ESRS E5: What You Need to Report on Waste, Resources and Circularity

Why ESRS E5 Will Redefine Circular Economy Reporting

ESRS E5, the Resource Use and Circular Economy standard under the Corporate Sustainability Reporting Directive (CSRD), is a very cross-cutting environmental disclosures. What makes ESRS E5 complex is that it requires organisations to connect data across procurement, production, and waste-management systems. The circular aspect means companies must trace the full material cycle, from resource inflows to waste outflows, and everything reused, recycled, or recovered in between.

The European Commission’s goal is to help companies quantify how efficiently they use materials, reduce reliance on virgin inputs, and embed circular-economy principles into design, sourcing, and operations.

For enterprises, ESRS E5 is both a challenge and a chance to rethink how they manage resources. It pushes companies to provide verified information on how materials are used and where waste goes — but it also gives them the insight to work more efficiently and make better decisions. With automated tools like geoFluxus, compliance becomes less about reporting and more about understanding how circular a business truly is.

What Is ESRS E5 (and How It Fits Into CSRD)

The Corporate Sustainability Reporting Directive (CSRD) is structured around three themes: Environmental, Social, and Governance. Each is covered by a set of European Sustainability Reporting Standards (ESRS) that define what companies must disclose and how.

• Environmental (E1–E5): climate, pollution, water, biodiversity, and resource use.
• Social (S1–S4): workers, value-chain labour, affected communities, and consumers.
• Governance (G1): business conduct and ethical management.

Within this framework, ESRS E5 focuses on resource use and the circular economy — how efficiently materials are used, reused, and recovered across the value chain. It asks companies to go beyond waste reporting and consider the full material cycle: what enters, what leaves, and what can stay in use longer.

As set out in EFRAG’s publication, ESRS E5 is structured around five Disclosure Requirements that cover both policies and metrics:

1. Policies on resource use and circular design (E5-1)
2. Actions and resources to implement them (E5-2)
3. Targets for improvement (E5-3)
4. Resource inflows such as material inputs (E5-4)
5. Resource outflows including products and waste (E5-5)

There is also clear overlap with ISO 14001. Both frameworks require organisations to identify key environmental aspects, set measurable objectives, and monitor progress on resource efficiency and waste. The difference is that ESRS E5 makes this information public and value-chain-wide, demanding verifiable data rather than internal documentation. For ISO-certified companies, this means extending existing management data into transparent, standardised disclosure.

Why ESRS E5 Can Be Challenging to Implement

For most organisations, the main difficulty with ESRS E5 isn’t understanding the standard — it’s bringing together the right data from the right teams. Each disclosure requirement touches a different part of the organisation: Sustainability defines policies and targets, QHSE tracks waste, Procurement holds supplier data, Operations manages production waste, and Finance validates figures for external reporting.

These teams often work in different systems, on different schedules, and with different priorities. Waste data may sit in a local spreadsheet, supplier data in a procurement platform, and material KPIs in a sustainability dashboard — making it difficult to build one consistent, audit-ready view across all five ESRS E5 areas.

Global operations add another layer of complexity. Some countries have digital waste registries and well-defined reporting codes, while others still rely on manual paperwork or inconsistent classifications. As a result, QHSE and Sustainability teams can spend weeks reconciling partial or incompatible data before it can be used for CSRD disclosure.

👉 With automated waste-data verification for E5-5, geoFluxus standardises reporting across countries and contractors — freeing resources to drive the circular improvements defined in E5-1 and E5-2.

The Five Disclosure Requirements Under ESRS E5

The Amended ESRS E5 Exposure Draft (July 2025) defines five Disclosure Requirements (E5-1 to E5-5) for how companies report on resource use and circular economy performance.

E5-1 Policies related to resource use and circular economy

This section requires two main disclosures:

1. The company shall report on its resource use and circular economy policies.
2. If circularity or eco-design principles are integrated into its key products and services, the company shall explain how this is done.

In practice, this means describing formal policies that guide how resources are sourced, used, and designed for reuse — for example, including eco-design standards in product development, supplier requirements, or procurement criteria.

E5-2 Actions and resources related to resource use and circular economy

This section requires the company to disclose its resource use and circular economy actions in accordance with the provisions of [Draft] Amended ESRS 2 GDR-A.

The GDR-A (paragraphs 36–38) defines that the company must describe:

• the key actions taken during the reporting year and planned for the future, including their scope and timeframe;
• the expected outcomes of these actions, and how they contribute to achieving the objectives of the related policy;
• the financial and other resources (operational and/or capital expenditure) allocated to implementing those actions, including where these amounts appear in the financial statements; and the future range of financial resources expected to be allocated.

For example, reporting may include investments in waste-sorting infrastructure, partnerships with recycling firms, or training programmes for staff on material segregation.

E5-3 Targets related to resource use and circular economy

This section requires the company to disclose its resource use and circular economy targets, in accordance with ESRS 2 GDR-T.

According to GDR-T (paragraphs 43–45), the company must provide information that allows users to understand:

• the objectives and timeframe of each target;
• the metrics or indicators used to measure progress;
• the base year and progress achieved since that base year;
• whether the target is mandatory (set by law) or voluntary;
• how the target links to related policies and actions; and
• if applicable, the financial or operational resources supporting achievement of the target.

In practice, this means defining measurable, time-bound goals connected to the company’s resource-use and circular-economy strategy — such as reducing total waste generation, increasing the proportion of secondary or recycled materials used, or improving product reparability within a defined timeframe — and reporting progress against those goals using consistent, verifiable data.

