EINF for consumer goods 2026: Product and Ops audit guide in UK
EINF consumer products in Spain demands auditable, traceable data across your value chain. Get ready for 2026.
What is EINF and Who Must Comply in Consumer Goods
The 8 Critical Areas Where EINF Impacts Consumer Goods Operations
Key Metrics Consumer Goods Teams Must Track Under EINF
How to Build an EINF Consumer Goods System That Survives Audit
4 Key Factors When Choosing an EINF Consumer Goods Solution
Why Dcycle is the Best Solution for EINF Consumer Goods
Frequently Asked Questions (FAQs)
The Non-Financial Information Statement (EINF in Spanish) isn't another sustainability initiative you can delegate to the CSR team and forget about.
For consumer goods companies, EINF fundamentally changes how you measure, control, and report your environmental, social, and governance impact across the entire product lifecycle – requiring auditable data, defined methodologies, and direct connection to your product development, sourcing, and quality systems.
For product and operations teams, this means EINF is product data, not marketing. The sustainability statement must cover your complete value chain – from raw materials to end-of-life – use the same materiality judgments that affect your business decisions, implement audit-grade controls, and directly feed customer requirements, brand reputation, and market access.
If you're still treating sustainability data as separate from product and operations data, you're creating risk. EINF requires the same rigor you apply to quality control – traceable sources, documented methodologies, version control, and evidence retention.
Companies that understand this early gain efficiency and competitive advantage. Those that don't will face costly rework, audit failures, greenwashing accusations, and credibility damage when verification begins.
This guide explains everything consumer goods product and operations teams need to know about EINF: what it requires, when it applies, how it connects to your PLM and ERP, which metrics matter most, and how to build a robust system that passes audit without disrupting operations.
Packaging specs, supplier certifications, material composition, and quality test results already exist in your PLM and supplier portals. The challenge is connecting them with the audit-grade controls EINF demands.
Quick win: identify the top 3 product categories with the highest packaging and sourcing impact — and start your evidence mapping there.
In Spain, the Non-Financial Information Statement (EINF) is a sustainability information block that must be included in the management report when certain thresholds are met. The legal basis is Law 11/2018, which integrates this into the commercial framework.
For consumer goods companies, this isn't about "listing ESG actions": it's about explaining real impacts and risks of the product lifecycle (raw materials, manufacturing, logistics, use, end-of-life) and the supply chain (subcontractors, farmers, workshops, contract manufacturers).
Key operational aspects:
In the UK, there is no label "EINF" as such. The functional equivalent is distributed across several pieces of corporate reporting: Strategic Report with non-financial information statement, climate-related financial disclosures (TCFD-aligned), SECR, and Modern Slavery statement under the Modern Slavery Act 2015, section 54.
Spain concentrates EINF as a single verified piece with clear publication rules. UK tends to function in layers within annual reporting. The winning practice is a single "data backbone" (packaging, energy, emissions, suppliers, quality) that feeds all layers without contradictions.
For consumer goods, the key is no longer listing policies, but demonstrating you understand your complete value chain (raw materials, manufacturing, logistics, channels, use, and end-of-life) and the impacts, risks, and opportunities that arise from both own operations and third parties.
A highly actionable angle for consumer goods is converting your EINF into a "stage-by-stage map":
Sourcing: Human rights risks, deforestation, traceability, certifications, commodity prices and dependency.
Manufacturing: Energy, water, chemical substances, waste, subcontracting, labor conditions.
Packaging: Design for recycling, recycled content, EPR compliance, reduction.
Distribution and retail: Emissions, returns, waste, last mile, cold chain.
Use: Safety, instructions, durability, impacts during use (e.g., detergents, cosmetics, food).
End-of-life: Real recyclability, return systems, extended producer responsibility.
The CNMV (Spanish regulator) insists that the value chain should avoid being generic, and that it is good practice to accompany it with diagrams and qualitative explanation focused on your specific products and categories.
