CSRD Reporting for Small Chemical Distributors
Small and medium-sized chemical and pharmaceutical distributors are vital to Europe’s manufacturing and healthcare supply chains. Yet they face growing pressure from suppliers, customers, and regulators to show how safely and responsibly they manage environmental, social, and governance (ESG) issues.
While many are not directly in scope of the Corporate Sustainability Reporting Directive (CSRD), larger chemical producers, logistics partners, and pharma clients are — meaning that small distributors are part of their reporting value chains.
This guide explains how smaller distributors can meet sustainability expectations using the Voluntary Sustainability Reporting Standard for SMEs (VSME) developed by EFRAG (2024). For related guidance, see hazardous substance tracking for pharmaceutical SMEs and what pollutants SMEs need to measure.
1. Why CSRD Matters for Chemical Distributors
Under Directive (EU) 2022/2464, large and listed companies must report on sustainability risks, impacts, and metrics across their own operations and value chains.
For small distributors, this means:
- You may receive sustainability data requests from suppliers or customers.
- Banks and investors could ask for ESG data before granting loans or trade finance.
- Your reporting readiness affects your reputation and competitiveness.
Fortunately, the VSME Standard provides a simpler, voluntary path to CSRD alignment — tailored for non-listed SMEs, including chemical and pharmaceutical traders, warehousers, and transporters.
2. Who Can Use the VSME Standard
You can apply the VSME Basic Module if your business is:
- Not listed on a regulated EU market
- Below CSRD thresholds (250 employees, €40m turnover, €20m balance sheet)
- Handling, distributing, or packaging chemicals, pharmaceuticals, or lab products
The Basic Module covers 11 disclosures (B1–B11) across general, environmental, social, and governance topics.
| Module | Focus | Suitable For |
|---|---|---|
| Basic Module (B1–B11) | Core sustainability data (energy, waste, workforce, governance) | Small and medium distributors |
| Comprehensive Module (C1–C9) | Optional advanced disclosures on climate targets, human rights, and risk | Growing SMEs or those in complex supply chains |
3. Key Reporting Topics for Chemical Distributors
| Area | VSME Disclosure | What to Report |
|---|---|---|
| General | B1–B2 | Company data, sustainability policies, safety culture |
| Environment | B3–B7 | Energy use, GHG emissions, pollution control, waste, circularity |
| Social | B8–B10 | Workforce safety, pay equity, training, diversity |
| Governance | B11 | Compliance, anti-corruption, and legal breaches |
4. Step-by-Step: How to Report Operations
Step 1 – Describe Your Business (B1)
Disclose:
- Legal form (e.g., GmbH, SARL, Ltd)
- NACE code (e.g., 46.75 – Wholesale of chemical products)
- Number of employees
- Turnover and main activities
- Any sustainability certifications (ISO 9001, ISO 14001, Responsible Care)
Example: “ChemServe GmbH, NACE 46.75, employs 24 people and distributes laboratory and industrial chemicals across Germany. The company operates under ISO 14001 certification.”
Step 2 – Report Energy and Emissions (B3)
Chemical warehouses often use significant energy for:
- Ventilation, temperature control, and safety systems
- Company vehicles (vans, forklifts)
- Transport and delivery services
Track:
- Electricity use (kWh) and fuel consumption (litres)
- Estimate Scope 1 (fuel) and Scope 2 (electricity) emissions
- Convert to MWh and tCO₂e using national conversion factors
Example:
| Source | Usage | Conversion | CO₂ Factor | Emissions |
|---|---|---|---|---|
| Electricity | 80,000 kWh | 80 MWh | 0.25 kg CO₂/kWh | 20 tCO₂ |
| Diesel (vehicles) | 5,000 L | 50 MWh | 2.68 kg CO₂/L | 13.4 tCO₂ |
| Total | 130 MWh | — | — | 33.4 tCO₂e |
Report energy efficiency actions (LED upgrades, renewable electricity contracts, EV vehicles).
Step 3 – Pollution Control (B4)
Chemical distributors must disclose emissions to air, water, and soil — if monitored or legally required — and mention systems that prevent leaks, spills, or volatile organic compound (VOC) emissions.
