CSRD

Manufacturing

What does CSRD require from a manufacturing company?

The Corporate Sustainability Reporting Directive transforms how industrial companies report their environmental and social impact. Here's what you need to know to comply.

Perimeter and "per plant": what enters a manufacturer's reporting

Not just "headquarters".

CSRD requires reporting at the company or group level (same perimeter as financial reporting).

In manufacturing, this translates to production centers: plants, warehouses, workshops, laboratories, logistics centers.

Also includes subcontracted operations over which you have operational control.

Requires disaggregating operations.

The standard doesn't mandate "one table per plant" in all cases.

However, in industry it's usually necessary because key impacts and metrics (energy, emissions, water, waste, incidents, permits) vary by facility.

This is what supports an auditable statement.

What this means in practice:

Inventory of sites — responsible party, activity, permits, consumption, critical equipment (furnaces, boilers, compressors, refrigerants)
Consolidation rules — what data is consolidated by group vs. presented by country/plant when material
Documented operational boundaries — for environmental metrics and how you treat joint ventures, maquila, toll manufacturing

Double materiality: you must justify what you report and what you don't

CSRD requires reporting with ESRS.

ESRS starts with double materiality:

Impact materiality

How your activity impacts people and the environment.

Financial materiality

How ESG risks and opportunities affect your P&L, balance sheet, cash flow and cost of capital.

Important: The assessment considers the entire value chain, not just your own operations.

Typical material topics in manufacturing:

Energy and emissions — scopes 1, 2 and relevant part of 3
Water and effluents
Waste, circularity, packaging — product end-of-life
Chemical substances and pollution
Health and safety — own and contractors
Labor rights — in critical suppliers

Real operational data they'll ask for (and that usually hurt in industry)

Although CSRD is "reporting," in industry it becomes an operational data system.

Here's what you'll need to track:

Energy

Consumption by vector: electricity, gas, fuel, steam

Self-consumption and PPA

Guarantees of origin and intensity per unit produced

Emissions

Scope 1: combustion, processes, refrigerant leaks

Scope 2: market-based and location-based

Scope 3: raw materials, transport, waste, travel, use and end-of-life

Water

Intake by source and consumption

Water stress assessment

Discharges and quality

Waste & Circularity

Hazardous vs. non-hazardous

Recovery and disposal methods

Traceability by waste manager

Key point: Numbers aren't enough.

ESRS pushes you to link policies, actions, resources, metrics and objectives.

You must also explain methodology and document any changes.

Supply chain and value chain: practical obligation, not optional

CSRD, via ESRS, requires material information from both directions:

Upstream (suppliers) and downstream (customers, end-of-life).

Upstream

Extraction and processing of raw materials.

Tier 1 suppliers and, if material, beyond.

Includes chemicals, minerals, critical components.

Downstream

Distribution and product use.

Maintenance and consumables.

End-of-life and recycling.

In manufacturing this usually translates to:

Supplier segmentation — critical by spend, risk, impact, dependency, geography
Evidence collection — questionnaires, audits, certifications, primary data when viable
Data quality rules — what you accept as primary, secondary, proxy, and how you document uncertainty

Internal control and governance: they'll look at it like financial reporting

ESRS 2 applies to all companies.

It requires describing governance, processes, controls and procedures to manage sustainability topics.

What they expect to see in a manufacturer:

Clear roles — board, management, plant managers, procurement, HSE, finance
IRO processes — identifying and managing impacts, risks and opportunities
Data controls — approvals, segregation of duties, traceability, internal audits, methodological change management
Sustainability-industrial planning link — CAPEX, maintenance, procurement, quality, EHS

Assurance: your report goes through external verification

CSRD requires the sustainability statement to be subject to assurance.

This must be done by an auditor or authorized provider.

At EU level, a limited assurance framework is envisioned.

The Commission must adopt standards by October 1, 2026.

Practical implication:

If you can't reconstruct a data point (source, calculation, responsible party, evidence), it's an audit weakness
You need an "audit trail" for operational metrics (plant) and for value chain estimates

Format and publication: it's not just a pretty PDF

CSRD seeks comparable and accessible information.

"Digital reporting" is moving toward XHTML + XBRL/iXBRL tagging.

This will apply when the taxonomy and ESEF framework are adopted.

Specific mandatory requirements depend on applicable acts.

The direction is clear: structured, machine-readable, comparable data.

This enables stakeholders to analyze and compare sustainability performance across companies.

CSRD | MULTI-PLANT

CSRD in multi-plant manufacturing: what really changes

When you manage facilities across different countries, CSRD transforms from a reporting exercise into a complex data orchestration challenge.

🏢

The perimeter is group-level, not plant-level

Your sustainability statement must cover the same reporting entity as your consolidated financial statements.

This means if you're a parent company, you report for the entire group — not facility by facility.

The challenge: Building a data model where each plant feeds homogeneous, consolidatable data upward.

📅

Calendar Chaos

Different fiscal years across countries and business units make consolidation a nightmare.

💱

Currency Confusion

Exchange rates for CapEx, OpEx, and environmental provisions vary by plant and period.

⚖️

Unit Inconsistency

MWh, GJ, kWh, therms — every plant measures differently, making comparison impossible.

