CSRD guide for the consumer products sector

CSRD changes the rules for consumer goods companies — from voluntary sustainability narrative to regulated financial disclosure requiring external assurance, board governance, and full integration with your annual report.

For product and operations teams, CSRD means sustainability data is product and operational data. Your PLM, ERP, supplier portals, and quality systems are your CSRD data foundation. The gap isn't ambition — it's data architecture and controls.

This guide explains what CSRD requires from consumer goods companies specifically, which ESRS topics carry the highest materiality across the product lifecycle, and how to build a system that connects to existing product infrastructure.

Implementation Timeline: UK vs EU

The original European timeline classified companies into waves: those already complying with NFRD (public companies with >500 employees) had to report in 2025 (FY2024 data), other large companies in 2026 (FY2025 data), listed SMEs in 2027 (FY2026 data), and non-European companies in 2029 (FY2028 data).

However, after the 2025 reforms ("stop-the-clock" and Omnibus), these dates were delayed by two years: large companies (non-NFRD) will report from FY2027 (report in 2028) and listed SMEs from FY2028 (report in 2029).

Summary Timeline for Spain/EU:

2025: First wave reports begin (NFRD companies with FY2024 data)

2027: Large companies not previously in NFRD start (FY2027 data, report in 2028)

2028: Listed SMEs begin (FY2028 data, report in 2029)

2029: Foreign companies with EU subsidiaries or significant sales start (FY2028 data, report in 2029)

The UK Position: Different Path, Same Direction

In the United Kingdom, CSRD as an EU directive does not apply. However, sustainability disclosure is gaining force through local regulations.

Since April 2022, large UK companies (all with >500 employees or £500M sales) must publicly disclose climate information according to TCFD (Task Force on Climate-related Financial Disclosures) taxonomy.

Additionally, the Government plans to adopt the IFRS Foundation standards (IFRS S1 general and IFRS S2 climate) as UK Sustainability Reporting Standards (UK SRS). These standards are expected to enter force from 2026 (for FY2025 reports).

Key Differences: EU (CSRD) vs UK

Key Differences: EU (CSRD) vs UK

Base regulation
Spain/EU (CSRD): CSRD Directive (EU) with mandatory ESRS standards.
United Kingdom: National laws such as the Companies Act and FCA rules, plus future UK SRS based on IFRS.

Mandatory subjects
Spain/EU (CSRD): Large EU companies, listed companies including certain SMEs, EU parent subsidiaries, and non-EU companies with more than €150M in EU sales.
United Kingdom: Large UK companies subject to TCFD since 2022; in the future, listed companies applying IFRS S1 and S2.

Materiality
Spain/EU (CSRD): Double materiality. Companies must report both their impact on society and the environment and the financial impact on the business.
United Kingdom: Financial or investor focused materiality. Emphasis on sustainability risks and opportunities affecting the business, similar to ISSB.

Standards
Spain/EU (CSRD): Detailed and audited ESRS, European Sustainability Reporting Standards.
United Kingdom: IFRS S1 and S2 issued by ISSB, to be adopted as UK SRS under consultation, plus TCFD climate requirements.

Timelines
Spain/EU (CSRD): Phased implementation. First reports in 2025 covering FY24 for large companies, with a two year delay for other entities.
United Kingdom: Climate reporting required from FY22. IFRS based standards expected to become mandatory from 2026, subject to final regulation.

Audit
Spain/EU (CSRD): Mandatory external audit of the sustainability report.
United Kingdom: Not yet mandatory, pending further development of SDR and UK SRS regulation.

Penalties
Spain/EU (CSRD): National fines, potentially based on a percentage of revenue, for non compliance.
United Kingdom: Fines under the Companies Act and FCA supervision, not ESG specific sanctions at this stage.

How Consumer Goods Teams Should Build CSRD Infrastructure

Step 1: Double Materiality with a Product Lifecycle Lens

Consumer goods double materiality assessments typically identify as material: climate change (Scope 3 from upstream sourcing and downstream use, packaging lifecycle), circular economy (packaging design, recyclability, EPR obligations, waste reduction), supply chain workers (upstream sourcing conditions in agriculture, textiles, manufacturing), and business conduct (responsible sourcing, anti-corruption in complex supply chains).

Run the assessment with Product, Sourcing, Operations, and Finance co-leading. Connect financial materiality to tangible drivers: carbon price exposure in raw materials, EPR compliance costs, supply chain disruption risk from human rights incidents.

Step 2: Connect CSRD to PLM and Sourcing Systems

Consumer goods ESRS E5 and S2 data lives in PLM (packaging specifications, material composition), supplier portals (sustainability declarations, certifications), procurement systems (spend by category and geography), and quality systems (supplier audits, non-conformances). Design automated or structured data feeds from these systems.

