How to Track Waste and Packaging in Retail for CSRD

Packaging waste is one of the most visible environmental impacts of retail and wholesale operations — from cardboard boxes and plastic wraps to returned or damaged goods. Under the Corporate Sustainability Reporting Directive (CSRD) and the Voluntary Sustainability Reporting Standard for SMEs (VSME), businesses are required (or encouraged) to measure and disclose how much waste they generate, how they manage it, and what portion is recycled or reused.

This guide explains how retail and wholesale companies can track, calculate, and report waste and packaging data step by step.

1. Why Waste and Packaging Matter Under CSRD

The CSRD (Directive 2022/2464/EU) expands sustainability reporting to include all material environmental impacts, including waste generation and resource use. For retailers, this means going beyond waste disposal figures — it’s about demonstrating circular practices such as reuse, recycling, and reduced packaging materials.

The VSME Standard, developed by EFRAG for smaller unlisted businesses, makes this easier by defining a single section — B7: Resource use, circular economy and waste management — which covers all relevant metrics.

2. Who Needs to Report?

a. Under CSRD

Large retailers and wholesalers must report if they exceed two of the three thresholds:

• 250 employees
• €40 million turnover
• €20 million in assets

This applies to groups and consolidated retail chains (e.g., supermarket groups).

b. Under VSME (Voluntary)

Smaller retailers, wholesalers, and distributors can use VSME Basic Module B7 to disclose waste and packaging data voluntarily. This helps SMEs respond to supply chain requests and financing due diligence while keeping compliance effort manageable.

3. What to Report

a. Waste Generation

Disclose total annual waste generated, separated into:

• Non-hazardous waste (e.g. cardboard, plastic packaging, food waste) - see our guide on what waste categories you must report
• Hazardous waste (e.g. cleaning chemicals, fluorescent tubes, batteries)

“The undertaking shall disclose the total annual generation of waste broken down by type (non-hazardous and hazardous).”

Waste should preferably be measured in kilograms or tonnes. If that’s impractical, volume (m³) can be used.

b. Waste Treatment

Report the share of waste:

• Diverted to recycling or reuse - learn more about how to track recycling and reuse
• Sent to disposal (landfill or incineration)

This distinction helps show circular economy progress. The VSME Standard provides a table format for this data.

c. Material and Packaging Flows

If your business has significant material flows (e.g., packaging for shipped goods), you must also report the annual mass-flow of relevant materials used — the total weight of packaging materials such as cardboard, plastics, or glass.

This aligns with ESRS E5 – Resource Use and Circular Economy, the equivalent CSRD disclosure standard for large companies.

4. Practical Steps for Tracking Retail Waste and Packaging

Step 1. Map Waste Sources

Identify where waste occurs:

• Shop floors (damaged goods, packaging)
• Warehouses (pallets, shrink wrap, broken containers)
• Office and backroom waste (paper, ink cartridges)

Step 2. Collect Data

Gather weight data from:

• Waste collection invoices or reports
• Packaging supplier data sheets
• Recycling contractor certificates
• In-store waste audits (weigh bins or estimate by volume)

If exact data isn’t available, use monthly averages or supplier estimates.

Step 3. Classify and Record

Use the European Waste Catalogue (EWC) codes to identify and classify waste streams. Any waste marked with an asterisk (*) is hazardous.

For example:

• 15 01 01 – Paper and cardboard packaging
• 15 01 02 – Plastic packaging
• 20 01 21* – Fluorescent tubes (hazardous)

Step 4. Distinguish Waste Fate

Split totals into:

• Recycled/reused
• Disposed (landfill/incinerated)
• Returned to supplier (e.g., pallets)

This split shows your waste circularity rate.

Step 5. Include Packaging Material Use

Track inbound and outbound packaging:

• Supplier packaging (e.g., delivery pallets, boxes)
• Customer packaging (e.g., shopping bags, e-commerce parcels)
• Internal packaging reuse systems

Step 6. Set Improvement Targets

Example:

“Reduce non-recyclable plastic packaging by 25% by 2026 compared to 2024 baseline.”

VSME allows including such targets under C2 – Comprehensive Module, complementing B7 disclosures.

5. Example: Waste Tracking for a Medium Retail Chain

Company: FreshMart Ltd Operations: 15 stores + 1 warehouse Annual turnover: €22 million Employees: 150

Initiatives:

• Introduced cardboard compaction and recycling system.
• Switched to 70% recycled content for delivery boxes.
• Partnered with suppliers to eliminate single-use pallets.

6. How to Present Waste and Packaging Data

Include both narrative and table formats in your sustainability section:

“In 2025, ShopSmart Group generated 105 tonnes of total waste, of which 86% was diverted to recycling or reuse. Packaging waste represented 52% of the total, primarily cardboard and plastic film. The company aims to phase out single-use plastic wrap by 2027.”

Attach visual aids such as pie charts or recycling rate graphs to make data accessible.

7. Circular Economy Practices for Retailers

CSRD encourages businesses to move from disposal to resource recovery. Retailers can show progress by:

• Returning supplier packaging (closed-loop systems)
• Using refillable or returnable containers
• Reducing over-packaging
• Offering reusable bags or deposit schemes
• Partnering with recyclers for take-back programmes

8. Common Challenges and Practical Fixes

Key Terms

• CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464).
• VSME – Voluntary Sustainability Reporting Standard for SMEs (EFRAG, 2024).
• Basic Module – Core disclosures for SMEs, including waste (B7).
• Comprehensive Module – Optional deeper disclosures including targets (C2).
• Circular Economy – An approach focusing on reuse, recycling, and material recovery.
• Hazardous Waste – Waste with harmful properties under the EU Waste Framework Directive.
• Packaging Waste – Materials used to contain, protect, or deliver goods, such as cardboard and plastics.
• Turnover – Total annual revenue.

To help you track all the waste and packaging data you need, use our checklist generator:

This tool will help you identify all the data points you need to collect for waste, packaging, and circular economy reporting.