⚖️

Financial vs operational control

EFRAG distinguishes between financial control (accounting consolidation) and operational control (directing operations).

For environmental metrics like GHG, pollution, and biodiversity, operational control matters even if you don't fully consolidate financially.

Impact: Joint ventures, third-party operated plants, and regulated facilities you "control" must be included.

❌ Without proper structure

✓ With proper structure

Each plant uses different emission factors and calculation methods

Centralized factor library with version control and audit trail

Duplicate sites with inconsistent naming across systems

Unique site_id system with clear hierarchies and standards

Estimated data without documentation or approval process

Written estimation policy with assumptions and governance

Different reporting periods make consolidation impossible

Group-wide calendar with synchronized cut-off dates

3-5

Different data systems per plant on average

40%

Time spent reconciling inconsistent data

15+

Different unit conversions needed typically

80%

Of multi-plant errors come from poor governance

The multi-plant CSRD implementation path

Define your perimeter

Map all facilities, determine financial vs operational control, establish which entities must report.

Standardize definitions

Create group-wide standards for sites, units, calendars, currencies, and data quality tiers.

Build data architecture

Implement unique IDs, hierarchies, factor libraries, and consolidation rules with audit trails.

Map existing data sources

Identify EU ETS, PRTR, energy audits, permits — determine gaps and bridge strategies.

Implement controls & governance

Establish "sustainability close" procedures, approvals, evidence requirements per plant.

Test and validate

Run consolidation dry runs, identify errors, verify traceability and prepare for external assurance.

Common multi-plant questions

Do I need to report data for every single plant?

You can consolidate at group level, but must disaggregate when material. For location-dependent impacts (water stress, local pollution, biodiversity), plant-level data is typically required.

Can I use existing EU ETS or PRTR data?

Yes, but with gaps. EU ETS covers Scope 1 for regulated installations but not Scope 2/3 or non-regulated sites. PRTR has thresholds that exclude smaller plants. You'll need to fill these gaps.

What if plants have different fiscal years?

You must establish a group-wide reporting calendar with standardized cut-off dates and clear allocation rules for data that crosses periods.

How do joint ventures affect my reporting?

If you have operational control (direct operations), you must include environmental metrics even if you don't fully consolidate financially. This applies to GHG, pollution, and biodiversity reporting.

Multi-plant CSRD isn't about compliance checkboxes

It's about building data architecture and governance that makes your group's sustainability performance visible, verifiable, and actionable across every facility.

OUR TEAM

The people behind the impact

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Sobre Dcycle

Your doubts answered

How Can You Calculate a Product’s Carbon Footprint?

Carbon footprint calculation analyzes all emissions generated throughout a product’s life cycle, including raw material extraction, production, transportation, usage, and disposal.

The most recognized methodologies are:

Digital tools like Dcycle simplify the process, providing accurate and actionable insights.

Life Cycle Assessment (LCA)
ISO 14067
PAS 2050

What are the most recognized certifications?

ISO 14067 – Defines carbon footprint measurement for products.
EPD (Environmental Product Declaration) – Environmental impact based on LCA.
Cradle to Cradle (C2C) – Evaluates sustainability and circularity.
LEED & BREEAM – Certifications for sustainable buildings.

Which industries have the highest carbon footprint?

Construction – High emissions from cement and steel.
Textile – Intense water usage and fiber production emissions.
Food Industry – Large-scale agriculture and transportation impact.
Transportation – Fossil fuel dependency in vehicles and aviation.

How can companies reduce product carbon footprints?

Use recycled or low-emission materials.
Optimize production processes to cut energy use.
Shift to renewable energy sources.
Improve transportation and logistics to reduce emissions.

Is Carbon Reduction Expensive?

Some strategies require initial investment, but long-term benefits outweigh costs.

Energy efficiency lowers operational expenses.
Material reuse and recycling reduces procurement costs.
Sustainability certifications open new business opportunities.

Investing in carbon reduction is not just an environmental action, it’s a smart business strategy.

CSRD para manufactura sin morir en la cadena de datos

Lo que suele pasar en manufactura con la CSRD

Qué cambia con Dcycle en una empresa industrial

De datos de planta a CSRD en 3 pasos

Menos reporting. Más control. Mejor defensa del dato.

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CSRD en manufactura, sin caos de datos

The people behind the impact

What does CSRD require from a manufacturing company?

Perimeter and "per plant": what enters a manufacturer's reporting

Double materiality: you must justify what you report and what you don't

Real operational data they'll ask for (and that usually hurt in industry)

Supply chain and value chain: practical obligation, not optional

Internal control and governance: they'll look at it like financial reporting

Assurance: your report goes through external verification

Format and publication: it's not just a pretty PDF

CSRD in multi-plant manufacturing: what really changes

The perimeter is group-level, not plant-level

Calendar Chaos

Currency Confusion

Unit Inconsistency

Financial vs operational control

The multi-plant CSRD implementation path

Define your perimeter

Standardize definitions

Build data architecture

Map existing data sources

Implement controls & governance

Test and validate

Common multi-plant questions

Multi-plant CSRD isn't about compliance checkboxes

The people behind the impact

Your doubts answered