CSRD, explained: How Europe’s reporting rules will change the way U.S. brands talk about (and design) plastic packaging

If PPWR tells you what your pack must be, the Corporate Sustainability Reporting Directive (CSRD) tells you what you must prove - and how. 

CSRD is part of the EU’s broader Green Deal push to decouple growth from resource use and make Europe the first climate-neutral continent. The goal is simple: the EU wants companies to compete on real performance on circularity, emissions, and social safeguards, not glossy PDFs. So it’s standardising sustainability disclosure - with audit-grade discipline - so investors, regulators, and customers can compare apples to apples.

2025 is the first big publication cycle for CSRD: thousands of EU companies are issuing audit-grade sustainability reports alongside their financials, which means procurement teams are actively asking suppliers to back packaging claims with evidence (recyclability protocols, verified PCR, chain of custody). Over the summer, Brussels also adopted a targeted “quick-fix” to the European Sustainability Reporting Standards (ESRS) to ease the first years of reporting and rolled out a voluntary SME standard so smaller suppliers can answer CSRD-driven data requests without boiling the ocean. In short: the paperwork is real, the timelines are live, and buyers need your packaging facts now.

In a webinar we hosted earlier this year on what American brands need to know about European packaging regulations, we spoke with Helena Mansilla Carpintero, who leads the EUDR and ESG Services at Peterson Solutions and lectures on Business Sustainability at EDEM School of Entrepreneurship. In this blog post, we capture her advice on what non-EU suppliers need to provide, and what US brands need to do to get CSRD-ready right now.

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A quick map of the EU landscape

The EU Green Deal isn’t a single law; it’s a program spanning climate, energy, industry, and circular economy. Two pieces matter most for packaging teams:

• PPWR (Packaging & Packaging Waste Regulation): product-side rules - design for recycling, recycled content, reuse, labelling, EPR fees.
• CSRD: reporting-side rules - what companies must disclose (and get assured) using ESRS standards (European Sustainability Reporting Standards).
  

Think of PPWR as the engineering spec and CSRD as the audit trail. U.S. teams selling into Europe will feel both - PPWR in packaging decisions, CSRD in the data you must generate and share with EU customers.

Helena’s take: CSRD is not “nice to have ESG.” It’s financial-reporting-grade for sustainability: repeatable processes, internal controls, and evidence trails that withstand assurance.

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CSRD 101 (without the jargon)

• Who’s in scope? Big EU companies first, then listed SMEs - with non-EU groups pulled in if they generate significant EU turnover and meet certain thresholds (via the “non-EU” entity report). Even if you’re not directly in scope, your EU customers are, which means your data becomes their data.
• What to report? CSRD uses ‘double materiality’: you must report a topic if it’s material under either lens - impact (how your business affects people and the planet) or financial (how it affects your value, cash flows, or access to capital). Packaging often hits both: multilayer sachets can worsen waste leakage (impact) while driving up EPR fees, redesign costs, and PCR supply risk (financial). Run a structured double-materiality assessment, then disclose against the ESRS topics it flags.
• What’s especially relevant to plastic packaging? Here’s how CSRD’s reporting standards map to everyday packaging decisions, and which ones matter most for plastics. ‍
  
  • ESRS E5 (Resource Use & Circular Economy) This is the packaging “home base.” It asks you to show how your products are designed to use fewer resources and fit a circular system. In practice:
    
    • Design for recycling: Can the pack be sorted and recycled in real EU systems? (e.g., mono-material PET bottle with compatible label/closure vs. a multilayer film that can’t be separated).
    • Recycled content (PCR): How much verified post-consumer content is in the pack—especially for food contact.
    • Waste prevention & reuse: Where are you reducing packaging, eliminating components, or piloting reuse/refill?
    • End-of-life outcomes: What actually happens to your packs—recycled, energy recovered, landfilled, leaked?
  • Also relevant: ESRS E1 (Climate). Packaging choices show up in your climate story:
    
    • Emissions from materials: Virgin resin vs. PCR has different footprints.
    • Design trade-offs: Lighter packs may cut transport emissions; switching materials may raise or lower the footprint depending on the full life cycle.
    • Targets & progress: How your packaging changes contribute to your emissions reduction plan.
  • Sometimes relevant: ESRS E2–E4 (Pollution, Water, Biodiversity). You don’t always report on every topic—only what’s material—but packaging can touch these:
    
