Which companies must comply with CSRD reporting requirements?

CSRD applies to all EU companies exceeding two of three thresholds: over 250 employees, over €50 million annual turnover, or over €25 million total assets. Listed SMEs, non-EU companies with EU subsidiaries meeting size thresholds, and non-EU companies with over €150 million EU turnover also face CSRD obligations. First reporting year depends on company size: large public-interest entities report from 2025 (financial year 2024 data), other large companies from 2026, and listed SMEs from 2027.

What packaging data do I need to collect for ESRS E5 disclosures?

ESRS E5 requires quantitative metrics on packaging weight by material category, percentage of recycled content, percentage designed for recyclability, and actual end-of-life recycling rates where available. You need supplier-provided data on material composition, third-party recyclability test results under EN 13430 or equivalent standards, and lifecycle assessment data for cradle-to-gate carbon footprint per kilogramme of packaging. Generic industry averages do not satisfy ESRS requirements; you need product-specific verified data from each packaging supplier.

How does molded fibre packaging compare to plastic for ESRS E1 carbon disclosures?

Recycled paper pulp used in molded fibre packaging has a cradle-to-gate carbon footprint of 0.4–0.6 kg CO₂e per kilogramme of material. Virgin polypropylene emits 1.9–2.3 kg CO₂e per kilogramme, and virgin polystyrene emits 2.7–3.1 kg CO₂e per kilogramme. This difference appears in your Scope 3 Category 1 (purchased goods and services) emissions inventory. Molded fibre packaging also avoids end-of-life incineration emissions associated with non-recyclable multi-material plastic packaging, further reducing your reported value-chain emissions under ESRS E1.

What documentation proves EUDR compliance for molded fibre packaging?

EUDR requires a Due Diligence Statement per shipment confirming that paper pulp originates from land not deforested after 31 December 2020. Compliant suppliers provide geolocation data for pulp sourcing, FSC or PEFC chain-of-custody certificates tracing fibre origin, and risk assessment documentation classifying sourcing regions as low-risk under EUDR criteria. Suppliers sourcing from EU countries—classified as low-risk under EUDR—can provide simplified Due Diligence Statements without plot-level geolocation data, streamlining your ESRS E4 biodiversity disclosure process.

Can I use supplier-provided LCA data in my CSRD submission?

Yes, provided the lifecycle assessment follows ISO 14040 and ISO 14044 methodology standards and undergoes third-party critical review. ESRS requires transparency on data sources and calculation methods. Your auditor will assess whether supplier-provided carbon data uses consistent system boundaries, appropriate allocation methods, and up-to-date emissions factors. Suppliers with ISO 14001-certified environmental management systems typically maintain LCA data meeting ESRS verification requirements, reducing your need for internal data validation.

Does CSRD require reporting on packaging recyclability or actual recycling rates?

Both. ESRS E5 requires disclosure of the percentage of packaging designed for recyclability (forward-looking design metric) and, where data is available, actual recycling rates achieved for packaging you place on the market (backward-looking outcome metric). For new packaging formats or low-volume products, actual recycling rate data may not exist—ESRS allows you to report design-for-recyclability metrics and explain why outcome data is unavailable. Testing packaging against EN 13430 recyclability criteria and EN 643 paper grade classifications provides verifiable design-for-recyclability evidence.

What happens if my packaging supplier cannot provide CSRD-required data?

Inability to obtain supplier data creates a disclosure gap in your CSRD submission. ESRS requires you to report data gaps, explain why information is unavailable, and outline steps to close gaps in future reporting periods. Repeated data gaps in material categories signal weak supplier management to auditors and investors. If current suppliers lack environmental data infrastructure, CSRD timelines may require you to qualify alternative suppliers with ISO 14001 certification, FSC chain-of-custody documentation, and established lifecycle assessment data—capabilities increasingly standard among molded fibre packaging manufacturers serving EU markets.

How often must I update packaging sustainability data in CSRD reports?

CSRD requires annual reporting covering the previous financial year. You must update packaging data annually to reflect changes in material sourcing, recycled content percentages, supplier switches, and design modifications affecting recyclability. Static data carried forward from prior years without verification signals weak data governance. Suppliers providing automated data exports aligned with ESRS disclosure categories—material composition, carbon footprint per kilogramme, recycled content percentage, FSC certificate validity—reduce your annual data-collection burden and improve disclosure consistency across reporting periods.

Home / Insights / ESG reporting for EU non-food packaging buyers – molded fibre metrics / CSRD reporting – molded fibre metrics for your sustainability disclosures

10. 14. 2026

CSRD reporting – molded fibre metrics for your sustainability disclosures

The Corporate Sustainability Reporting Directive (CSRD), Directive (EU) 2022/2464, requires companies to disclose quantitative environmental data under European Sustainability Reporting Standards (ESRS). For companies using molded fibre packaging in non-food categories—cosmetics, electronics, audio, fashion accessories, fragrance, wine and spirits secondary packaging—you need verifiable metrics on material composition, recyclability, carbon footprint, and supply chain due diligence. Your CSRD submission depends on collecting packaging-specific data from suppliers, including fibre sourcing, recycled content percentages, end-of-life recyclability rates, and Scope 3 emissions per kilogramme of packaging. Molded fibre packaging offers measurable advantages in several ESRS disclosure categories, particularly ESRS E2 (pollution), ESRS E4 (biodiversity), and ESRS E5 (circular economy), but your reporting accuracy depends on supplier transparency and third-party verification of claims.

