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ESRS — the sustainability reporting standards and your product data

The twelve ESRS standards, the 3 July 2026 revision and the datapoint cut, a map of which disclosures are fed by product data, and the value-chain cap that protects suppliers with 1,000 employees or fewer.

Author: myDPP Team

ESRS — the sustainability reporting standards and your product data

The CSRD says who reports. The ESRS say what exactly has to be disclosed — which is why the standards, not the directive, are what generates work inside manufacturing companies. The 2023 version contained more than a thousand datapoints. On 3 July 2026 the European Commission adopted a delegated act that removes more than 60% of the mandatory ones and more than 70% of all of them. That is not cosmetic tidying; it is a rewrite of the standard.

For a manufacturer, one distinction matters more than any other, and it is the one most ESRS explainers lose: some disclosures can be filled from accounting and HR systems, and some only from product data — material composition, component masses, recycled content share, emissions in the use phase. That is precisely the same asset the digital product passport is built on. This article maps the twelve standards, sets out what the 2026 revision changed, and identifies which disclosures can only be fed from the product level.

Key takeaways

  • ESRS is twelve standards: ESRS 1 (general requirements), ESRS 2 (general disclosures), five environmental (E1–E5), four social (S1–S4) and one on governance (G1). The 2026 revision kept that whole architecture.
  • The original set is Delegated Regulation (EU) 2023/2772. The Commission adopted the revised version on 3 July 2026 as a delegated act, together with a separate standard for voluntary use.
  • The cut: more than 60% of mandatory datapoints and more than 70% of all datapoints. Mandatory datapoints drop from over 1,000 to roughly 320. The Commission estimates reporting costs fall by more than 30% per undertaking.
  • The revised ESRS apply to financial years beginning on or after 1 January 2027, with early application possible for financial year 2026 once the act enters into force.
  • The delegated act is in the scrutiny period of the European Parliament and the Council — two months, extendable by a further two. It enters into force after publication in the Official Journal, provided neither institution objects.
  • Double materiality stays. What changed is the method: the materiality assessment is more proportionate, principles-based and run top-down. A clarification was added that faithful presentation applies to the report as a whole, not to each datapoint separately.
  • Omnibus I introduced the value-chain cap: a company in scope of the CSRD cannot require a counterparty with 1,000 employees or fewer to provide more information than the voluntary standard sets out. That protects every smaller company, not only formally defined SMEs.
  • The cap does, however, have a climate gap — more on that below. Do not assume customer questionnaires are about to disappear.
  • The two standards fed mainly by product data are E1 (climate) and E5 (resource use and circular economy); partly also E2 (pollution, substances) and E4 (biodiversity).
  • myDPP is not a CSRD reporting tool and does not produce an ESRS-compliant report. It maintains the product data from which some ESRS disclosures can be calculated.

What the ESRS are and how the twelve standards divide up

ESRS (European Sustainability Reporting Standards) are the implementing standards for the CSRD. The directive sets the scope and the obligation; the standards set the content of the disclosures. The division is as follows:

Cross-cutting standards — always apply:

  • ESRS 1 — General requirements. Contains no disclosures of its own. It establishes the architecture: how to run the materiality assessment, how to draw value-chain boundaries, how to handle estimates and time horizons.
  • ESRS 2 — General disclosures. Disclosures that are mandatory regardless of the outcome of the materiality assessment: business model, strategy, the role of governance bodies, risk management processes, and the result of the materiality analysis itself.

Environmental standards:

  • ESRS E1 — Climate change. Transition plan, energy consumption, greenhouse gas emissions in scopes 1, 2 and 3, reduction targets, physical and transition risks.
  • ESRS E2 — Pollution. Emissions to air, water and soil, microplastics, and also substances of concern and substances of very high concern.
  • ESRS E3 — Water and marine resources. Water withdrawal, consumption and discharge, and the water stress sensitivity of the location.
  • ESRS E4 — Biodiversity and ecosystems. Impacts on habitats and species, land-use change, dependencies on ecosystem services.
  • ESRS E5 — Resource use and circular economy. Resource inflows and outflows, secondary raw material share, product durability and repairability, waste broken down by stream and treatment route.

Social standards:

  • ESRS S1 — Own workforce.
  • ESRS S2 — Workers in the value chain.
  • ESRS S3 — Affected communities.
  • ESRS S4 — Consumers and end-users.

Governance:

  • ESRS G1 — Business conduct. Corporate culture, anti-corruption, payment practices towards suppliers, political influence.

With the exception of ESRS 1 and ESRS 2, whether each remaining standard has to be filled in depends on the outcome of the double materiality analysis. A metal products manufacturer will have extensive E1, E2 and E5, and potentially immaterial E3. We cover the double materiality principle in more depth in the article on CSRD and sustainability reporting.

What the 3 July 2026 revision changed

The revision follows from the Omnibus package announced in February 2025. EFRAG delivered its technical advice to the Commission on 3 December 2025, the draft delegated act went to public consultation in May 2026 (comments due 3 June 2026), and the Commission adopted the final act on 3 July 2026. On the same day it adopted a second delegated act — a sustainability reporting standard for voluntary use, intended for smaller companies.