If your catalog touches packaging, regulators and the market will scrutinize this intensely because it's massive and measurable impact:
Spain:
UK:
KPIs that usually provide signal (and avoid "marketing" EINF):
In consumer goods, Scope 3 usually dominates (raw materials, packaging, upstream and downstream transport, product use, end-of-life). The CNMV reminds that, if you report Scope 3, you must detail by significant categories using the 15 categories of the GHG Protocol value chain standard (and explain exclusions and their effect).
Practical framework (without repeating the obvious) for Scope 3 in consumer goods:
Define which categories are material by product family (not for the entire company). Example: cosmetics usually loads more on packaging and chemistry; food on agriculture and refrigeration; fashion on fibers and use (washing).
Explain methodology by category: primary data vs secondary factors, base year, assumptions, and boundaries.
Connect the data with product decisions: format redesign, material change, concentration, refill, pallet optimization.
The CNMV notes that almost a third of issuers still don't report Scope 3, and of what's reported, Scope 3 represents around 85% of the total. For deeper understanding of corporate emission methodologies and how they align with global climate goals, frameworks like the SBTI provide useful context for target setting and validation.
Another differential angle for consumer goods is treating product safety and recalls as an ESG topic (consumer impact, reputational risk, quality governance).
In the EU, Regulation (EU) 2023/988 (GPSR) applies from December 13, 2024, reinforcing safety, traceability, and market surveillance obligations. In a powerful EINF, this translates into KPIs like: incident ratio, withdrawals, response times, audits of critical suppliers, and design improvements for safety.
If you're going to include "product footprint" or claims like "lower impact," you should align with quantification standards like ISO 14067 for product carbon footprint (principles, requirements, and guidelines for quantifying and reporting).
At EU level, Directive (EU) 2024/825 (empowering consumers for the green transition) hardens the ground against generic environmental claims, weak labels, and misleading practices. Spain will have to reflect this in consumer enforcement, so your EINF can play a defensive role if it documents criteria and evidence behind claims.
For consumer goods, real risk is usually upstream (agriculture, textiles, chemicals, mining for packaging components).
Spain: Law 11/2018 pushes to apply due diligence in supply chains when pertinent and proportionate.
UK: The Modern Slavery Act obliges large companies to publish an annual statement on steps to prevent modern slavery in their business and supply chain. Updated guidance (December 2025 update) and recent statutory guidance help publish statements with real substance, not templates.
Directive (EU) 2024/1760 on corporate due diligence obliges companies in scope to identify and address adverse impacts on human rights and environment in their value chain. Although the calendar and thresholds matter, for consumer goods it's a very useful framework because real risk is usually upstream.
An advanced EINF can anticipate this approach: risk mapping by categories, supplier assessment, remediation mechanisms, and traceability.
Water: consumption and water stress in key suppliers (food, textiles, cosmetics, cleaning products) is material for many consumer goods categories.
Biodiversity: agricultural raw materials, wood, palm, cocoa, fishing, etc., with risks of deforestation or degradation. This is especially relevant for food, cosmetics, and home care products sourcing natural ingredients.
Useful KPIs:
EINF requires external assurance. This forces implementation of controls, owners, segregation of duties, evidence, reviews, and an "ESG close" similar to quality control processes.
Controls that typically make the difference:
Verification of EINF: prepare the "audit package" as if it were a financial close
Independent verification stops being a formality when you start publishing product metrics, Scope 3, or claims.
The typical reference standard in non-financial information assurance is ISAE 3000 (Revised), which structures how to plan, evidence, and conclude in an assurance engagement. For organizations managing complex reporting structures, using robust ESG data architectures is essential to maintain consistency and traceability across all sustainability disclosures.
For zero friction, think about:
Sustainability reporting will also require XBRL tagging. ESMA is working on XBRL taxonomy for ESRS and technical framework adjustments.
For IT and data teams, this means designing data from origin thinking about "tagging," not at the end. You need data structure and tagging capacity, not just a pretty PDF.
