CSRD reporting for merch procurement teams

What it requires

• Double materiality assessment (impact + financial materiality) covering merch category
• ESRS E1 (climate change): Scope 3 emissions per ISO 14064 / GHG Protocol
• ESRS E5 (resource use & circular economy): material flows for merch items
• ESRS S2 (workers in the value chain): supplier labour standards disclosure
• ESRS G1 (business conduct): anti-corruption + bribery in supplier contracts
• Limited assurance from a registered auditor (moving to reasonable assurance by 2028)
• XBRL-tagged digital reporting submitted to the European Single Access Point

How it impacts merch programs

• Each merch SKU needs a product carbon footprint (PCF) per ISO 14067
• Supplier list needs full-tier disclosure (Tier 1, 2, 3 manufacturers)
• End-of-life data: what % of merch is recyclable, compostable, landfill-bound
• Take-back / circular-economy programs strengthen ESRS E5 disclosure
• Anti-bribery clauses required in all supplier contracts (ESRS G1)
• Worker-grievance mechanism disclosure for supply-chain workers

Documentation packet — what suppliers must provide

1. ISO 14064 / GHG Protocol Scope 1+2 inventory from supplier
2. Product-level carbon footprints (ISO 14067) per SKU
3. EcoVadis Silver+ or Sedex SMETA 4-pillar audit report
4. Material declarations (cotton, PET, etc.) with origin tracing
5. Living-wage attestation (BSCI / SA8000 / FLA)
6. Anti-corruption policy + training records from supplier
7. Annual sustainability report aligned to GRI or ESRS
8. Full Tier-2 / Tier-3 sub-supplier mapping

Decision tree — when does this framework apply?

• Is your group a large undertaking (>250 employees, >EUR 50M turnover)? CSRD applies
• Do you exceed two of three thresholds: assets, turnover, employees? Group level
• Are you listed on EU-regulated market? Earlier phase-in
• Is merch material to your stakeholders' decisions? Drives disclosure depth

Penalties for non-compliance

• National-level fines per Member State implementing law (often 1-10% turnover)
• Director liability for false or misleading disclosures
• Loss of access to EU green-finance / sustainability-linked loans
• Public listing on non-compliance registers in some Member States

How we help

• Per-SKU product carbon footprint (ISO 14067) at no charge above 2 000 units
• Annual GHG Scope 3 data pack aligned to GHG Protocol Cat-1 (Purchased goods)
• EcoVadis Silver+ rating refreshed annually with shared scorecard access
• Tier-2 fabric mill + Tier-3 fibre origin disclosure on request
• Take-back program with circularity reporting for ESRS E5
• Pre-formatted XBRL-ready data extract for your auditor

Related frameworks

• Cbam Carbon Border
• Reach Svhc Merch
• Modern Slavery Acts

Related resources

• Glossary of compliance terms
• Material catalogue
• Sustainability report 2026
• Data Processing Addendum
• Whitepapers and reports

Frequently asked questions

Is merch material to CSRD?

Its part of Scope 3 Cat-1 (Purchased goods) and Cat-12 (End-of-life): small per-SKU but cumulative; double-materiality test decides depth.

Do we need ISO 14067 PCFs?

Either ISO 14067 product-level or activity-based emissions; ISO 14067 is preferred for limited-assurance audits.

Does our supplier need EcoVadis?

Not strictly: but EcoVadis Silver+ or Sedex SMETA are the most efficient way to evidence ESRS S2 disclosures.

What about Tier-2 + Tier-3 mapping?

ESRS S2 expects reasonable visibility of value-chain workers: we provide Tier-2 mill + Tier-3 fibre origin on request.

Limited or reasonable assurance?

Limited assurance from FY 2024; reasonable assurance from FY 2028. Plan data quality accordingly.