CSRD waste reporting: preparing reliable ESRS E5 data

CSRD directive: what you need to know

The EU simplification adopted in February 2026 narrows CSRD scope to companies with more than 1,000 employees and more than €450 million net annual turnover. National transposition, group circumstances and transitional rules still need checking before determining your reporting obligations.

Why CSRD waste reporting is complex in practice

The data is there - it's generated and documented continuously across operations through: 

• service orders
• invoices
• recycler and vendor reports
• internal tracking systems

And for large organisations this poses an extra challenge in that it's distributed across different locations, vendors and formats. Each reporting cycle requires bringing these inputs together and cleaning and structuring this raw data into something understandable. That preparation step is where most of the effort sits.

What CSRD requires for waste reporting (ESRS E5)

Where ESRS E5 is material, use applicable ESRS E5 standard to define the waste and resource-use disclosures. Distinguish required disclosures from additional internal metrics, and document the reporting boundary and calculation method for each measure.

• total waste volumes
• waste types and materials
• disposal methods (recycling, recovery, incineration, landfill)
• changes over time
• performance indicators such as recycling rates

The key step: structuring waste data for reporting

Preparing waste data for CSRD reporting involves a set of practical steps that are repeated across sites and reporting periods.

1. Consolidating data across sites

Combining data from sites and vendors requires more than extraction. Reconcile collection records, invoices and summaries; check duplicates, missing weights and inconsistent units. Confirm the documentation required by each contract and applicable rule rather than assuming one universal supplier obligation. Retain validation steps and a route for correcting the source data.

2. Standardising materials and waste categories

The next step is grouping waste into consistent categories across the organisation. The European Waste Catalogue (EWC) established a consistent framework for identifying different types of waste and each European country has their own way of version of what that means in the real world. (For Germany - it's AVV codes.) These 6 digit codes are standardised across the EU and while countries can have local naming or administrative variations, the codes themselves remain the same.

For example, 15 01 06 is the code for mixed packaging while 20 03 01 is for mixed municipal waste. And these mean the same thing whether a company is operating in Germany, the Netherlands or France. But even if these codes are standardised, they still don't fully solve the classification problem at this stage because they don't reflect how companies group materials for their reporting so organisations still need a consistent way to structure their data for reporting purposes. Without standardisation, the same material may appear under different labels making it difficult to reconcile data cleanly and accurately.

3. Classifying disposal routes

The same challenge applies to the classification of disposal routes. Here are the CSRD disposal route reporting standards as outlined by ESRS E5: 

• Total waste split by hazardous vs. non-hazardous
• Treatment methods split into recycled, prepared for reuse, other recovery (eg. engergy recovery) and disposed of (eg. landfill, incineration without recovery)
• Material breakdowns including volumes by material or treatment types
• Geography or business unit breakdowns including volumes per material and treatment methods across locations
• Year on year comparisons

Agree with each recycler which quantities, treatment routes and supporting documents they can provide. Do not assume every supplier must report every ESRS metric to you. Identify missing information, record estimates transparently and classify the available evidence consistently across sites.

• Varying route descriptions: Similar disposal methods are labelled differently across vendors (eg. “energy from waste” vs “thermal recovery”), making direct comparison difficult.
• No predefined mapping to reporting categories: Disposal routes need to be consistently mapped into standard categories such as recycling, recovery or disposal to support CSRD reporting.

4. Applying consistent calculation logic

Use the definitions and calculation requirements in the applicable reporting standard. Internal operational KPIs can add useful detail, but they should not be presented as mandatory ESRS disclosures without checking that mapping. Document the rule, source and owner for each reported number.

• Recycling rate
• Separation rate
• CO₂ savings / avoided emissions
• Raw materials saved
• Recovery vs disposal share
• Cost per tonne
• Waste volumes by treatment type

Each of these KPIs has their own nuance and can reported slightly differently ways and they're not created simply because waste data exists. They depend on rules such as:

• which disposal routes count as recycling
• how mixed or transformed materials are handled
• which factors are used for CO₂ and raw material calculations
• how costs and volumes are allocated across sites, materials or routes

Real-time access to ESRS E5-relevant waste KPIs

To get an overview of previous periods, Resourcify's EasyDropAI allows new customers to simply upload all waste related documents in bulk pulling the data into a digital and structured format. And Resourcify Insights gives businesses full control as to how certain KPIs are captured, grouped and calculated. Once the setup is complete, recycler feedback is consistently fed into the system by email and all new data is structured according to your fully customised logic and made available in easy to use dashboard available for analysis or export at any time.

From waste data entry to waste ROI optimisation

Once waste data is structured consistently across sites, materials and disposal routes, it becomes possible to move beyond reporting and start using the data operationally. Instead of spending time consolidating inputs and aligning formats, teams can work with a unified dataset that supports analysis across the organisation. This makes it easier to identify patterns in waste volumes, understand where costs are driven, and compare performance between locations on a like-for-like basis.

In practice, this means waste data can be translated into concrete opportunities. For example, organisations can pinpoint sites with higher-than-average costs per tonne, identify materials with low recycling rates, or compare recycler performance across regions. As shown in the example above, structured data can be aggregated into a clear view of cost savings potential and environmental impact, highlighting where interventions such as improving sorting, renegotiating prices, or changing recycling pathways will have the greatest effect.

This shift changes the role of waste reporting. Instead of being a periodic exercise to meet reporting requirements, it becomes a continuous source of operational insight. With a consistent data foundation in place, organisations can prioritise actions, track improvements over time, and connect sustainability reporting with measurable business outcomes.

Key takeaway

CSRD waste reporting is not limited by data availability. Most organisations already have the necessary inputs across their operations. The challenge lies in turning that fragmented, operational data into a structured and consistent dataset that can be used reliably across sites and reporting periods. Building this foundation changes what waste reporting can deliver. It reduces the effort required for each reporting cycle and creates a dataset that can be used across compliance, operations and cost management.

As data preparation becomes more automated, the focus shifts towards using waste data to identify inefficiencies, improve performance and unlock measurable savings. This is where the real value lies - connecting reporting requirements with operational decision-making.

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