EU CSRD: What Manufacturers Must Know Now
The Corporate Sustainability Reporting Directive keeps shapeshifting: first the 2022 headlines, then the August 2024 ESRS release, and now a February 2025 “stop-the-clock” that chopped 80 % of companies from scope. The rules are still coming for thousands of building-product makers that sell into Europe’s supply chains. Skip the noise and see what the directive really demands—and how the product-level data you already collect for an EPD can tick half the boxes.
CSRD in one minute
Think of CSRD as Europe’s new reporting league. If the old Non-Financial Reporting Directive covered a village, CSRD covers a metropolis: up to 50 000 EU firms plus about 10 000 non-EU multinationals before the latest carve-outs (Deloitte, 2024). In May 2025 the Commission proposed yanking 80 % of smaller companies from scope and delaying wave two and wave three filings to 2028 (EC Sustainable Finance Newsletter, 2025). Yet wave one—mostly listed firms over 500 workers—must still file 2024 data in 2025.
Who still needs to comply and when
Until lawmakers finish debating the Omnibus package, the safest timeline is the original three-wave model, adjusted by the February 2025 delay:
- Wave one: large listed entities (reports in 2025).
- Wave two: large private groups above two of the 250-20-40 thresholds (reports in 2028).
- Wave three: listed SMEs (reports in 2029).
- Non-EU parents with €150 m EU turnover: reports in 2030.
Auditors will verify the data, and every report lands in digital XBRL tags that investors can scrape in seconds.
The data menu auditors will order
CSRD follows the European Sustainability Reporting Standards (ESRS). Environmental sheet E1 alone asks for absolute GHG totals, reduction targets, and granular Scope 3 breakdowns. ESRS E5 drills into resource use and circular economy. If you make insulation, rebar, or floor systems, that means cradle-to-gate emissions per kilogram, not vague corporate averages.
Why product numbers trump corporate averages
Construction buyers already compare EPDs when chasing LEED v5 or French RE2020 points. ESRS simply moves the same scrutiny up the chain. A product-level carbon factor published in an EPD can feed both client tenders and the parent company’s Scope 3 line item—avoiding double data collection hell. The Commission’s July 2025 “quick fix” even lets early reporters omit some forward-looking climate risk text, but not hard numbers (EC Quick Fix, 2025).
Turning your EPD workflow into a CSRD shortcut
If you have a recent EN 15804-A2 EPD, you already store: energy bills, raw-material weights, transport legs, waste streams. That is 70 % of the evidence ESRS auditors will ask for on GHGs, water, and materials. The same life-cycle model can spin out company-level Scope 3 inventories by adding sales volumes. Ths reuse of models is the hidden budget win.
Choosing a data partner without gray hairs
Look for three traits:
- Data-wrangling muscle. Fielding spreadsheets from plant managers on three continents beats any fancy dashboard.
- Audit trail discipline. Every input needs a source file and version history.
- Program-operator fluency. Publishing with IBU or Smart EPD trains consultants in the evidence style CSRD auditors crave.
Fees vary with portfolio size, so insist on scoping sessions rather than price lists.
Key takeaways for busy manufacturers
CSRD is not just investor fluff; it is a legally binding, audit-level demand for verified environmental metrics. Product EPDs already contain most of the hard data, so scaling that workflow today is the fastest way to dodge future fines and win specs tomorrow.
Frequently Asked Questions
Does an existing EN 15804-A2 EPD cover all CSRD environmental metrics?
Not all, but most. EPDs give robust cradle-to-gate GHG, resource, and waste figures. You still need corporate energy use, strategy narratives, and some forward-looking climate-risk details outlined in ESRS E1 and E4.
Will the February 2025 Omnibus package really exclude companies under 1 000 employees?
The Commission proposed the cut, but it is not final law yet. Parliament and Council debates run into late 2025, so plan on current thresholds until the directive gets amended (EC Sustainable Finance Newsletter, 2025).
Is third-party EPD verification enough for CSRD assurance?
Helpful but not sufficient. CSRD requires a limited assurance opinion over the full report, so auditors will still sample your underlying process data and controls.
How often will CSRD data need updating?
Annually, aligned with your financial year. If you publish EPDs on a five-year cycle, keep the life-cycle model alive in between to refresh production volumes and utility bills each year.
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.
