Auto Repair: How to Track Waste Oil, Tyres, and Hazardous Materials for CSRD
Auto repair and service workshops handle several forms of hazardous and regulated waste — from used engine oil to brake fluids, tyres, and chemical cleaners. Under the Corporate Sustainability Reporting Directive (CSRD) and the Voluntary Sustainability Reporting Standard for SMEs (VSME), small and medium-sized garages are expected to demonstrate responsible management of these materials.
This guide walks you through a practical, step-by-step process to track, record, and report waste oil, tyres, and hazardous materials in line with VSME Basic Module B7 – Resource Use, Circular Economy and Waste Management. For broader guidance, see the CSRD guide for auto repair shops and what waste categories you must report.
1. Why Tracking Workshop Waste Matters
Even small garages generate significant quantities of oil residues, tyres, filters, and brake fluids — all of which fall under environmental regulations. Proper tracking:
- Ensures legal compliance with national waste handling laws
- Demonstrates environmental responsibility under CSRD or VSME reporting
- Builds trust with customers and large fleet partners
- Reduces costs through efficient recycling contracts
Under CSRD: Larger companies must report on their value-chain impacts. If your workshop services fleets or corporate clients, they may ask you for your waste management data.
2. What You Need to Track
According to the VSME Basic Module (B7), every SME should disclose:
- Total annual waste generated, broken down by type (hazardous / non-hazardous)
- Waste diverted to recycling or reuse
- Material use and circularity practices, such as reusing parts or recycling fluids
For auto services, this typically includes:
| Waste Category | Examples | Reporting Type |
|---|---|---|
| Hazardous waste | Engine oil, oil filters, brake and coolant fluids, contaminated rags | Quantity in litres or kilograms |
| Tyres and parts | Used tyres, rubber, batteries, catalytic converters | Units or weight |
| Non-hazardous waste | Packaging, plastics, paper, office waste | Weight in kilograms |
| Reused/recycled materials | Oil sent to certified recyclers, tyres retreaded | Tonnes or % recycled |
3. Step-by-Step: How to Track and Record Workshop Waste
Step 1 – Identify Waste Streams
Walk through your workshop and list all activities that produce waste:
- Oil changes → used oil, filters
- Tyre replacements → used tyres
- Brake service → brake fluid, pads, metal parts
- Cleaning → solvent containers, cloths
Group them under hazardous or non-hazardous categories.
Step 2 – Set Up Simple Collection Points
Use labelled, sealed containers:
- Waste oil – metal drums with bunded storage to prevent leaks
- Filters and absorbents – closed bins or boxes
- Tyres – stack in a clean, dry area
- Chemical containers – stored in separate fire-resistant cabinets
💡 Tip: Most EU countries require certified waste carriers. Keep your waste carrier licence number on file.
Step 3 – Keep Disposal and Collection Records
For each waste collection or disposal, record:
- Date of collection
- Waste type (e.g., oil, tyre, coolant)
- Quantity (litres, kg, or units)
- Carrier or recycler’s name and permit number
- Final destination (recycling, recovery, or disposal site)
Store copies of waste transfer notes or receipts — these serve as your audit trail.
Step 4 – Summarise Monthly and Annual Totals
At the end of each month:
- Add up quantities for each waste category
- Convert units if needed (e.g., 1 litre = 0.9 kg for waste oil)
- Note any recycling percentages or reuses
| Month | Waste Oil (L) | Tyres (Units) | Batteries (Units) | Waste Recycled (%) |
|---|---|---|---|---|
| Jan | 480 | 38 | 5 | 92% |
| Feb | 530 | 40 | 6 | 90% |
| … | … | … | … | … |
Use this table to report your annual data in your VSME sustainability statement or your CSRD-aligned supplier form.
Step 5 – Work with Certified Recyclers
Always use approved recyclers or waste management partners who can provide:
- Waste transfer documentation
- Certificates of recycling or disposal
- Annual summaries (many can export directly to Excel)
This not only meets compliance but also simplifies your CSRD reporting.
4. Example: Simple Workshop Waste Report
Company: EcoGarage Services Ltd Year: 2024 Employees: 8 Report Type: VSME Basic Module B7
| Waste Type | Quantity | Disposal / Recycling Partner | % Recycled | Notes |
|---|---|---|---|---|
| Used oil | 5,800 L | GreenOil Recovery GmbH | 100% | Collected monthly |
| Used tyres | 480 units | TyreCycle Europe | 95% | Re-treaded or shredded |
| Batteries | 68 units | ReBat Ltd | 100% | Compliant with EU Battery Directive |
| Oil filters | 1,200 pcs | EcoFilter Recycling | 98% | Crushed and metal recovered |
This table can be attached to your sustainability report or client documentation.
5. Reporting Under VSME and CSRD
Under VSME (B7 – Waste Management)
You must disclose:
- Total waste generated (hazardous vs non-hazardous)
- Recycling rates or evidence of circular economy practices
Under CSRD/ESRS (E5 – Resource Use and Circular Economy)
Larger firms must show how suppliers (like garages) manage:
- Hazardous materials safely
- Waste disposal and recycling percentages
- Compliance with EU waste and chemical regulations
Providing structured data — even on a voluntary basis — helps your customers meet their own value-chain reporting duties.
6. Common Pitfalls and How to Avoid Them
| Mistake | Impact | Fix |
|---|---|---|
| Mixing hazardous and non-hazardous waste | Legal non-compliance | Use separate containers and labelling |
| No receipts from waste collector | Can’t prove proper disposal | Request a signed waste transfer note |
| Forgetting to record small quantities | Incomplete data for reports | Keep a simple logbook or spreadsheet |
| Using unlicensed carriers | Possible fines or liability | Verify permits before signing contracts |
7. Quick Wins for Greener Workshops
- Switch to bulk oil delivery systems to cut packaging waste.
- Encourage tyre retreading or recycling schemes.
- Replace solvent cleaners with water-based alternatives.
- Join a local waste co-operative to share recycling costs.
- Train staff on waste segregation and spill prevention.
Key Terms
- CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464) setting sustainability disclosure rules.
- VSME – Voluntary Sustainability Reporting Standard for SMEs, EFRAG 2024.
- Basic Module (B7) – Waste and circular economy disclosure under VSME.
- Hazardous Waste – Waste posing risk to human health or the environment (e.g., oil, chemicals).
- Waste Transfer Note – Document proving proper disposal by a licensed carrier.
- Scope 3 Emissions – Indirect emissions from waste treatment, logistics, or product end-use.
- Circular Economy – Practice of reusing, recycling, and minimising waste.