Good practices to report:
- Use of sealed containment and spill trays
- Air extraction with filters
- Regular leak inspections and safety audits
- Emergency response and containment training
Example: “In 2024, ChemServe recorded no spills or regulatory breaches. A new spill prevention system reduced solvent evaporation by 18%.”
Step 4 – Waste and Circular Economy (B7)
This is especially important for distributors handling chemical residues, packaging, and containers.
Disclose:
- Total waste generated (hazardous and non-hazardous)
- Recycling or reuse rates (%)
- Partnerships with licensed waste handlers
| Waste Type | Annual Quantity (kg) | Disposal Method | Recycled (%) |
|---|---|---|---|
| Packaging (plastic, metal drums) | 3,200 | Recycled | 95% |
| Expired chemicals | 400 | Hazardous incineration | 0% |
| Paper and pallets | 1,100 | Recycled | 100% |
Circular Practices:
- Reuse cleaned containers for compatible substances
- Returnable packaging agreements with suppliers
- Refill and dilution services to reduce waste generation
Step 5 – Workforce Safety and Training (B9–B10)
Occupational health and safety is central to your social reporting.
Disclose:
- Number of employees by contract type and gender
- Safety incidents (recordable injuries, near-misses)
- Training hours per employee
- Compliance with chemical handling standards (REACH, CLP)
Example: “All 24 employees received 12 hours of hazardous materials training in 2024. No lost-time injuries occurred.”
Step 6 – Governance and Compliance (B11)
Under B11, report any convictions or fines related to corruption, anti-bribery, or environmental breaches. If none occurred, clearly state “no violations.”
Recommended additions:
- Anti-bribery policy summary
- Internal compliance or ethics training
- Membership in sector initiatives (e.g., Responsible Care, Chemie³)
5. Example: Simplified VSME Sustainability Statement
Company: ChemServe GmbH Sector: Wholesale of chemical products Employees: 24 Reporting Year: 2024 Module: Basic (B1–B11)
| Disclosure | Key Metric | 2024 Result |
|---|---|---|
| B3 – Energy & GHG | 130 MWh; 33.4 tCO₂e | 15% renewable |
| B4 – Pollution | 0 spills; VOC reduction 18% | No incidents |
| B7 – Waste | 4.7 tonnes waste; 92% recycled | Licensed collectors |
| B9 – Health & Safety | 0 lost-time injuries | 100% trained |
| B11 – Governance | No fines or convictions | ISO 14001 certified |
Statement:
“ChemServe GmbH applies Responsible Care principles and aims to reduce emissions by 10% by 2025 through efficiency upgrades and electric delivery vans.”
6. Linking to CSRD and ESRS
Larger chemical and pharmaceutical firms reporting under CSRD/ESRS must include their value chain impacts (Article 19a, Directive 2022/2464). By following the VSME Standard, small distributors provide structured data covering:
- Energy and emissions (ESRS E1 – Climate Change)
- Pollution control (ESRS E2 – Pollution)
- Waste and resource use (ESRS E5 – Circular Economy)
- Workforce and ethics (ESRS S1/S3, G1)
This helps clients integrate SME data into their CSRD disclosures.
7. Quick Wins for Chemical Distributors
| Area | Action | Benefit |
|---|---|---|
| Energy Use | Switch to LED and renewable electricity | Lower Scope 2 emissions |
| Transport | Optimise routes or use low-emission vehicles | Reduce fuel use |
| Packaging | Reuse containers and drums | Cut waste and costs |
| Safety | Refresh spill response training | Fewer incidents |
| Documentation | Use VSME templates for B3–B11 | Streamline reporting |
Key Terms
- CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464).
- VSME – Voluntary Sustainability Reporting Standard for SMEs (EFRAG 2024).
- Basic Module (B1–B11) – Core SME disclosure framework covering environment, social, and governance topics.
- Hazardous Waste – Substances or mixtures posing environmental or health risks.
- REACH & CLP – EU regulations on chemical safety and classification.
- Responsible Care – Global chemical industry initiative promoting safe management.
- GHG Intensity – Greenhouse gas emissions per turnover unit.