Step 3: Build Product-Level Evidence Architecture

CSRD requires company-level aggregates, but building from product-level data ensures consistency and future-proofs for product carbon footprint and product environmental footprint requirements. Structure your data model to support both company-level CSRD reporting and product-level customer data requests.

CSRD Mistakes Consumer Goods Companies Make

1. Treating Packaging Data as Qualitative

ESRS E5 requires quantitative packaging disclosures: weight, recycled content, recyclability rates, EPR compliance. Consumer goods companies that treat packaging as a narrative topic rather than a measured KPI will face significant gaps when assurance begins.

2. Not Capturing Scope 3 by Product Category

Company-level Scope 3 estimates without category breakdown are increasingly insufficient. ESRS E1 requires disclosure by significant Scope 3 category, and auditors will probe methodology for the most material categories — typically purchased goods, packaging, and use phase.

3. Underestimating Supply Chain ESRS S2 Requirements

Consumer goods supply chains have significant upstream labor risk — agriculture, textiles, chemical sourcing. ESRS S2 requires due diligence processes, not just a supplier code of conduct. If you don't have systematic supplier assessment, audit programs, and remediation tracking, S2 will be a significant compliance gap.

4. Leaving EPR Compliance Data Disconnected from CSRD

Extended Producer Responsibility compliance data — packaging volumes by material, recycled content percentages, EPR fee calculations — is the same data ESRS E5 requires. Integrate EPR compliance reporting with CSRD preparation to avoid collecting the same data twice.

What to Look for in a Consumer Goods CSRD Platform

PLM and Supplier Portal Integration

The consumer goods CSRD platform must integrate with PLM for product specifications and packaging data, and provide a supplier portal for sustainability declaration collection. These are the primary sources for ESRS E5 and S2 data — manual entry from these systems isn't viable at scale.

Product-Level Data Granularity

The platform must support data collection and calculation at product family or SKU level to produce both company-level CSRD aggregates and product-level customer data. Single-level company aggregation is insufficient for complex consumer goods portfolios.

Supply Chain Due Diligence Workflow

Look for structured supplier assessment workflows: questionnaire distribution, risk scoring, audit findings management, corrective action tracking, and remediation evidence storage. This is the operational backbone of ESRS S2 compliance.

EPR and Packaging Compliance Integration

The platform should connect EPR compliance data (material types, weights, recycled content) directly to ESRS E5 disclosures — eliminating duplicate data collection and ensuring consistency between regulatory filings and sustainability reporting.

Why Dcycle is the Best Solution for Consumer Products CSRD

When choosing an ESG management platform for CSRD compliance, what really matters isn't just functionality – it's the ability to deliver a comprehensive, product-centric solution oriented to the real complexity of consumer goods.

We are not auditors or consultants. We are a solution designed for companies that want to measure, manage and communicate their product and supply chain impact simply and efficiently.

Our objective is clear: enable every organisation to collect all their ESG information at product level and distribute it automatically to different use cases, without complications or manual processes.

We centralise environmental, social and governance data from any source – PLM, procurement systems, supplier portals, quality systems, LCA databases – and convert it into standardised, traceable product metrics ready for official reports. Companies can generate documentation compatible with EINF, CSRD, ISO 14067, PEF, EPD or any other standard in minutes.

Why Consumer Brands Choose Us

Product-Level by Design: We understand that in consumer goods, sustainability lives at the SKU/formulation level. Our platform structures data around products, BOMs and supply chains, not just corporate aggregates.

Value Chain Transparency: Manage multi-tier supplier data, due diligence workflows, audit status and traceability documentation in one place. Support both mandatory due diligence (EUDR, CSDDD) and CSRD reporting needs.

Lifecycle Impact Built-In: Calculate product carbon footprint, water footprint and multi-impact environmental profiles with recognised methodologies (ISO 14067, PEF). Link calculations to BOM changes automatically.

Complete Traceability: Every metric links back to source evidence – supplier declarations, certifications, test reports, ingredient specs, packaging drawings. This isn't just good practice, it's a requirement for external assurance and claims substantiation.

Multi-Regulation Ready: Generate reports and data exports for CSRD, Taxonomy, PPWR, EUDR, DPP and customer-specific requirements from a single dataset. No duplication, no inconsistencies.

Strategic, Not Just Compliance: We firmly believe sustainability should be a strategic lever for innovation and market access, not an administrative burden. Our mission is clear: convert ESG data into smarter product decisions and competitive advantage.

With Dcycle, consumer brands can control their information, reduce compliance costs, automate reporting, win retail partnerships and guarantee complete traceability of their product sustainability claims.

In a market where transparency determines market access, our proposition is simple: make product sustainability work as a real engine for growth.