What changed in substance:

  • Datapoints. Mandatory ones fell by more than 60% — from over 1,000 to roughly 320 (sector analyses put the figure at 61% against the 2023 version) — and all datapoints by more than 70%. The second number is higher because the category of voluntary datapoints was removed from ESRS altogether; only mandatory requirements remain.
  • Structure of the standards unchanged, disclosure requirements rebuilt. The twelve standards and their thematic scopes were kept, but the disclosure requirements inside the standards were renumbered and reorganised. That has a practical consequence: data mappings and templates built against the 2023 numbering do not carry over one-to-one.
  • Materiality assessment. Double materiality stays as a principle, but the method is more proportionate and principles-based, with a clearer top-down approach. A clarification was added that faithful presentation refers to the report as a whole, not to each datapoint — which takes some of the risk attached to a single imperfect number off companies.
  • Costs. The Commission estimates reporting costs will fall by more than 30% per undertaking.

Formal status today: the delegated act has been adopted by the Commission and transmitted to the European Parliament and the Council for scrutiny. The scrutiny period is two months and can be extended by a further two. The act enters into force after publication in the Official Journal if neither institution objects. Until that point, early application for financial year 2026 is not possible.

Which ESRS disclosures come from product data

This is the core of the article and also the place where CSRD projects most often open a gap: the company builds its data collection around finance and HR, and then discovers that several disclosures cannot be closed without descending to the level of the individual product.

ESRS E1 — climate: scope 3 is a product data problem

Scope 1 and 2 emissions are calculated from fuel and energy consumption at sites — meter and invoice data. Scope 3 is different. Two categories weigh heaviest on manufacturers:

  • Purchased goods and services — emissions embedded in the materials and components you buy. Calculating them requires a product structure with masses: how many kilograms of which material go into the product, from which supplier, with what emission factor.
  • Use of sold products — for energy-using goods, often the largest single item in the whole footprint. It requires data on energy draw, assumed lifetime and usage profile.

The methodology and input data here are in practice identical to those for the product carbon footprint (PCF). A company that calculates PCF for its products already has the foundation for E1; a company that only holds purchasing totals in monetary terms is condemned to average factors and spend-based estimates.

ESRS E5 — resources and circularity: disclosures calculated directly from the product

E5 is the standard most tightly bound to product data in the whole set. Among other things it requires:

  • Resource inflows — total mass of materials used, plus the share of secondary raw materials and biological materials. This cannot be reported without material composition including recycled content shares at component level.
  • Resource outflows — product properties relevant to circularity: durability, repairability, recyclability, recycled content.
  • Waste — mass and composition by stream and by treatment route: preparation for reuse, recycling, other recovery, disposal, split between hazardous and non-hazardous.

It is worth noticing that durability, repairability and recycled content are the same attributes that ESPR introduces as ecodesign requirements and product passport fields. Two different legal regimes ask for one value — and if that value lives in two spreadsheets inside the company, sooner or later they will diverge.

ESRS E2 — substances: data you already report elsewhere

E2 covers substances of concern and substances of very high concern in products. That overlaps with the records kept for the SCIP database and the SVHC candidate list and — for electronics — with the restrictions of the RoHS Directive. The source is the same dataset: chemical composition at component level, supplier declarations, concentration thresholds.

ESRS E4 and S2 — supply chain, not product

E4 (biodiversity, land-use change) rests on the origin of raw materials, which meets the geolocation data collected under EUDR. S2 (workers in the value chain) is data about suppliers, not about products — that layer connects rather to CSDDD and due diligence.

What product data will not solve

S1, S3, G1 and the cross-cutting ESRS 2 are disclosures about the organisation: headcount, pay, the structure of governance bodies, payment practices, anti-corruption processes. None of those numbers exist in product data, and no product data management tool will generate them. The correct order in a CSRD project is: materiality analysis first, then a split of disclosures into those coming from finance and HR systems and those coming from product systems, and only at the end the choice of tools.

The value-chain cap — the most important change for suppliers

For companies below the CSRD thresholds this is the most significant part of the whole reform. The Omnibus I Directive introduced the value-chain cap: an undertaking in scope of the CSRD cannot require an entity in its value chain employing 1,000 people or fewer to provide information going beyond the content of the standard for voluntary use. A counterparty below that threshold is entitled to refuse to answer questions that go further.

Two things are worth emphasising:

  • The cap protects all companies below 1,000 employees, not only those meeting the formal definition of an SME. That covers a substantial share of mid-sized manufacturers.
  • For large companies already reporting, the cap applies from financial year 2027.

