Most packaging managers know CSRD is coming. Far fewer know what it actually demands from them - at the data level, line by line, in the sustainability report.
ESRS E5 - the standard on Resource Use and Circular Economy - is where packaging becomes a reporting obligation. Not vaguely. Specifically. And the gap between "we have sustainability goals" and "we have audit-ready data" is where most companies will struggle.
This post maps the exact data points ESRS E5 requires for packaging, explains what the Omnibus simplification changed (and what it didn't), and shows why fragmented data from Excel and ERP exports will not survive third-party assurance.
What Omnibus Changed - and What It Didn't
The EU's Omnibus I Directive, formally adopted in February 2026, significantly reshaped CSRD's scope and timeline. The Omnibus directive narrows mandatory CSRD reporting to EU entities with more than 1,000 employees and net turnover exceeding €450 million. EFRAG's simplified ESRS cut mandatory data points by roughly 70% - from approximately 1,073 down to around 320 core metrics.
That sounds like relief. But the underlying logic hasn't changed.
Double materiality remains mandatory under the Omnibus framework - companies must still conduct a double materiality assessment covering both impact materiality and financial materiality. Limited assurance is still required. XBRL digital tagging is still required. And for any company where circular economy topics are material - which includes virtually every manufacturer, FMCG brand, or retailer handling significant packaging volumes - ESRS E5 disclosures remain in scope.
Who is still in scope for ESRS E5? Companies with significant product waste or packaging obligations, manufacturers with material waste streams, and retailers handling high volumes of packaging are explicitly named as ESRS E5 candidates — even under the simplified Omnibus framework. If packaging is core to your business, it is almost certainly material under your double materiality assessment.
The Omnibus simplification changes how much you report - not whether packaging data is reportable. Wave 2 companies now report for FY2027, with first publication in 2028. That makes 2026 a preparation year - the window to build the data foundation, not to wait.
ESRS E5 and Packaging: The Five Disclosure Requirements
ESRS E5 is structured around five disclosure areas. Three are qualitative (policies, actions, targets - E5-1 through E5-3). Two are quantitative and directly packaging-relevant: E5-4 Resource Inflows and E5-5 Resource Outflows.
| Disclosure Requirement | Focus | Packaging Data Required |
|---|---|---|
| E5-1 | Policies on resource use & circular economy | Qualitative — circular design commitments, packaging reduction targets |
| E5-2 | Actions & resources allocated | Qualitative — investments in recyclable material switch, supplier programmes |
| E5-3 | Measurable targets | Time-bound goals — e.g. 50% recycled content by 2030, recyclability rate targets |
| E5-4 | Resource inflows (materials entering operations) | Quantitative — total weight of packaging materials, % recycled/secondary inputs, % sustainably sourced bio-materials |
| E5-5 | Resource outflows (products & waste leaving operations) | Quantitative — recyclability rate of packaging, waste streams by type and treatment method |
E5-4: What You Must Report on Packaging Inflows
E5-4 covers what enters your operations. For packaging-intensive companies, this is where material composition data becomes a hard reporting requirement.
Under E5-4, the sustainability statement must include:
- Total weight of packaging materials used during the reporting period, in tonnes or kilograms
- The percentage of secondary (recycled or reused) materials used in packaging - weight in absolute value and as a percentage of total material use
- The percentage of sustainably sourced biological materials used in packaging, including the certification scheme applied
- Methodological disclosure - whether data comes from direct measurement or estimation, and the key assumptions used
The denominator for all percentage calculations is the overall total weight of materials used during the reporting period. That means you need per-article material weight data across your entire portfolio, not category averages.
A critical practical problem surfaces here. If a packaging manufacturer buys plastic resin from a distributor rather than directly from the petrochemical producer, the distributor may not provide recycled content certificates. The company cannot simply assume 0% recycled content - ESRS E5 requires the percentage to be disclosed, and if it's estimated, the estimation basis must be explained. In practice, this means requesting material composition data from suppliers representing at least 80% of total material spend.
E5-5: What You Must Report on Packaging Outflows
E5-5 covers what leaves your operations - both as products placed on the market and as waste generated. This is where recyclability and waste stream data become mandatory.