    • E2 (Pollution): Additives/inks/adhesives, restricted substances, microplastics risk.
    • E3 (Water): Water use in resin production or recycling steps.‍
    • E4 (Biodiversity): Litter/leakage risks in certain markets; land-use impacts for non-plastic substrates.‍
  • Don’t forget value-chain data. EU customers will want supplier facts they can trust:
    
    • Materials & additives used (spec sheets, declarations).
    • Recyclability evidence (recognized design-for-recycling protocol results).‍
    • PCR claims with proof (chain-of-custody, batch tests, certifications).
    • Social safeguards (e.g., fair labor in your upstream recycling supply).

Helena’s take: Don’t treat the double materiality exercise as a one-off. It’s your roadmap - a way to prioritise packaging hotspots (materials, formats, markets) and show auditors why you disclose what you disclose.

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So… what changes for U.S. brands & suppliers?

1) Evidence replaces adjectives

“Sustainable,” “recyclable,” and “low plastic” won’t fly without definitions, methods, and numbers. If you say a pouch is “recyclable,” CSRD-grade customers will ask: Where? Under which protocol? With what sort rate? If you say “30% PCR,” they’ll ask for chain-of-custody and testing.

Action: Pick one design-for-recycling protocol (e.g., APR/CEFLEX equivalents used in the EU) and make it your house standard. Log decisions: resin, barrier, inks, adhesives, closures, colourants, and their recyclability implications. Store the receipts.

2) Circularity moves into the sales conversation

EU customers will weigh suppliers who can prove recyclability and deliver PCR on spec. Procurement briefs already read like: “show us LCAs, design evidence, and third-party verification.” Price still matters - but verifiable circularity is quickly becoming a qualifier.

Action: Build a Supplier Data Pack you can hand to any EU buyer:

• Product composition (resin IDs, additives, inks/adhesives),
  
• Recyclability evidence (protocol + pass/fail + known MRF flow),
  
• PCR content with documentation (source, certification, batch test) and food-contact status,
  
• EPR fee class (if known) and design alternatives to reduce fees.
  

Helena’s take: The fastest suppliers to win are the ones who can answer the auditor’s questions in one email - clean templates, clear evidence, consistent claims.

3) Data quality is now an operations problem

CSRD demands consistent, controllable processes: who records PCR %, who approves a recyclability claim, how lab results are stored, how often supplier declarations are refreshed. That’s operations, not marketing.

Action: Assign data owners for packaging metrics (recyclability score, PCR %, material mix, EPR class). Implement simple internal controls (maker/checker, versioning, evidence links). If you can’t trace a claim to a document, don’t publish it.

Helena’s take: Treat packaging data like financial data: materiality thresholds, controls, cut-off dates, and evidence ready for assurance.

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What about non-EU companies - what’s the actual impact?

• If you sell into the EU (directly or via distributors): Your EU customers must produce CSRD-aligned reports. They’ll come back to you for Scope 3 (upstream emissions), packaging composition, PCR content, and end-of-life performance. Slow or incomplete supplier data will become a sales friction - or a contract clause.
  
• If your group crosses EU thresholds: You may need a consolidated CSRD report for your non-EU group’s EU operations (the “non-EU” entity report). That pushes CSRD discipline directly into your corporate reporting cycle.
  
• If you’re a U.S. consumer brand selling into the EU (food, apparel, personal care, services with packaged goods): three moves now:
  
  1. Be buyer-ready: Build a one-page Supplier/Data Pack for every EU-bound SKU (specs, recyclability protocol result, verified PCR with chain-of-custody, EPR fee class, contact owner). Keep it audit-ready and consistent.
  2. Contract for evidence: Add data SLAs, audit rights, and claim substantiation to supplier agreements; align marketing claims (e.g., “recyclable,” “30% PCR”) to documents you can produce in days, not weeks.
  3. Plan the portfolio: Triage SKUs by risk/tonnage, model EPR + PCR cost scenarios, prioritize design-for-recycling fixes, and lock in PCR offtakes (especially food-grade) for 2026–2028.