Key takeaways

CSRD applies to companies with over 250 employees or €50 million turnover from 2025
ESRS E5 requires recyclability rates and recycled content percentages per packaging material
Molded fibre packaging typically contains 70–100% recycled paper pulp content
Cradle-to-gate carbon footprint for recycled paper pulp: 0.4–0.6 kg CO₂e per kg
Virgin polypropylene emits 1.9–2.3 kg CO₂e per kg—substantially higher than recycled pulp

What CSRD reporting is and how it works for packaging buyers

The Corporate Sustainability Reporting Directive came into force in January 2023, expanding sustainability disclosure obligations beyond large public-interest entities to include all large companies and listed SMEs operating in the EU. The directive introduces the European Sustainability Reporting Standards (ESRS), a comprehensive framework covering environmental, social, and governance topics. Companies subject to CSRD must report quantitative data on their environmental impact, including detailed metrics on materials used, waste generated, and emissions across their value chain.

For packaging buyers, CSRD creates specific reporting obligations under three environmental standards. ESRS E2 (pollution) requires disclosure of microplastic release risks and hazardous substance content. ESRS E4 (biodiversity and ecosystems) mandates reporting on deforestation-risk commodities and land-use impact of raw materials. ESRS E5 (resource use and circular economy) requires quantitative data on recyclability rates, recycled content percentages, and packaging waste generation. These three standards directly affect how you report packaging material choices in your annual sustainability statement.

Molded fibre packaging intersects with CSRD requirements at several disclosure points. Under ESRS E5, you must report the percentage of packaging materials that meet recyclability thresholds—molded fibre packaging typically achieves 85–95% recyclability through existing paper waste streams, aligning with Packaging and Packaging Waste Regulation (PPWR) targets of 70% recyclability from 2030 and 80% from 2038. Under ESRS E4, you must disclose whether raw materials originate from deforestation-risk supply chains—molded fibre suppliers complying with the EU Deforestation Regulation (EUDR), Regulation (EU) 2023/1115, can provide Due Diligence Statements confirming pulp sourcing from low-risk EU regions. Under ESRS E2, you report on persistent chemical content and material degradation pathways—molded fibre avoids the PFAS, phthalates, and plasticiser disclosures required for many plastic alternatives.

Your CSRD submission depends on collecting supplier-specific data. Generic industry averages do not satisfy ESRS requirements; you need product-level metrics with third-party verification where material claims exceed standard industry practice. For molded fibre packaging, this means requesting lifecycle assessment (LCA) data, FSC chain-of-custody certificates, EUDR Due Diligence Statements, and laboratory test results confirming recyclability under EN 643 paper grade standards. Suppliers operating under ISO 14001 environmental management systems can typically provide structured data aligned with ESRS disclosure categories, reducing your internal data-collection workload.

What this means for packaging buyers under CSRD

CSRD shifts sustainability reporting from voluntary corporate communications to mandatory audited disclosures. Your packaging supplier selection directly affects your ability to meet ESRS quantitative thresholds. If your current plastic packaging supplier cannot provide cradle-to-gate carbon data or recyclability test results, you face disclosure gaps in your CSRD submission. Molded fibre suppliers with ISO 14001 certification, FSC chain-of-custody documentation, and EUDR compliance infrastructure can supply the verified metrics CSRD requires, reducing your reporting burden and audit risk.

ESRS E5 circular economy disclosures require you to report the percentage of packaging materials designed for recyclability. Under PPWR, Regulation (EU) 2025/40, fibre-based packaging must achieve 70% recyclability from 12 August 2030 and 80% from 12 August 2038. Molded fibre packaging designed to EN 13430 recyclability standards and tested under EN 643 paper grade classifications can demonstrate compliance with these thresholds today, giving you forward visibility on regulatory alignment. By contrast, multi-material plastic packaging—combining PP, PET, adhesives, and metallised films—often fails recyclability thresholds, creating disclosure liabilities under ESRS E5 and potential non-compliance under PPWR from 2030.

ESRS E4 biodiversity disclosures require you to identify whether packaging materials originate from deforestation-risk regions. EUDR applies from 30 December 2026, prohibiting placement of products containing forest-risk commodities from deforested land. Molded fibre packaging uses paper pulp—an EUDR-covered commodity. Suppliers sourcing pulp from EU low-risk regions and providing shipment-level Due Diligence Statements enable you to report zero-deforestation sourcing under both ESRS E4 and EUDR. Suppliers without EUDR compliance systems leave you with disclosure gaps and regulatory risk exposure.

ESRS E2 pollution disclosures address hazardous substances and persistent pollutants. Molded fibre packaging formulations avoid the PFAS coatings, heavy-metal pigments, and plasticiser additives found in many plastic alternatives. This simplifies your ESRS E2 reporting—you can disclose packaging material choices that eliminate entire categories of regulated substances rather than managing complex chemical inventories and migration test results.

TRIDAS perspective on CSRD-compliant packaging data

TRIDAS operates under ISO 14001 environmental management systems and maintains FSC chain-of-custody certification, enabling structured ESRS-aligned data provision. TRIDAS sources pulp primarily from EU low-risk regions and provides EUDR-compliant Due Diligence Statements per shipment under Regulation (EU) 2023/1115, supporting your ESRS E4 biodiversity disclosures. TRIDAS designs and manufactures its own molded fibre production lines, allowing process-level carbon accounting and lifecycle assessment data for cradle-to-gate emissions reporting under ESRS E1 climate disclosures. TRIDAS operates both wet press and dry press production technologies under one roof, enabling technology selection per application with documented recyclability validation under EN 13430 and EN 643 standards, supporting your ESRS E5 circular economy metrics.