ESG legislation and CSRD: is your organization ready?

ESG stands for Environmental, Social, and Governance and encompasses everything related to environmental, social, and governance issues. The abbreviation covers all aspects of environmental, social, and governance. A company's ESG objectives must be reported according to the guidelines of the CSRD (Corporate Sustainability Reporting Directive) and the ESRS (European Sustainability Reporting Standards). These guidelines prescribe detailed standards and requirements for compiling ESG reports.

Market changes don't happen automatically. In the transition to a circular economy, we're largely dependent on legislation imposed on us. This isn't surprising: sometimes companies want to become more sustainable, but they don't yet know how to go about it. There's also the fear that they'll accidentally greenwash or pinkwash: portraying themselves as greener or more inclusive than they actually are. Clear regulations, now enshrined in the CSRD, help with this.

The goal is to eventually obtain ESG reporting from all companies, which will prevent greenwashing and hold companies accountable for the impact they have on their stakeholders.

Large companies (with 250 or more employees, more than €40 million in revenue, or a balance sheet total exceeding €20 million) must begin submitting reports for the previous year as early as 2025. They are also required to report on their supply chain. This means that even SMEs supplying such companies must be able to transfer data. Starting in 2026, listed SMEs will also be required to report on their own ESG impact.

An important detail about the CSRD is that it is a European regulation that EU countries must incorporate into national legislation. Although implementation in the Netherlands is not yet final, the rules are already in effect within the EU.

- Dennis Ostendorf, Commercial Director at Milieu Service Nederland

The CSRD sets specific requirements for waste measurements and reporting. The goal is to provide insight into how your organization manages waste and circularity. The most important obligations are listed below:

• Total waste: Indicate how much waste your organization produces (in kilograms).

• Waste within the circular chain: Report how much waste you offer for recycling, reuse or other circular applications.

• Residual waste: Specify the amount of waste that is not reused and is incinerated in the Netherlands.

• Percentage of non-recycled waste: Determine and report the share of waste that is not reused.

This data must also be broken down into hazardous and non-hazardous waste . As your waste partner, we support you in collecting and organizing this data.

There's also a less tangible aspect: how do you calculate the CO₂ emissions of waste in mixed trucks, for example? While sector-specific guidelines are being developed, it's important to formulate an approach and collect data now so you're prepared for stricter regulations in the future. We explain how to do this below.

Ultimately, you'll need to compile an annual report covering all your ESG practices. Because the CSRD doesn't yet prescribe specific targets for circularity and waste management, reporting on your own policies and actions, the targets you set, your figures, and the impact of your choices is sufficient. What should you pay attention to? We'll provide examples from waste management.

1. Does
   your organization already have a policy on environmental and social issues? It's important to develop one.
   For example: your organization might choose source separation instead of post-separation using Multi Waste Containers (MACs).

2. Actions
   : Here, you consider the concrete actions you will take to implement your policy.
   For example, you purchase MACs and an MSG trolley for cleaners to use to weigh waste. You also want to guide your employees in disposing of their waste in the correct bin.

3. Targets:
   To demonstrate that your company is truly taking action, it's essential to define KPIs and attach targets to them. This way, you make the actions you're taking concrete.
   For example: one year after commissioning, you want at least half of your waste to be recycled.

4. Figures:
   Measuring is knowing. You can only achieve your targets if you continuously gather information to ensure complete reporting.
   For example, the figures from the trolley can be used to evaluate the target annually.

5. Impact of choices:
   You must always justify the reasons behind your choice, which may lead to a less favorable outcome.
   For example: to help employees dispose of their waste correctly, you want to provide information about waste bins. You need to weigh this up: you could place a waste coach at each waste bin for a month to explain to users which waste goes in each bin (expected cost: €10,000). An alternative is to hang posters at each bin (expected cost: €200). Although waste coaches can better guide your employees in waste separation, posters were chosen for cost reasons.

The policy has been developed and you've clarified the actions you'll be taking. How will you then measure the figures? For your ESG report, you can make estimates of waste kilograms, provided you can substantiate them. This could be based, for example, on the average weight of a container for a specific waste stream.

However, our recommendation here is not to lag behind. You can still decide for yourself how detailed your reports should be, but experience shows that stricter regulations will follow soon. For advice on waste reporting, you can request a free consultation .

You can immediately start checking how your company is doing with the following topics:

1. What is your policy on waste and circularity? If you haven't yet made decisions on the topics prescribed by the CSRD, it's time to take action.

2. Do you already separate your waste? And can you report the figures? For our clients, the answer to these questions is usually "yes."

Is your answer to any of these questions still unclear? As your waste partner, we can help you comply with the new legislation. This allows you to become a leader in circular business practices, ensuring your business is future-proof. We're also happy to advise you on the possibilities of detailed reporting and the solutions we offer. For example, we can weigh per truck, record per kilo, tip into a compactor, or install a weighbridge in the waste storage area.

A suggestion for facility or property managers, for example, is our MSG trolley , which allows you to measure detailed figures per waste stream per floor or department in a shared building.

Are you an SME? Perhaps you don't separate your waste yet. If you generate more than 240 liters of waste per week, you're legally required to separate your waste streams and send them for recycling. In that case, we can work with you to analyze your waste to determine which streams would be best for you to separate.