09. 07. 2026
The Corporate Sustainability Reporting Directive (CSRD) requires large European companies to disclose detailed environmental data at the packaging level, not just corporate totals. From fiscal year 2025 onwards, this means documenting material composition, recyclability validation, supply chain traceability, and end-of-life outcomes for each packaging SKU in your portfolio. Procurement teams must work with suppliers to collect product-specific data that auditors can verify, creating documentation chains from raw material sourcing through to post-consumer waste management.
The Corporate Sustainability Reporting Directive – Directive (EU) 2022/2464 – requires companies meeting size thresholds to publish audited sustainability statements alongside their financial reports. CSRD applies to companies with more than 250 employees, €50 million turnover, or €25 million total assets. For packaging procurement teams, CSRD means your sustainability claims must be documented at the individual packaging SKU level, not aggregated across product lines.
CSRD operates through the European Sustainability Reporting Standards (ESRS), published by the European Financial Reporting Advisory Group (EFRAG). ESRS E5 – Resource use and circular economy – sets the specific disclosure requirements for packaging materials. Under ESRS E5, companies must report the weight of packaging materials by type (paper/board, plastic, metal, glass), the percentage of recycled content, recyclability rates achieved through collection systems, and material flow throughout the value chain.
The documentation chain starts with your supplier. For molded fibre packaging, suppliers must provide material composition declarations showing pulp source and any additives or coatings. If the packaging contains recycled content, the supplier must provide chain-of-custody certificates tracing material back to certified recycling facilities. For virgin fibre, suppliers operating under Regulation (EU) 2023/1115 must provide Due Diligence Statements confirming deforestation-free sourcing. These supplier declarations form the foundation of your CSRD disclosure.
Recyclability claims require technical validation. CSRD auditors expect evidence that your packaging meets the EU definition of recyclable under Regulation (EU) 2025/40 Article 6. For fibre-based packaging, this means documentation showing the material passes sortation in existing collection systems and can be reprocessed without quality degradation. Testing laboratories provide recyclability certificates based on EN 13430 protocols, confirming your packaging meets the technical requirements.
End-of-life data closes the documentation loop. CSRD requires disclosure of actual recycling rates, not theoretical recyclability. This means obtaining data from waste management operators showing what percentage of your packaging was collected, sorted, and reprocessed. For B2B packaging, this typically involves working with your customers' waste contractors to document material flows. Consumer-facing brands often commission Extended Producer Responsibility (EPR) audits to quantify post-consumer collection rates by packaging type and geography.
CSRD shifts the burden of proof from verbal supplier claims to documented evidence chains. When evaluating molded fibre suppliers, request material declarations in a format aligned with ESRS E5 reporting requirements. The declaration should state pulp type (virgin or recycled), geographic origin of fibre, percentage of post-consumer recycled content if applicable, and presence of non-fibre components such as adhesives or coatings. Without this documentation, you cannot complete your CSRD disclosure.
Chain-of-custody certification becomes mandatory for recycled content claims. If your supplier states the molded fibre contains 40% post-consumer recycled content, ask for FSC Recycled or equivalent certification documentation. The certificate must link the specific production batch to certified recycling input sources. Batch traceability allows you to connect the packaging SKU in your CSRD report to the upstream material flow your auditor will verify.
Due diligence documentation addresses deforestation risk. Regulation (EU) 2023/1115 requires operators placing wood-fibre products on the EU market to collect geolocation data for harvest areas and confirm the material was not produced on land deforested after 31 December 2020. Your molded fibre supplier should provide a Due Diligence Statement per shipment, declaring compliance with EUDR requirements. This statement becomes part of your CSRD supporting documentation, demonstrating your packaging supply chain meets EU environmental safeguards.
Recyclability validation requires third-party testing evidence. CSRD auditors treat recyclability as a forward-looking statement requiring substantiation. Request test reports from your supplier showing the molded fibre packaging meets EN 13430 criteria for recyclability. The report should document material identification in sortation systems, reprocessing yield rates in paper mills, and confirmation that reprocessed fibre meets quality standards for secondary applications. These test reports support the recyclability disclosure in your ESRS E5 statement.
TRIDAS provides packaging-level documentation aligned with CSRD disclosure requirements as standard commercial practice. Material declarations state pulp composition and geographic sourcing, FSC chain-of-custody certificates trace recycled content back to certified input sources, and EUDR Due Diligence Statements accompany shipments under Regulation (EU) 2023/1115. TRIDAS sources pulp primarily from EU low-risk regions, simplifying the documentation chain for buyers subject to both CSRD and EUDR compliance obligations. EN 13430 recyclability validation for fibre-based packaging is conducted through third-party testing laboratories, with reports available to support customer disclosure requirements.
