ESG Reporting Needs Data You Don't Have Yet: Downstream Product Waste

General background only, not legal or compliance advice - ESRS reporting obligations depend on your specific circumstances and should be confirmed with your sustainability and legal advisors.

Ask a sustainability team how confident they are in their downstream waste and product-use figures, and the honest answer is usually: those numbers are modelled, not measured. That’s not a failure of the team - it’s a reflection of a real gap in where the underlying data would even come from.

What CSRD Actually Asks For

The EU’s Corporate Sustainability Reporting Directive (CSRD) has pushed sustainability reporting from a voluntary nice-to-have into a structured, auditable requirement for a growing set of companies operating in Europe. Most of the attention so far has gone to emissions and supply-chain data. Less discussed is a gap on the other side of the transaction: what happens to a product after it’s sold.

CSRD requires in-scope companies to report against the European Sustainability Reporting Standards (ESRS), using a double-materiality lens - both how sustainability issues affect the business, and how the business affects the environment and society. Two areas of that framework reach further downstream than most companies currently have visibility into: ESRS E5 (resource use and circular economy), which covers waste generation, and the downstream categories of Scope 3 emissions, which include the use and end-of-life of products a company has already sold.

Most companies can report reasonably well on what happens before a sale - manufacturing emissions, supplier data, packaging materials. Almost none have structured data on what happens after: how much of a consumable product actually gets used versus wasted, or how it’s disposed of. That data was never collected in the first place, because nothing in a typical commerce stack - Shopify, a CRM, a logistics system - is built to ask a customer what happened after delivery.

Estimates Are the Default, Not a Choice

For most consumable and physical product categories, downstream waste and use-phase impact are currently estimated using category-level industry averages, because no company-specific measurement exists. That’s a reasonable stopgap, but it means a brand with a genuinely below-average waste profile and one with an above-average one can end up reporting an identical downstream figure - the estimate can’t tell them apart.

What Measured Data Looks Like Instead

A structured question asked directly to customers after delivery - how much of this specific product, in this pack size, did you actually use - replaces an industry assumption with a real, product-level number. Aggregated across customers, that becomes a waste and consumption signal per SKU, which is both more accurate for reporting and more useful operationally: it also tells a product team which specific pack sizes or formulations are driving waste, not just a company-wide average.

Where This Fits an ESG Data Pipeline

This kind of data doesn’t replace the broader ESG reporting process - emissions accounting, supplier audits, and materiality assessments remain their own workstreams, typically owned by sustainability and finance teams with their own tooling. What post-purchase consumption data adds is a missing input to that pipeline: a measured figure for the one part of the product lifecycle - after delivery, before disposal - that’s hardest to observe any other way, feeding into the E5 and downstream Scope 3 categories rather than replacing the reporting process around them.

Don’t Wait Until You’re In Scope

Two things make waiting a weaker strategy than it looks for a growing brand. First, CSRD’s scope has consistently expanded to cover more companies over time - including large, listed SMEs in later phases - so a brand growing quickly in revenue or headcount can move into scope faster than expected. Second, and more practically: downstream product-use and waste data can’t be reconstructed retroactively. A company that starts measuring it a year before it’s required has a year of real data; a company that waits until it’s mandatory starts from zero, under a deadline.

A brand doesn’t need a full ESG reporting function in place years in advance. What’s realistic and worth doing early is establishing the data collection itself - specifically the parts, like post-purchase product waste and consumption signal, that depend on an ongoing feedback loop with customers rather than a one-time audit. Emissions accounting and supplier audits can be built out closer to when they’re actually required; a customer-facing data collection process benefits from starting well before it’s needed, simply so there’s a track record by the time reporting does become mandatory. The useful side effect: the same signal that eventually feeds a sustainability disclosure is, right now, product-level information about satisfaction, consumption, and waste that a product team can act on today.

A Narrow, Honest Starting Point

Turning “we estimate” into “we measured” for one part of a sustainability report is a meaningfully smaller project than overhauling ESG reporting entirely - and for brands in food, beverage, beauty, or other consumable categories, it’s often the single largest source of downstream uncertainty in the report.

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TrueSignal supplies measured, SKU-level consumption and waste data as an input to sustainability reporting - not a CSRD compliance or assurance product. See how TrueSignal works.