For products and packaging placed on the market, E5-5 requires:
- Designed recyclability rate - the share of materials in products and their packaging that are recyclable, calculated as total weight of recyclable materials divided by total weight of materials in the product
- Circular design characteristics - durability, reusability, repairability, and disassembly/recyclability attributes of key products and packaging
For waste generated from own operations, E5-5 requires:
- Total waste generated, in tonnes or kilograms
- Waste composition by stream and material type - plastics, metals, biomass, non-metallic minerals, textiles, critical raw materials
- Waste diverted from disposal, split by hazardous/non-hazardous and by recovery type (preparation for reuse, recycling, other recovery)
- Waste directed to disposal, split by treatment type (incineration, landfill, other disposal)
- Total amount and percentage of non-recycled waste
The recyclability rate formula is explicit in the amended November 2025 ESRS draft: total weight of recyclable materials incorporated in the product ÷ total weight of materials in the product. This is a per-article calculation — not a portfolio estimate. You need recyclability data at the packaging component level.
Why Fragmented Data Fails the Audit
Here is the practical problem: most companies do not have this data in one place. Waste data sits in a local spreadsheet. Supplier material declarations arrive as PDFs and email attachments. Recycled content percentages live in ERP exports that were never designed for sustainability reporting. Recyclability assessments - if they exist at all - are buried in supplier correspondence.
ESRS E5 requires both qualitative and quantitative reporting, and the standard assumes companies have access to reliable and granular data. Yet many businesses - particularly those with complex supply chains - face significant challenges in obtaining accurate resource flow data.
The audit problem is structural. CSRD sustainability statements are subject to third-party limited assurance. Auditors will not accept batch-average claims, unverified supplier statements, or annual estimates assembled from disconnected sources. They will expect per-article data, traceable to source, with documented methodology.
Waste data may sit in a local spreadsheet, supplier data in a procurement platform, and material KPIs in a sustainability dashboard - making it difficult to build one consistent, audit-ready view across all ESRS E5 areas. Sustainability and compliance teams can spend weeks reconciling partial or incompatible data before it can be used for CSRD disclosure.
The PPWR-CSRD Data Overlap: Build Once, Report Twice
Here is the strategic upside. The packaging data required for ESRS E5 is largely the same data required for PPWR compliance - which becomes mandatory from August 12, 2026.
PPWR requires verified evidence: per-lot recycled-content certificates, mass-balance documents, substance test reports, and full material breakdowns. CSRD ESRS E5 requires the same underlying data, structured differently for the sustainability statement.
Packaging data collected for PPWR also feeds CSRD (ESRS E5), EcoVadis, EPR national registries, and customer audits - built once correctly, it is reusable; built badly, it is redone every quarter.
This is the core strategic argument for building a structured packaging data foundation now, not in 2027. The same material composition data, recyclability assessments, and supplier declarations that power your PPWR Declaration of Conformity are the inputs for your ESRS E5 disclosures. One data effort. Two compliance outputs.
From Data Gap to Audit-Ready: What a Structured Approach Looks Like
The path from scattered packaging data to an ESRS E5-ready sustainability statement runs through five concrete steps:
Material composition, component weights, and supplier data must be structured and machine-readable — not locked in PDFs, email attachments, or ERP exports. AI-powered digitisation can turn a spec sheet into structured data in under 2.5 minutes per article.
Auditors expect per-lot PCR/PIR certificates from named recyclers — not batch averages or supplier word-of-honour. Request material composition data from suppliers covering at least 80% of total material spend.
The ESRS E5-5 designed recyclability rate is calculated per product and its packaging. You need recyclability data at the component level — film, tray, label, closure — not at the portfolio level.
Waste data must be broken down by material (plastics, metals, biomass) and by treatment (recycling, incineration, landfill), split between hazardous and non-hazardous. This is often the most data-intensive E5 disclosure.
All data — specifications, certificates, recyclability assessments, waste records — must be traceable, methodology-documented, and accessible for third-party assurance. A single platform eliminates the reconciliation problem that makes Excel-based approaches fail audits.
Packa's Sustainability Cockpit generates LCA, CO₂, recyclability, and EPR data at item level - the same structured data foundation that powers PPWR Declarations of Conformity and feeds directly into ESRS E5 disclosures. One platform. One data effort. Both regulatory outputs covered.
The Bottom Line
ESRS E5 is not a vague sustainability commitment. It is a structured set of quantitative data requirements - material weights, recycled content percentages, recyclability rates, waste stream breakdowns - that must be traceable, methodology-documented, and auditable.
The Omnibus simplification reduced the number of mandatory data points. It did not remove the obligation to report packaging data where circular economy topics are material. And for most companies with significant packaging portfolios, they are.
The companies that will pass CSRD assurance are not the ones with the best sustainability strategy on paper. They are the ones with the best packaging data infrastructure underneath it.