Beyond compliance, companies aligning their reporting with European frameworks such as CSRD and broader sustainable finance frameworks can enhance investor trust and streamline ESG data integration. These frameworks help consumer goods teams connect operational metrics to financial relevance, reinforcing the transparency that regulators and markets now expect.
Energy and Climate
Packaging and Circular Economy
Water and Raw Materials
Workforce
Supply Chain Workers
Product Quality and Safety
Business Conduct
The biggest mistake: Assigning EINF to the sustainability team without involving Product Development, Sourcing, Quality, or Operations.
Why it fails: EINF is operational reporting about products. It requires audit-grade data from PLM, supplier portals, quality systems, and ERP.
Solution: Establish a multifunctional EINF program led by Operations or Product, with clear accountability to senior leadership.
Treating EINF as a quarterly close (not annual) works better. Create an ESG subledger that consolidates product data, supplier data, calculations, and evidence.
Think of EINF data as quality data. Implement reconciliations (supplier declarations vs lab tests), segregation of duties, approval flows, and evidence retention for every data point.
The problem: Marketing makes environmental claims without documented product-level evidence.
Why it fails: Directive (EU) 2024/825 and UK Green Claims Code require substantiation for all environmental claims.
Generic claims like "eco-friendly" or "sustainable packaging" without traceable product data expose consumer goods companies to greenwashing enforcement under EU Directive 2024/825. EINF verifiers will test every claim against its underlying evidence.
Rule: every environmental claim must link to specific product evidence — LCA, certification, test result, or supplier declaration — before it appears in any public disclosure.
Relying on supplier self-declarations without verification or quality controls means auditors will question data quality and poor supplier data undermines all downstream claims.
Build your data model to allow reporting by product family, category, or SKU to future-proof for product environmental footprint requirements.
Can the platform integrate with your PLM, supplier portals, and quality systems? Consumer goods ESG data lives in product specifications, supplier declarations, lab tests, and quality audits.
Does the platform support data collection across the full product lifecycle? From raw material sourcing and certifications through manufacturing, packaging design, distribution, use phase, and end-of-life recyclability.
Can the platform manage supplier data at scale? Consumer goods companies work with hundreds or thousands of suppliers and need a supplier portal, data validation rules, version control, audit trails, and risk scoring.
Can you calculate and report at product or category level? This is critical for product carbon footprints (ISO 14067), packaging claims and EPR reporting, customer data requests, retailer requirements, and product labeling.
Level 1: company-level metrics only, claims without product evidence, sustainability team working in isolation.
Level 2: category-level packaging and emissions data, supplier assessments, quarterly close cycle.
Level 3: SKU-level traceability, claim register with full evidence, PLM-integrated ESG data, audit-ready at any time.
When choosing an ESG management platform for EINF compliance in consumer goods, what really matters is the ability to handle product-level data with the rigor and traceability that regulators and customers demand.
We are not auditors or consultants. We are a Solution designed for companies that want to measure, manage, and communicate their ESG impact simply and efficiently.
Our goal is clear: enable every organization to collect all their ESG information and automatically distribute it to different use cases, without complications or manual processes.
We centralize environmental, social, and governance data from any source – PLM, ERP, supplier portals, quality systems, spreadsheets – and convert them into standardized, traceable metrics ready for official reports. Companies can generate documentation compatible with EINF, SBTi, CSRD, European Taxonomy, ISO, or any other standard in minutes.
Designed for Product Rigor: We understand that EINF is product data. Our platform integrates with PLM, quality systems, and supplier portals that product teams already use, delivering the same level of control and traceability as your quality management system.
Product-Level Granularity: Calculate and report at company, category, or product level. Support product carbon footprints, packaging claims, and customer-specific data requests.
Supply Chain Management: Built-in supplier portal, data validation, evidence storage, and audit trails for managing data from hundreds or thousands of suppliers.
Complete Traceability: Each metric links to source evidence – supplier declarations, lab tests, certifications, product specifications. This is not just good practice, it's a requirement for external assurance and claim substantiation.