And now the honest caveat missing from most communications about “protecting suppliers”. The cap has a gap, and it is climate-shaped. The protection is measured by the content of the voluntary standard, and outside its reach sit the climate disclosures from that standard’s supplementary module — greenhouse gas reduction targets and climate risks — as well as scope 3 in full depth. In practice that means climate questionnaires from customers will not disappear, and a supplier who counted on the cap lifting the entire burden will be surprised. Data on emissions embedded in a product remains the single most frequently requested item in all value-chain communication.

The operational conclusion is independent of whether a company is in CSRD scope: since you will be asked about emissions at product level anyway, it pays to calculate them once, in a reusable structure, rather than reconstructing them for every new questionnaire.

Timeline

DateEvent
31 July 2023Adoption of the original ESRS set — Delegated Regulation (EU) 2023/2772
February 2025Announcement of the Omnibus package simplifying reporting
3 December 2025EFRAG delivers technical advice to the Commission on simplified ESRS
26 February 2026Omnibus I Directive (EU) 2026/470 published in the Official Journal
18 March 2026Omnibus I Directive enters into force
6 May 2026Draft delegated act with the revised ESRS goes to consultation
3 June 2026Public consultation closes
3 July 2026Commission adopts the revised ESRS and the voluntary standard
2 (+2) months from adoptionScrutiny period of the European Parliament and the Council
financial year 2026Early application possible — once the act enters into force
from 1 January 2027Mandatory application of the revised ESRS; value-chain cap for large companies

What the ESRS are not

  • Not the same thing as the CSRD. The CSRD is a directive and sets who is in scope. The ESRS are a delegated act and set the content of the disclosures. The change to scope thresholds happened in Omnibus I, not in the ESRS.
  • Not a product standard. ESRS report at company level, for a financial year, in the management report. A digital product passport describes an item or a product model and lives continuously. A passport is not an accounting aggregate and does not replace the report.
  • Not a set to be filled in completely. Outside ESRS 1 and ESRS 2, scope follows from the materiality analysis. Trying to answer every datapoint without that analysis is the most expensive possible way to run an ESRS project.
  • Not a settled state. The delegated act is in its scrutiny period, and the numbering of disclosure requirements has changed against the 2023 version. Training material and mappings from 2024–2025 need verifying before use.

Preparation: five steps

1. Establish which side of the threshold you are on

Above 1,000 employees and €450 million net turnover — you report. Below — you have no direct obligation, but as a supplier you receive questions, and the value-chain cap marks the boundary of what you have to answer. Knowing that boundary has measurable negotiating value.

2. Run the double materiality analysis before building anything

The materiality analysis reduces the volume of work faster than any automation. The revised ESRS explicitly favour a top-down approach — start from topics, not from datapoints.

3. Split material disclosures by data source

Three buckets: finance and HR data, site operations data (energy, water, waste), product data (composition, masses, recycled content, durability, embedded emissions). The third bucket is usually the least ready and takes the longest.

4. Build product data once, for many recipients

The same recycled content figure is an answer for E5, a passport field under ESPR and a line in a customer questionnaire. One record with a defined owner, unit and change history is cheaper than three diverging spreadsheets. We describe the practical side in the article on DPP and PIM.

5. Plan for assurance and the audit trail

The report is subject to limited assurance. The assurance provider will ask where a number came from — who entered it, on what basis, when it was changed. Data without change history has to be reconstructed by hand during the audit.

Frequently asked questions (FAQ)

How do the ESRS differ from the CSRD?

The CSRD is a directive: it determines who has to report, in which document and from when. The ESRS are a delegated act: they determine the content — which specific datapoints have to be disclosed. In practice the CSRD sets the obligation and the ESRS generate the work.

How many ESRS standards are there, and did the revision change that?

Twelve: ESRS 1, ESRS 2, E1–E5, S1–S4 and G1. The revision of 3 July 2026 kept that structure and those thematic scopes, but rebuilt the disclosure requirements inside the individual standards.

Are the revised ESRS already in force?

No. The delegated act was adopted on 3 July 2026 and is in the scrutiny period of the European Parliament and the Council (two months, extendable by a further two). Mandatory application covers financial years beginning on or after 1 January 2027; early application for financial year 2026 will be possible once the act enters into force.

I am a supplier with fewer than 1,000 employees — does the cap free me from questionnaires?

Not entirely. The cap means a customer in CSRD scope cannot require more than the voluntary standard sets out, and that you may refuse to answer questions going further. Outside the protection, however, sit the climate items from the supplementary module — reduction targets and climate risks — and scope 3 in full depth. Expect questions about emissions embedded in your products to continue.

Is a digital product passport enough for ESRS reporting?

No. A passport describes a product, while an ESRS report covers the company for a financial year and includes areas that are simply not in product data — employment, governance, payment practices. A passport helps with those disclosures that require descending to product level, above all E5 and scope 3 within E1.

Does myDPP produce an ESRS-compliant report?

No. myDPP is not a CSRD reporting tool, does not run materiality analyses and does not produce a management report. It maintains product data — composition, masses, recycled content share, durability, embedded emissions — together with change history, so that it can be used both in the product passport and as input for calculating the relevant disclosures.

Sources

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