PLMV-KB-016 · Regulation & Compliance · Reviewed 2026-10-16
CSRD and Product Data: What Sustainability Reporting Needs
The Corporate Sustainability Reporting Directive (CSRD), Directive (EU) 2022/2464, requires large companies to report sustainability information under the European Sustainability Reporting Standards (ESRS). After the Omnibus I Directive (EU) 2026/470, it covers companies with more than 1,000 employees and over EUR 450 million turnover. Product data feeds emissions, circularity and substance disclosures.
Key takeaways
- Omnibus I narrowed CSRD scope to EU companies with more than 1,000 employees and over EUR 450 million net turnover, and removed listed SMEs.
- Companies newly in scope first report on financial year 2027, after the 2025 stop-the-clock directive postponed the second wave.
- Simplified ESRS, published in September 2026, apply from financial year 2027 and cut mandatory datapoints by more than 60%.
- PLM supplies the product-level data behind Scope 3 emissions, resource use and substances of concern disclosures.
How Omnibus I changed CSRD
The CSRD entered into force in January 2023 with a phased scope. In 2025 and 2026 the EU simplified it in two steps:
- Stop-the-clock: Directive (EU) 2025/794, adopted in April 2025, postponed reporting for the second and third waves by two years.
- Content and scope: the Omnibus I Directive (EU) 2026/470 was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026. Member States must transpose the CSRD amendments by 19 March 2027.
| Topic | Position after Omnibus I |
|---|---|
| EU companies in scope | More than 1,000 employees and net turnover above EUR 450 million (both criteria) |
| Non-EU groups | EU net turnover above EUR 450 million and an EU subsidiary or branch above EUR 200 million |
| Listed SMEs | Removed from scope |
| First wave (FY2024 reporters) | Continue; Member States may exempt those now below the thresholds for FY2025 and FY2026 |
| Newly in-scope companies | First report on FY2027, published in 2028 |
| Non-EU groups | First report on FY2028, published in 2029 |
| Assurance | Limited assurance only; reasonable assurance dropped |
| Sector-specific ESRS | Removed |
Smaller companies in a reporter's value chain, with up to 1,000 employees, can decline information requests beyond the voluntary standard.
What the simplified ESRS mean
The Commission published delegated acts on revised ESRS and a voluntary standard for smaller companies in July 2026. They appeared in the Official Journal on 21 September 2026 and apply to financial years beginning on or after 1 January 2027, with early application allowed for 2026. Mandatory datapoints fall by more than 60%. For product data, the main points are:
- ESRS E1 (climate): Scope 1, 2 and significant Scope 3 emissions remain, which keeps purchased goods and use-phase emissions relevant.
- ESRS E2 (pollution): substances of concern disclosures remain, but only for material manufacturers, importers or users, aligned with REACH and CLP thresholds.
- ESRS E5 (circular economy): resource inflows and outflows focus on key materials; quantitative durability and repairability requirements for products were replaced by narrative disclosure.
All of these apply only where the topic is material in the double materiality assessment. For a manufacturer, climate and resource use are usually material, so product-level emissions and material data remain relevant even after simplification. The value chain cap limits what reporters can demand from smaller suppliers, which makes internally held product data, such as bills of materials and supplier declarations already collected for compliance, more important as an input.
Which product data does CSRD reporting draw on?
| Disclosure | Product data needed | Typical source |
|---|---|---|
| Scope 3 category 1 (purchased goods) | Material quantities per product, supplier emission factors | PLM bill of materials, procurement |
| Scope 3 category 11 (use of sold products) | Energy consumption profiles, product lifetime | PLM specifications |
| Scope 3 category 12 (end-of-life) | Material composition, recyclability | PLM, packaging specifications |
| E2 substances of concern | Substance content per product and sales volumes | Compliance software, ERP |
| E5 resource inflows | Material weights, recycled and bio-based content | PLM, supplier declarations |
| E5 resource outflows | Product and packaging weights, waste streams | PLM, ERP |
Aggregation multiplies product-level values by volumes from ERP, so consistent identifiers between systems matter as much as the values themselves.
Where PLM fits in the reporting stack
CSRD reports are compiled in sustainability reporting software, though the underlying product data originates in operational systems. Organisations that already compute a product carbon footprint per item can roll these values up into Scope 3 instead of relying on spend-based estimates. Substance data collected for REACH and RoHS compliance supports E2, and packaging data gathered under PPWR supports E5.
Reporting teams should agree data definitions with PLM owners, for example whether recycled content is calculated by mass balance or physical segregation, and document them for assurance. The digital thread between PLM, ERP and the reporting tool reduces manual reconciliation. Vendors such as Siemens Teamcenter, Aras Innovator and Centric Software offer sustainability data extensions with differing scope. Because limited assurance covers the reported figures, the lineage from product record to reported total should be traceable and repeatable.
Frequently asked questions
Which companies are in CSRD scope after Omnibus I?
After Directive (EU) 2026/470, CSRD applies to EU companies with more than 1,000 employees and net turnover above EUR 450 million, and to non-EU groups with EU turnover above EUR 450 million and an EU subsidiary or branch above EUR 200 million. Listed SMEs were removed. Member States must transpose the changes by 19 March 2027, so national rules may still vary in detail.
When do newly in-scope companies first report under CSRD?
Companies that meet the new thresholds but were not first-wave reporters first report on financial year 2027, with reports published in 2028. Non-EU groups first report on financial year 2028. First-wave companies that reported for 2024 continue, although Member States may exempt those now below the thresholds for financial years 2025 and 2026.
Does CSRD require a product carbon footprint for every product?
No. CSRD requires company-level disclosures, including significant Scope 3 emissions where climate is material. It does not mandate a footprint per product. Many companies still use product-level footprints from PLM or LCA tools because they improve Scope 3 accuracy over spend-based estimates and are increasingly requested by customers and other EU laws.
Sources
- Directive (EU) 2022/2464 Corporate Sustainability Reporting Directive (EUR-Lex)
- Directive (EU) 2026/470 Omnibus I amending CSRD and CSDDD (EUR-Lex)
- EFRAG: Commission publishes delegated act on revised ESRS
Reviewed 16 October 2026 by the PLM Vendors editorial team. Regulatory dates and vendor details change; check the sources for the latest position.