Multi-Framework Support: Generate reports for EINF, CSRD, product footprints, EPR packaging, customer requirements, and any other framework from a single data set. No duplication, no inconsistencies.
Claim Management: Register and substantiate all environmental claims with direct links to product evidence, protecting you from greenwashing risk.
Strategic, Not Just Compliance: We firmly believe that sustainability should be a strategic lever for competitiveness, not an administrative burden. Our mission is clear: convert ESG data into smarter, more efficient, and more profitable product and business decisions.
With Dcycle, consumer goods teams can control their product information, reduce costs, automate processes, and ensure complete traceability of their ESG indicators.
In a market where measuring well is the difference between moving forward and falling behind, our proposal is simple: make sustainability work as a real growth engine.
When implementing EINF, prioritize three core elements: product lifecycle coverage, supply chain data quality, and claim substantiation.
Product lifecycle coverage means tracking environmental and social data across sourcing, manufacturing, packaging, distribution, use, and end-of-life. Partial coverage creates gaps that auditors will question.
Supply chain data quality means establishing standards for supplier data, requesting evidence and certifications, and having verification processes. Poor supplier data undermines all downstream metrics.
Claim substantiation means every environmental claim must trace to specific product evidence (LCA, certifications, test results). This protects you from greenwashing accusations and regulatory enforcement.
EINF connects with product development through design decisions, material selection, and specifications. Although EINF is separate from quality management, if sustainability factors affect product design, they must be reflected in both systems.
Examples:
The critical rule: If your sustainability strategy says "X" but your product specifications say "Y", auditors and customers will flag the inconsistency.
EINF is company-level regulatory reporting; product sustainability is product-level environmental disclosure. But they're deeply connected.
EINF requires company-level metrics (total emissions, waste, packaging) aggregated across all products.
Product sustainability (ISO 14067, PEF, EPD) requires product-level life cycle assessment and specific environmental performance.
For consumer goods teams: Use product-level data as the foundation. Aggregate it for EINF compliance, but maintain granularity for customer requests, product labels, and marketing claims.
Preparing for EINF assurance requires product-grade evidence and controls:
1. Product data traceability: Each metric must trace to product specifications, supplier declarations, lab tests, or calculations with documented methodology.
2. Supplier evidence: Maintain supplier certificates, audit reports, sustainability declarations, and verification of critical data.
3. Calculation transparency: Document LCA models, emission factors, allocation rules, and assumptions. Make them reproducible.
4. Claim substantiation: Every environmental claim must link to specific evidence. Create a claim register with supporting documentation.
5. Sample readiness: Be prepared for auditors to sample specific products, suppliers, or facilities. Have complete evidence packages ready.
Framework recommendation: Use ISAE 3000 (Revised) as your assurance standard reference, and treat it like a quality audit.
Dcycle is built specifically for product-led ESG reporting with the rigor and traceability that consumer goods teams demand.
Product-level integration: Direct connection to PLM, supplier portals, quality systems, and ERP – no manual data entry for product specifications or supplier data.
Audit-ready evidence: Each number traces to product evidence with clear calculation methodology and version control – from supplier declarations to finished product claims.
Supply chain management: Built-in supplier portal, data validation, evidence storage, and audit trails for managing complex supplier networks.
Product-level reporting: Calculate and report at company, category, or product level. Support product footprints, packaging EPR, customer requests, and marketing claims.
Multi-framework compliance: Generate EINF, CSRD, product footprints, packaging EPR, customer reports, and claim substantiation from a single data set.
Most importantly, we are a solution, not consultancy. We provide the technology infrastructure that consumer goods teams need to own their product ESG data, control their processes, and deliver audit-ready reports – without dependency on external advisors.
In a regulatory environment where measuring well is the difference between competitiveness and falling behind, Dcycle makes sustainability work as a strategic lever for product innovation, not as an administrative burden.
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.
Some strategies require initial investment, but long-term benefits outweigh costs.
Investing in carbon reduction is not just an environmental action, it’s a smart business strategy.
.png)
