The Corporate Sustainability Reporting Directive (CSRD) represents the most significant expansion of sustainability reporting requirements in Europe. For hospitality businesses of certain sizes—and those in their value chains—food waste reporting is now squarely in scope.
What Is CSRD?
CSRD replaces the previous Non-Financial Reporting Directive (NFRD) with much broader, more detailed requirements:
Scope expansion: More companies are covered, including large subsidiaries of non-EU companies operating in the EU.
Detailed standards: European Sustainability Reporting Standards (ESRS) specify exactly what must be reported.
Assurance requirement: Reports must be independently audited.
Digital tagging: Reports must be machine-readable.
Timeline
CSRD applies in phases:
- 2024 reporting (published 2025): Largest public interest companies already subject to NFRD
- 2025 reporting (published 2026): Other large companies meeting two of: >250 employees, >€40M revenue, >€20M assets
- 2026 reporting (published 2027): Listed SMEs (with opt-out until 2028)
- 2028 reporting (published 2029): Non-EU companies with significant EU operations
Food Waste Under ESRS
The European Sustainability Reporting Standards include food waste as part of:
ESRS E5: Resource use and circular economy
- Disclosure of resource inflows and outflows
- Waste generation and management
- Circular economy metrics
ESRS E1: Climate change
- Scope 3 emissions (including from waste)
- Emissions reduction targets and progress
For hospitality companies, food waste is typically a material topic requiring detailed disclosure.
What You Need to Report
Likely requirements for food waste under CSRD:
Quantitative metrics:
- Total food waste (tonnes)
- Food waste by destination (landfill, composting, AD, etc.)
- Food waste prevention measures and their impact
- Year-on-year trends
Strategy and governance:
- Policies on food waste
- Targets and progress
- Management accountability
- Integration with business strategy
Value chain:
- Upstream impacts (supply chain waste)
- Downstream impacts (where applicable)
Risks and opportunities:
- Regulatory risks
- Physical risks (climate impact on supply)
- Transition risks
- Opportunities from waste reduction
Preparation Steps
1. Assess materiality: Conduct a double materiality assessment to confirm food waste is material for your business.
2. Gap analysis: Compare current capabilities against ESRS requirements.
3. Build systems: Implement data collection and management systems that meet requirements.
4. Establish baselines: You can't report trends without historical data.
5. Develop narratives: CSRD requires qualitative as well as quantitative disclosure.
6. Prepare for assurance: Build audit-ready data systems from the start.
Implications for Non-Covered Companies
Even if your company isn't directly subject to CSRD, you may be affected:
Value chain requirements: Large companies must report on their value chains. If you're a supplier to CSRD-covered companies, expect information requests.
Competitive pressure: Companies not required to report may choose to anyway, to remain competitive.
Future expansion: Scope is likely to expand over time.
Technology and Data Requirements
CSRD's granularity and assurance requirements essentially mandate systematic data collection:
- Manual estimates are unlikely to pass audit
- Consistent methodology across sites is required
- Audit trails are mandatory
Our platform provides CSRD-ready food waste data collection and reporting.
Next Steps
If CSRD applies to you or your clients:
- Confirm your timeline (when requirements apply)
- Identify material topics including food waste
- Assess current data capability against requirements
- Build necessary systems and processes
- Prepare for first reporting cycle
Contact us for help navigating CSRD food waste requirements.