CSRD for manufacturers: what to know now
If Europe is part of your sales map, the Corporate Sustainability Reporting Directive is not background noise. It is the new operating system for investor‑grade sustainability data, and it touches product choices, supplier screening, and the credibility of every EPD you publish. Nearly 50,000 companies are expected to be in scope, which means your customers and competitors are reading from the same rulebook (European Parliament, 2022). ([europarl.europa.eu](https://www.europarl.europa.eu/news/en/press-room/20221107IPR49611/sustainable-economy-parliament-adopts-new-reporting-rules-for-multinationals?_cldee=0jxga2uvlr9xr0GH3uIePIDscS0ICWy8I-VLynQdlxB5YtyVRTr2cMxJLHmZNsRL&esid=a42f54eb-5c5f-ed11-9561-6045bd8952ce&recipientid=contact-ab85bbf7cca1eb11811a001dd8b72b61-07f98f57b0ea48fc93aa3f9823120520&utm_source=openai))
)
Ensure that you use no text, as this illustration will be used on international translations of the article..
Use an illustrative style (e.g. isometic) and don't generate in a photorealistic style.](/_next/image?url=%2Fapi%2Fmedia%2Ffile%2Ffe6e6ec76232.webp&w=3840&q=75)
CSRD in plain English
CSRD is the EU rule that moves sustainability reporting from glossy PDFs to audited, comparable numbers. Reports follow the European Sustainability Reporting Standards, or ESRS, and sit inside the annual management report, not off on a marketing page. Think of ESRS as the table of contents that investors and procurement teams will actually use.
Who is in scope and when
Wave one companies that were already reporting under the old NFRD filed CSRD reports in 2025 for financial year 2024. Other large EU companies report in 2026 for financial year 2025. Listed SMEs follow in 2027, with a temporary opt‑out available in the first year. Non EU groups with over €150 million EU turnover enter for financial year 2028. These dates matter for suppliers because data requests cascade months earlier (European Parliament, 2022). (europarl.europa.eu)
2025 reset you should actually care about
Two changes shifted planning. First, the EU formally postponed adoption of sector specific ESRS and the non EU ESRS set to 30 June 2026, so companies can focus on the base ESRS now (Council of the EU, 2024). (consilium.europa.eu)
Second, a political deal in December 2025 signaled narrower future scope for CSRD, aimed at companies with more than 1,000 employees and over €450 million turnover. Treat that as pending until the final law is published and in force, but plan scenarios now (European Parliament, 2025). (europarl.europa.eu)
What ESRS actually pulls from your product world
ESRS E1 asks for Scopes 1 and 2, and material Scope 3. For most manufacturers, purchased goods and services, use, and end of life dominate Scope 3. Product level LCA data, ideally third party verified in EN 15804 EPDs, turns guesswork into defensible numbers that pass assurance. Without it, you are stuck with generic datasets that make your footprint look worse than it actually is.
Win A $50 Amazon Gift Card in One Click!
Enter weekly raffle in one click • Help us get to know our readers and improve!
EPDs are the credible building blocks
An EPD will not tick every ESRS box, but it anchors the hardest pieces. Bill of materials, energy mixes, waste routes, transport distances, packaging, and declared unit mappings flow straight into Scope 3 and circularity narratives. When bids in Europe ask for EN 15804 format, an existing product specific EPD removes the penalty many buyers apply to non disclosed impacts.
Data to start pulling this quarter
Aim for one reference year per plant, per product family. Lock the following, then let your LCA partner do the wrangling so engineers keep building:
- Utility bills by meter, with renewables contracts and residual mix details
- Inbound materials by supplier, mass, and transport mode
- Scrap, yield loss, and waste destinations with EWC codes
- Outbound transport profiles and packaging specs
If a product is new, three months of production data can start a prospective EPD, then true up after a full year. That gets sales into specs alot sooner.
Assurance is not a footnote
CSRD requires limited assurance today with a pathway to reasonable assurance later. The Commission’s 2025 quick fix extended phase ins for early reporters, yet auditors still expect traceable datasets, role owners, and version control (European Commission, 2025). (finance.ec.europa.eu)
Interoperability is improving
The EU and ISSB published guidance to reduce overlap, so reporting to both should feel less like double entry bookkeeping. That alignment lowers friction for multinationals with UK, Canada, or other ISSB based regimes in play (Reuters, 2024). (reuters.com)
Smart sequencing to cut cycle time
Do not wait for sector standards. Build product LCAs and EPDs first, then roll them up into ESRS metrics. Pick partners who handle internal data collection and project management, not just modeling, so your R&D and plant leads stay focused on output rather than spreadsheets.
Bottom line for manufacturers
CSRD is raising the bar on decision grade data across Europe, and EPDs are the fastest way to turn your operations into numbers buyers trust. Nail the product math now, keep an eye on the 2026 standard set and any scope changes, and you will be ready whether the final net catches 50,000 companies or fewer (European Parliament, 2022; Council of the EU, 2024; European Parliament, 2025). (europarl.europa.eu)
Frequently Asked Questions
Does CSRD require us to publish EPDs for every product?
No. CSRD requires ESRS based disclosures, not EPDs. EPDs provide high‑quality product data that feed Scope 3 and circularity metrics, and they reduce risk in assurance.
We sell into the EU but are not headquartered there. Are we in scope?
Current law captures non‑EU groups with more than €150 million EU turnover for financial years starting 2028. A later political deal proposes raising scope thresholds, but treat that as pending until enacted.
Should we wait for sector‑specific ESRS?
No. The two‑year delay sets the adoption date to 30 June 2026. Use the base ESRS, EFRAG implementation guidance on materiality and value chains, and build your product LCAs now.
How does this help in bids and specs?
Product‑specific EPDs cut the default penalties buyers apply when data is missing, and they map to EN 15804 which many European tenders reference. That boosts credibility and keeps you in the running on non‑price factors.
About the Author
John brings a clear, research-driven perspective on the EPD, LCA and HPD space and keeps a close pulse on environmental trends and standards in North America, helping clients understand where the industry is heading and how to get there.
