What CSRD asks of manufacturers and where records fit

What the CSRD asks of large companies, what it may ask of manufacturers in their supply chains, and where product-level records fit.

By Jack Cook 24 February 2025
ESG CSRD Compliance

The Corporate Sustainability Reporting Directive (CSRD), Directive (EU) 2022/2464, is an EU law that requires companies above a certain size to report on sustainability. The Commission's own description is that these companies must disclose "information on what they see as the risks and opportunities", reported "according to European Sustainability Reporting Standards (ESRS)".

When the rules apply

The first wave covered financial year 2024, with reports published in 2025. Parliament and Council reached political agreement on 14 April 2025 on a stop-the-clock Directive to postpone the later waves. Check the Commission's CSRD page for its status and the new dates before planning around them.

What is still changing

The Commission has proposed changes that would simplify the rules and narrow which companies are in scope. Check the Commission's page for the current position before you plan around them.

What it may mean for a manufacturer

A manufacturer that supplies a large reporting company may be asked for evidence that supports that company's disclosures. That evidence can be requested at two levels:

  • Product level: the materials, components and processes behind a specific product or batch, with the certificates and test results that show them.
  • Supplier level: where each material or part came from, and what those suppliers have confirmed about their own practices.

What a customer might ask for

A request for product-level evidence usually comes down to a few plain questions: which product, which batch, which materials went into it, and what proof exists for each. A request for supplier-level evidence asks which supplier provided each material, when, and what that supplier has declared. Answering either takes longer when the proof is spread across folders, inboxes and spreadsheets.

What to do now

  • Ask your larger customers whether they report under the CSRD, and what evidence they expect from suppliers.
  • Keep certificates and test results against the product and batch they relate to, not in a separate folder.
  • Keep a current list of your material suppliers and the declarations each has given you, with dates.

Where product records fit

A disclosure is only as strong as the records behind it. For a small manufacturer those records often sit in different places: certificates in a quality folder, batch results in a spreadsheet, supplier declarations in an inbox. Keeping them against the product and the batch makes them quicker to find and easier to check when a customer asks.

TraceID's Traced module keeps a product's certificates and batch records in one place, which is the raw material for this kind of disclosure.

Where to read more

The Commission's page on corporate sustainability reporting sets out the current position: Corporate sustainability reporting (European Commission).

Share this article:

Need a clearer record model?

Discuss a practical Traced or Verified setup for your product and inspection workflow.

Talk to us

Related Articles

Book a demo