Do Small Food Producers Need to Report Nutrient Runoff Under CSRD?

Fertiliser use is part of everyday farming — but excess nutrients washing into rivers and groundwater are a major environmental concern across Europe. Under the Corporate Sustainability Reporting Directive (CSRD) and the Voluntary Sustainability Reporting Standard for SMEs (VSME), this topic falls under pollution of air, water and soil.

So, what does this mean for small and medium-sized farms, cooperatives, and food producers? Let’s break it down clearly. For related guidance on agriculture reporting, see the CSRD guide for farms and what pollutants SMEs need to measure.

1. Understanding Nutrient Runoff

Nutrient runoff occurs when fertilisers — mainly nitrogen (N) and phosphorus (P) — leave farmland and enter surface or groundwater. It can cause:

• Algae blooms and oxygen depletion in rivers or lakes.
• Soil degradation and biodiversity loss.
• Long-term water quality issues affecting communities and ecosystems.

Under the CSRD’s environmental objectives, nutrient runoff is part of the “pollution” theme, alongside emissions to air and soil contamination.

2. Who Has to Report Under CSRD?

Not every farm or food producer is directly covered by the CSRD.

Large undertakings (directly in scope)

Farms or food companies must report under CSRD if they meet two of the following three thresholds (Directive 2013/34/EU, Article 3):

• 250 or more employees
• €40 million net turnover
• €20 million total assets

These companies must follow the European Sustainability Reporting Standards (ESRS), which include pollution-related disclosures such as ESRS E2 – Pollution.

SMEs (indirectly in scope)

Most small and medium-sized food producers are not legally required to report under CSRD. However, they may still need to share environmental data with buyers, processors, or banks who are required to report.

This is where the VSME Standard (EFRAG, 2024) helps — a simplified, voluntary framework for SMEs to share sustainability data efficiently.

3. What the VSME Standard Says About Nutrient Runoff

Under the VSME Basic Module (B4 – Pollution of air, water and soil), small producers are encouraged to disclose their emissions of pollutants, including those from fertilisers, if:

• They are already required by national law (e.g. Nitrates Directive reporting).
• They voluntarily monitor nutrient runoff or have data from environmental management systems.

If the information is already public (for example, through a water authority report or farm certification), the SME may simply refer to the source or hyperlink rather than repeat the data.

Practical examples of what to disclose:

• Total nitrogen and phosphorus applied annually (kg/ha).
• Measures taken to reduce runoff (e.g. buffer zones, soil cover, precision spreading).
• Any participation in sustainable agriculture schemes or certification (e.g. LEAF, GlobalG.A.P., or national nitrate programmes).

No complex modelling is required. Simple, verifiable figures and brief descriptions are enough.

4. When Nutrient Runoff Reporting Becomes Necessary

You must or are expected to report nutrient runoff data if:

If none of these apply, reporting remains voluntary, but starting early prepares you for buyer and finance requirements.

5. How to Collect Simple Data on Nutrient Runoff

Small food producers can use these low-cost methods to prepare their disclosures:

1. Estimate fertiliser inputs Track nitrogen and phosphorus application by weight (kg or tonnes). → Use invoices or nutrient management plans.

2. Note preventive practices Mention field buffer strips, soil testing, or cover cropping.

3. Link to external data If you’re part of a water protection scheme or cooperative initiative, cite it.

4. Summarise annually Keep one page showing fertiliser use, key mitigation actions, and any incidents (e.g. flooding causing nutrient loss).

Example:

“In 2024, GreenFields Farm applied 110 kg N/ha and 20 kg P/ha across 80 hectares. Runoff risks reduced through grass cover between maize rows and buffer strips along ditches. No pollution incidents reported.”

6. Why It Matters – Beyond Compliance

Even for small producers, reporting on nutrient runoff offers clear benefits:

• Market access: Buyers prefer traceable, environmentally responsible suppliers.
• Finance: Banks increasingly require sustainability data for green loans.
• Efficiency: Precision fertiliser use cuts costs and improves yields.
• Reputation: Demonstrates responsible stewardship of land and water.

7. Step-by-Step: How SMEs Can Report Using VSME B4

This aligns directly with VSME B4 and supports requests from CSRD-compliant customers.

8. What Not to Worry About

• No laboratory testing required: Estimations based on known fertiliser use are acceptable.
• No Scope 3 chain analysis: That’s only relevant for large processors.
• No penalties under CSRD: VSME reporting is voluntary, not regulatory.

However, being prepared strengthens your business for future sustainability demands.

Key Terms

• CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464), which requires large companies to disclose environmental and social impacts.
• VSME – Voluntary Sustainability Reporting Standard for SMEs, a simplified framework by EFRAG (2024).
• Basic Module (B4) – Pollution disclosure under VSME covering air, water, and soil pollutants.
• ESRS – European Sustainability Reporting Standards for CSRD-compliant companies.
• Nutrient runoff – Loss of nitrogen and phosphorus from fertilisers into water bodies.
• SME – Small and medium-sized enterprise.
• NACE Code A01 – Agriculture, forestry, and fishing sector classification.