Frequently Asked Questions (FAQs)

What should I prioritise when implementing CSRD for consumer products?

When implementing CSRD in consumer products, prioritise three core elements: product-level data infrastructure, value chain traceability and claims substantiation.

Product-level infrastructure means structuring ESG data around your BOM, formulations and specifications. Every product must have traceable sustainability attributes that can be aggregated to corporate reporting.

Value chain traceability is non-negotiable for consumer brands. Your impacts and risks live in supplier factories, raw material farms and packaging production. Build supplier engagement programmes with clear data requirements by tier.

Claims substantiation protects you from anti-greenwashing enforcement. Every sustainability statement about your products must be backed by CSRD-quality data and recognised methodology.

Also ensure your solution integrates with PLM, procurement and quality systems, supports recognised calculation standards (ISO 14067, PEF) and can generate both regulatory reports and customer-specific data exports.

What are the main challenges for consumer brands under CSRD?

The main challenges are:

Product portfolio complexity: Different product categories have completely different hotspots and data needs. Fashion data models don't work for food or cosmetics.

Multi-tier supply chain opacity: Visibility beyond tier 1 suppliers is limited, especially for raw materials (agriculture, chemistry, textiles). Tracing palm oil to plantation or cotton to farm is complex.

Data fragmentation: Product data lives in PLM, formulation systems, packaging specs, supplier portals, quality databases and marketing systems without integration.

Scope 3 dominance: For most consumer brands, 80-95% of impact is Scope 3 (raw materials, manufacturing, transport, use, disposal). Corporate operations are negligible.

Regulatory convergence: CSRD overlaps with PPWR, EUDR, ESPR/DPP, anti-greenwashing and CSDDD. You need one integrated system, not five separate compliance projects.

Claims and communication risks: Marketing and sustainability must align. Unsubstantiated claims create legal exposure.

How does CSRD differ between EU and UK consumer brands?

EU consumer brands must comply with CSRD and ESRS, which require double materiality, detailed value chain disclosures and external audit. They also face product-specific regulations (PPWR, EUDR, ESPR) that feed into CSRD.

UK consumer brands follow TCFD for climate (already mandatory for large companies since 2022) and will likely adopt IFRS S1/S2 standards focused on financial materiality and investor decision-usefulness.

The practical difference: CSRD is more comprehensive (covering full ESG scope) and more product-granular (expects value chain detail), while UK standards focus on climate and financial risks.

However, UK brands selling into EU face CSRD indirectly: EU retailers and distributors will demand product-level ESG data for their own CSRD reporting. Product regulations (PPWR, EUDR) also apply to products sold in EU regardless of company domicile.

Smart UK brands build CSRD-compatible systems even if not legally obligated, because market access demands it.

Can small consumer brands benefit from CSRD preparation even if not required?

Absolutely. Even if you're below the mandatory thresholds, building a CSRD-aligned product sustainability system delivers concrete benefits:

Retail requirements: Major retailers increasingly require product-level ESG data as condition of listing. Having robust, verified data positions you as a preferred supplier and protects shelf space.

Consumer trust: Conscious consumers demand transparency. Verified sustainability data (not just marketing claims) builds brand loyalty and justifies premium pricing.

Regulatory readiness: Even if CSRD doesn't apply today, product regulations (PPWR, EUDR, anti-greenwashing) do apply. The same data infrastructure serves both.

Innovation efficiency: Measuring product footprints reveals hotspots and improvement opportunities. Brands that measure early can innovate faster (lighter packaging, better materials, cleaner processes).

Investor and finance access: ESG performance increasingly determines access to growth capital and favourable financing terms.

The investment in product-level ESG infrastructure pays dividends whether or not CSRD compliance is mandatory.

How long does it take to implement a CSRD-ready system for consumer products?

For a typical consumer brand, a realistic timeline is:

90 days for minimum viable system: Materiality assessment, hotspot analysis for top product categories, BOM data structure defined, key suppliers identified, packaging database started, controls framework documented.

6-12 months for full implementation: Product-level data for major SKUs, supplier engagement programme launched, Scope 3 methodology documented, packaging compliance tracking (PPWR), traceability for high-risk materials (EUDR), evidence management, first complete CSRD report with identified gaps.

Ongoing evolution: Product sustainability is not a one-time project. Expect continuous portfolio expansion (new products, formula changes), supplier coverage improvement, methodology refinement and adaptation to evolving regulations.

The key is to start with a solid foundation – clear materiality by product category, BOM-centric data model, supplier segmentation strategy, integration with PLM/procurement and the right technology platform.

With the right approach and the right tools, CSRD compliance becomes a manageable process that strengthens your brand and products rather than burdening them. In consumer goods, the brands that master product-level sustainability data will win the shelf space and consumer trust of tomorrow.