 2008/98/EC (Waste Framework Directive) as waste that displays one or more hazardous properties (HP1–HP15), such as toxicity, flammability, or corrosiveness.

A waste is considered hazardous if it:

• Appears on the European List of Waste (LoW) with a hazardous code (marked with an asterisk “*”), or
• Exhibits hazardous characteristics under the CLP Regulation (EC No 1272/2008).

These classifications are used by all EU Member States and underpin CSRD reporting for environmental disclosures.

2. Common Examples of Hazardous Waste in Manufacturing and Automotive Sectors

Typical hazardous waste streams for small and growing businesses (SMEs) in manufacturing or automotive industries include:

Even small quantities (e.g. under 100 kg per year) must be reported as hazardous if they carry these classifications.

3. How to Identify Hazardous Waste in Your Business

To determine whether your waste is hazardous:

1. Check your waste codes (EWC/LoW codes) on collection invoices or manifests.
   • Hazardous waste codes end with an asterisk “*” (e.g. *13 02 05* – mineral-based engine oils).
2. Review Safety Data Sheets (SDS) for substances used in your operations — they indicate whether waste residues are hazardous.
3. Ask your waste contractor — licensed handlers are required to classify waste correctly under EU law.
4. Maintain records of quantities, storage, and transfer for audit and assurance purposes.

These records support both CSRD and local environmental compliance obligations.

4. Reporting Hazardous Waste Under CSRD and VSME

In your CSRD or VSME report, hazardous waste data typically appears under:

• ESRS E5-4: Waste generated (by type and disposal method).
• VSME B8: Resource use and waste management.

You should report:

• Total waste generated (tonnes/year)
• Share of hazardous vs. non-hazardous waste
• Disposal method: recycling, recovery, or landfill
• Any reduction initiatives (e.g. waste separation or chemical substitution)

Example disclosure:

“In 2025, the company generated 2.4 tonnes of waste, of which 0.3 tonnes were classified as hazardous (used oil, solvent residues, and contaminated rags). All hazardous waste was handled by licensed contractors and 100% sent for recovery or recycling.”

This level of transparency meets the VSME proportionality principle while aligning with full CSRD expectations for ESRS E5 compliance.

5. Estimating Data if Exact Weights Are Unavailable

If your waste contractor doesn’t provide detailed weights, you may estimate quantities based on:

• Collection frequency (e.g. monthly drum collection)
• Container size and fill level
• Average waste density (e.g. 0.9 kg/L for oil, 0.6 kg/L for solvents)

Document your assumptions clearly, as explained in how to estimate missing data for CSRD reporting. Over time, request more precise data from contractors to improve accuracy.

6. How to Reduce Hazardous Waste

Reducing hazardous waste not only lowers environmental impact but can also cut disposal costs and improve safety. Practical actions include:

• Switching to water-based paints and detergents.
• Using closed-loop oil recycling systems.
• Improving material segregation to avoid contamination of non-hazardous waste.
• Training staff on hazard identification and storage.

You can report these actions under ESRS E5-5 (Waste Prevention and Recycling Initiatives) or VSME B8 (Resource Efficiency Measures).

Frequently Asked Questions

Does small-scale hazardous waste need to be reported?

Yes. Even small quantities (under 100 kg/year) should be included if hazardous by classification. You can report them proportionally in tonnes or kilograms.

What if the waste contractor doesn’t share hazardous classifications?

Request the EWC/LoW codes from your contractor. If unavailable, classify based on the waste source and Safety Data Sheets.

Can hazardous waste be recycled?

Yes. Many hazardous materials (e.g. oils, batteries, solvents) can be safely recovered or treated by specialised facilities. Always record the recovery method.

Should packaging contaminated with chemicals be included?

Yes. Packaging that has contained hazardous materials is also classified as hazardous unless fully cleaned.

Key Terms

• Hazardous waste – Waste posing risk to health or the environment under EU Directive 2008/98/EC.
• EWC/LoW code – European Waste Catalogue code identifying waste type.
• ESRS E5 – European Sustainability Reporting Standard for resource use and circular economy.
• VSME B8 – Voluntary SME disclosure covering waste and resource management.
• HP properties (HP1–HP15) – EU hazard categories used to classify dangerous waste.

Conclusion

For CSRD and VSME reporting, hazardous waste includes any material classified under EU law as potentially harmful, even in small amounts. The key to compliance is clear classification, transparent reporting, and responsible handling through licensed contractors.

By tracking EWC codes, keeping disposal records, and disclosing your management methods, your company demonstrates both legal compliance and environmental responsibility.

To learn how to integrate waste data into your wider sustainability cycle, see our annual CSRD reporting calendar.