CSRD & ESG: how sustainability reporting, PPWR and the product passport interlock

Many companies treat their sustainability obligations as separate projects: the ESG team writes the report under the Corporate Sustainability Reporting Directive (CSRD), packaging development handles the EU Packaging and Packaging Waste Regulation (PPWR), product management the Digital Product Passport and accounting the volume reporting for extended producer responsibility (EPR). Yet all four draw on largely the same data. This article shows where the rules interlock, where they differ and how to collect the data once and use it several times.

CSRD

Sustainability reporting under the ESRS

PPWR

Product requirements and evidence per packaging

DPP

Product data digitally on the product, under the ESPR and the Battery Regulation

Shared basis

Material, weight, recycled content, recyclability, supply chain

Four obligations, one data basis

The rules pursue different goals. The CSRD requires companies to report on their impacts, risks and opportunities. The PPWR sets requirements for every single piece of packaging and requires evidence for them. The Digital Product Passport makes product information available to customers, retailers and authorities. EPR reporting accounts for the volumes of packaging a company places on the market. The perspective differs each time, but the underlying data is largely the same.

Where CSRD and PPWR meet

The closest link runs through ESRS E5 on resource use and circular economy. If the topic is material for a company, it reports on resource inflows, meaning which materials are used in what quantities and how high the share of secondary material is, and on resource outflows, meaning how circular products and packaging are designed. These are exactly the values the PPWR collects per packaging: material, weight, recycled content and recyclability.

The difference is altitude. The PPWR asks about the individual packaging, the CSRD about the company as a whole. For the report, the individual values are aggregated. If you have recorded your packaging data cleanly per component for the PPWR, you can derive totals, shares and developments over the years. It does not work the other way round: a company-level figure does not help with the declaration of conformity for a specific packaging.

Where the Digital Product Passport comes in

The Digital Product Passport under the Ecodesign Regulation (ESPR) and the Battery Regulation makes product data available digitally on the product. It becomes mandatory for the first product groups from 2027, with more following step by step through delegated acts. Much of the passport content, such as material composition, recycled content or disposal information, overlaps with what the PPWR needs for the packaging and the CSRD for the report.

The passport plays a special role: it makes the data visible externally. What appears as an average in the sustainability report appears in the passport for a specific product. Contradictions between the two are therefore noticed faster, by customers, retailers and authorities.

EPR reporting, claims and supply chain

• EPR reporting: the volumes you report for extended producer responsibility should match the material quantities in the sustainability report. Discrepancies are a typical audit point.
• Environmental claims: since the EmpCo Directive, claims such as “recyclable” or “made from recycled material” have to be substantiated. That evidence comes from the same data as the PPWR evidence and the report.
• Supply chain: the PPWR obliges suppliers under Art. 16 to give the manufacturer the information it needs. For the CSRD, requests to smaller partners in the value chain are meant to be limited. Both requests can still be bundled if they ask for the same fields.
• Emissions: packaging materials feed into Scope 3 emissions under ESRS E1. Material and weight per packaging are the basis for that.

Why separate projects get expensive

If you handle the obligations separately, you collect the same data several times, often from the same suppliers, in different formats and at different times. That costs time and creates contradictions: the report shows a different recycled content than the technical documentation, the product passport a different weight than the EPR report. At the latest during an audit of the report or a request from market surveillance, it shows.

How to connect the obligations

• Collect once: record material, weight, recycled content and recyclability per packaging and component in one place.
• Bundle supplier requests: one request that covers PPWR evidence, product passport and reporting data instead of three separate ones.
• Aggregate instead of recalculating: derive report figures from the individual values rather than estimating them separately.
• Keep versions: when packaging changes, it affects evidence, passport and report. A change history shows which state applied when.
• Clarify responsibilities: ESG, packaging development, purchasing and product management work with the same data and should know who maintains it.