What Waste Categories Must SMEs Report Under CSRD?

The Corporate Sustainability Reporting Directive (CSRD) is mainly aimed at large companies, but many small and medium-sized enterprises (SMEs) will be asked by banks, investors, or bigger clients to provide waste information. The good news: the categories you need to report are straightforward.

Waste Categories Under CSRD

Under the European Sustainability Reporting Standards (ESRS) — and the simplified Voluntary Sustainability Reporting Standard for SMEs (VSME) — SMEs should report their annual waste generation, broken down into two groups:

• Non-hazardous waste Everyday waste that does not pose a direct risk to people or the environment. Examples: paper, packaging, food waste, plastics, wood, textiles.

• Hazardous waste Waste containing harmful substances that require special handling. Examples: solvents, oils, paints, batteries, fluorescent tubes, electronic waste.

In addition, SMEs should also disclose:

• Waste diverted to recycling or reuse — how much was recovered rather than sent to landfill or incineration. See how to track recycling and reuse.
• Material flows (if relevant) — companies in material-heavy sectors (like manufacturing, construction, or packaging) should also track the main raw materials they use. Learn if packaging materials count as material flows.

Why This Matters

• Non-hazardous waste: shows how effectively your business manages everyday resources.
• Hazardous waste: proves you handle high-risk materials safely and in line with regulations.
• Recycling/reuse: demonstrates support for the EU’s circular economy goals — something banks and customers increasingly value.

Practical Steps for SMEs

1. Check your waste invoices and contracts. Providers often give breakdowns by waste stream.
2. Keep hazardous waste certificates. Disposal companies must issue these — store them securely.
3. Ask for recycling rates. Waste collectors can provide percentages or weights.
4. Start with a simple split. Reporting just hazardous, non-hazardous, and recycled waste is enough for the VSME Basic Module.

Example Disclosure (Small Office)

In 2024, we generated 7 tonnes of waste: 6.5 tonnes of non-hazardous (mainly paper and packaging) and 0.5 tonnes of hazardous (electronic equipment and batteries). Of the total, 65% was recycled or reused.

Short, factual statements like this are usually sufficient.

Frequently Asked Questions

What counts as hazardous waste for an office-based business?

Typical hazardous waste in offices includes electronic equipment (WEEE), batteries, fluorescent tubes, toner cartridges, and cleaning chemicals. Even small volumes must be reported separately under VSME B7 because they carry different regulatory obligations. See What Counts as “Hazardous Waste” for CSRD for the full EU classification.

Do I need European Waste Codes (LoW codes) in my VSME report?

Not for the Basic Module — a simple split by hazardous versus non-hazardous is sufficient. LoW codes (from the European List of Waste, Directive 2008/98/EC) are used internally by waste contractors and on transfer notes. Comprehensive Module and full CSRD reports increasingly reference LoW codes for auditable traceability.

What if my business has zero hazardous waste?

Report “zero” explicitly — it is a valid disclosure. Avoid leaving the field blank, which auditors interpret as missing data rather than genuinely zero. A short sentence confirming your operations do not generate hazardous waste strengthens the disclosure.

Key Terms

• Corporate Sustainability Reporting Directive (CSRD) — An EU law requiring large companies — and eventually some medium-sized ones — to report on environmental and social impacts. SMEs may still be asked for CSRD-style data by banks or large clients.
• Voluntary Sustainability Reporting Standard for SMEs (VSME) — A simplified, voluntary framework to help SMEs provide sustainability data when requested.
• Basic Module — The minimum VSME reporting set, covering essentials such as energy, waste, emissions, and workforce data.
• Circular Economy — An approach that keeps materials in use for longer by recycling, reusing, or repurposing them.
• Hazardous Waste — Waste with harmful properties requiring special handling (e.g. chemicals, oils, batteries).
• Non-hazardous Waste — General waste streams without harmful properties, such as paper, packaging, and food waste.