CSRD / ESRS
CSRD, ESRS and Product-Level Data
How the Corporate Sustainability Reporting Directive and ESRS relate to product-level data, and where Scope 3 reporting intersects with the DPP.
CSRD and its reporting standards, ESRS, operate at company level. The Digital Product Passport operates at product level. They look like separate worlds — but the numbers in a corporate report are the sum of product data.
Why Scope 3 needs product data
Scope 3 covers indirect emissions in the value chain. For a manufacturer it is usually the large majority of total emissions, and the largest line is purchased goods and services.
That line can be estimated with spend-based averages, but the result is coarse. Showing real performance requires material-level, supplier-specific data — exactly what a DPP collects. See primary vs secondary data.
Overlapping data fields
| Data | CSRD/ESRS | DPP | CBAM |
|---|---|---|---|
| Site energy consumption | Yes | Indirect | Yes |
| Material quantities | Yes | Yes | Yes |
| Supplier emission intensity | Yes | Yes | Yes |
| Recycled content | Yes (E5) | Yes | Partly |
| Water consumption | Yes (E3) | By product group | No |
| Hazardous substances | Yes (E2) | Yes | No |
See CBAM and the DPP and DPP data fields.
After the Omnibus
The 2025 sustainability Omnibus changed the scope and timing of CSRD and CSDDD, so fewer companies report directly. That does not remove the data demand: large in-scope companies still ask suppliers for the data behind their own Scope 3 numbers.
For an SME, therefore, the real trigger is not regulation but the customer contract. See what retailers ask suppliers for.
Building one data programme
- A shared data dictionary so the same field carries the same name in all three regimes.
- One supplier questionnaire rather than a separate form per regime.
- Site plus product breakdown: corporate reporting wants sites, passports want products.
- Decide the assurance level up front: CSRD requires limited assurance, and the same evidence can support passport fields.
See collecting data from suppliers and the carbon guide.
Frequently asked questions
I am out of CSRD scope. Am I still affected?
Yes, if you supply someone who is in scope. They will ask you for data.
Can a product carbon footprint feed a Scope 3 calculation?
With methodological alignment, yes: product PCFs can be aggregated into purchased goods emissions.
Where should I start?
With site energy and material data. Those two underpin all three regimes.