‍Helena’s take: Whether or not you file a CSRD report yourself, you’re part of someone’s report. That means your packaging facts must be audit-ready - or you become a bottleneck.

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The CSRD “must-knows” for plastic packaging teams

1. Double materiality drives scope. Run it once, then update annually. It should surface where packaging creates impact (waste, leakage, additives) and financial risk/opportunity (EPR fees, PCR costs, market access).
   
2. ESRS E5 is your home base. Be ready to report design rules, recyclability, reuse pilots, PCR usage, take-back, and waste minimisation. Link choices to actual outcomes, not intentions.
   
3. Assurance is coming. Build a tidy trail: supplier declarations, test results, certifications, audit notes. Decide which claims you will not make until evidence is ready.
   
4. Non-EU timelines don’t equal “not now.” Even if formal reporting hits later for non-EU groups, your 2028 data is tomorrow in operational terms. The brands that practise now won’t be back-filling in a panic.
   

Helena’s take: Start with the data you already trust - then widen the circle. CSRD rewards consistent, repeatable processes over one-off perfection.

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A practical 90-day plan to get CSRD-ready

Month 1  -  Foundation

• Stand up a CSRD Packaging Taskforce (packaging engineering, sourcing, quality, sustainability, finance).
  
• Decide your recyclability protocol and PCR verification approach (audits, mass-balance policy, testing cadence).
  
• Draft the one-page Supplier Data Pack template you’ll request and provide.
  

Month 2  -  Inventory & gaps

• Catalogue EU-bound SKUs: resin, structure, labels/inks/adhesives, colourants, closures, current PCR %.
  
• Tag red flags: multilayers, problematic colours, non-detachable components, unverified PCR, food-contact claims without evidence.
  
• Map evidence gaps (what claim, what proof is missing, who owns it).
  

Month 3  -  Close gaps & pilot

• Collect declarations and lab results from top-20 suppliers by volume.
  
• Run two redesign sprints on high-tonnage, high-fee formats (move to mono-material, adjust labels/closures).
  
• Contract PCR for 2026–2028 volumes where you can (especially food-grade).
  

Run a mini-assurance rehearsal: pick one SKU and trace every packaging claim to a document.

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How CSRD changes the executive conversation

• From slogans to specs. Your European revenue now depends on verified packaging specs and their data trails.
  
• From annual PDF to monthly controls. CSRD discipline lives in your operating cadence (who measures, who checks, who files).
  
• From cost centre to moat. Verified recyclability and secured food-grade PCR become customer-winning capabilities - and harder for competitors to copy overnight.
  

Helena’s take: The companies that win won’t be the loudest—they’ll be the ones that can prove their packaging claims quickly and withstand assurance.

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TL;DR

• CSRD = audit-grade sustainability reporting that your EU customers must do (and many non-EU groups will, too).
  
• For plastic packaging, it spotlights recyclability by design, verified PCR, and evidence-backed claims under ESRS E5.
  
• Non-EU suppliers aren’t off the hook; your data feeds your customers’ reports.
  
• Start now: standardise protocols, clean your data, lock in PCR, and practise an “assurance rehearsal.”

Watch the full webinar, CSRD and PPWR: What New EU Regulations on Plastic Packaging and Reporting Mean for American Brands, on our YouTube channel here. 

And check out our blog post on the EU’s Packaging and Packaging Waste Regulation, which covers what American brands need to know about PPWR, how it stacks up against California’s SB54 laws, and what the implications are for circular system design.

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Explore our EPR essentials series:

• EPR Essentials: A Guide to Extended Producer Responsbility (EPR)
• EPR Reporting Made Simple: The Core Data Every Producer Needs to Capture
• Design Smarter, Pay Less: How Eco-Modulation Makes EPR Work for Your Bottom Line
• Operating at Scale: How Enterprise Teams Put EPR into Motion
• EPR Regulations Worldwide: What Every Global Brand Needs to Know Now
• From Compliance Cost to Business Value: Making EPR Work for You
• PPWR, explained: What Europe’s new packaging rules mean for U.S. brands
• CSRD, explained: How Europe’s reporting rules will change the way U.S. brands talk about (and design) plastic packaging