E5-4 Resource inflows

This section requires the company to report information that provides an understanding of its resource inflows, focusing on the types and quantities of materials entering the organisation and their degree of circularity.

When resource inflows are assessed as a material topic, the company shall disclose the following:

• (a) the key materials used to manufacture products, deliver them and/or provide services;
• (b) the total weight of key materials, with a breakdown per key material (in weight or percentage of total weight);
• (c) the percentage of total weight of critical and strategic raw materials;
• (d) the percentage of total weight of secondary resourced materials;
• (e) the percentage of total weight of key biological materials that are sustainably sourced.

Application requirements clarify that the percentage calculations are based on the total weight of all key materials used during the reporting period, and that biological materials are assessed against the total weight of biological inputs.

In practice, this means the company must quantify the material composition of its operations—identifying which inputs are virgin, recycled, or renewable—and express them as percentages of total material use. Procurement data, supplier declarations, and sustainability certifications (for example, proof of recycled or sustainably sourced content) form the evidential basis for this disclosure.

E5-5 Resource outflowsE5-5 Resource outflows

This section requires the company to report information that provides an understanding of how it implements the circular-economy principles in the design, manufacture, and provision of goods and services, and how it manages the waste resulting from its own operations.

Products and services

The company shall disclose:

• (a) information on the expected durability of its key products;
• (b) information on the scope of reparability of its key products;
• (c) the rate of recyclable materials included in its key products and in their packaging;
• (d) the rate of recycled materials used in its key products.

In practice, this means providing quantitative or descriptive data on product lifespans, repair options, and recycled or recyclable content — information often derived from product-design documentation, supplier specifications, or life-cycle assessments.

Waste

The company shall disclose the following information on waste from its own operations:

• (a) a description of the waste streams relevant to its sector or activities;
• (b) the total weight of waste generated;
• (c) the percentage and/or total weight diverted from disposal, with a breakdown between hazardous and non-hazardous waste and by recovery operation type (preparations for reuse, recycling, other recovery);
• (d) the percentage and/or total weight directed to disposal, with a breakdown between hazardous and non-hazardous waste and by disposal operation type (thermal-based disposal, landfill, other disposal);
• (e) the percentage and/or total weight for which the final destination is unknown;
• (f) if the company generates radioactive waste, the total amount shall be disclosed in accordance with Article 3(7) of Council Directive 2011/70/Euratom.

In practice, this requires verified weight data for all waste streams, broken down by treatment and hazard category. Data sources typically include manifests, processor certificates, and national waste-tracking systems.

Key Metrics and KPIs to Track for ESRS E5 Reporting

ESRS E5 does not introduce additional KPIs beyond those already required under E5-3, E5-4, and E5-5.
The quantitative data focus on three main areas:

• Material inputs (E5-4): total weight of key materials and the share of critical, secondary, or sustainably sourced inputs.
• Material outputs (E5-5): product durability, reparability, rate of recyclable materials in key products and packaging, rate of recycled materials in key products, and waste streams by material and processing method.
• Targets and progress (E5-3): measurable, time-bound objectives linked to those same indicators.

Together, these numbers show how efficiently a company uses resources and how circular its operations are. They rely on verified procurement, production, and waste data, rather than estimates.

👉 geoFluxus helps standardise and verify these datasets, turning them into audit-ready metrics for CSRD submission.

How to Prepare for ESRS E5 Compliance

Preparing for ESRS E5 means building a clear and verifiable picture of how materials enter, move through, and leave the organisation. Most companies can follow four main steps to structure this process.

1. Conduct a materiality assessment

Start by identifying which resource and waste flows are truly material to your company.
A materiality assessment helps determine where your business has a significant contribution to, or dependency on, a sustainability topic — and where those topics, in turn, create risks or opportunities for you. Under CSRD, both sides are assessed:

• Impact materiality: Do we as a company have a significant contribution to or dependency on this topic?
• Financial materiality: Could this topic significantly affect our business results, costs, or resilience?

For ESRS E5, this means examining your activities, supply chain, and products to decide whether resource use and circular economy are material. If they are, you must report under E5-1 to E5-5.

2. Map and verify data sources

Once you know that ESRS E5 is material, the next step is to identify where the data for each disclosure comes from and ensure it can be verified. This means tracing information across procurement, operations, and waste management systems to build a single, consistent record of how materials enter and leave the organisation.

Key actions include:

• listing all data sources for material inflows (E5-4) and outflows (E5-5);
• checking that measurement units, time periods, and classifications are consistent;
• confirming that supporting evidence exists, such as supplier declarations, manifests, or processor certificates.

3. Define circularity targets and actions

Once the data is mapped and verified, the next step is to set specific targets and describe the actions that will help achieve them. Under ESRS E5, this connects the company’s strategy and policies (E5-1) with measurable goals (E5-3) and the actions disclosed under (E5-2).

Targets must be quantifiable and time-bound, and they should relate directly to the company’s material resource and waste topics.
Examples include:

• reducing total waste generated by a set percentage by a certain year;
• increasing the share of secondary or recycled materials in production; or
• improving product reparability and durability within a specific timeframe.

Actions describe how these goals will be achieved — for example, through procurement criteria that favour recycled content, investments in recovery systems, or collaborations with recyclers and suppliers.

4. Automate and standardise reporting

Once targets and actions are in place, the final step is to collect, verify, and report data in a consistent format that aligns with CSRD and the ESRS structure. Because ESRS E5 data comes from multiple departments and sites, manual collection quickly becomes time-consuming and error-prone.

Automation and standardisation help ensure:

• all resource and waste data use the same units, timeframes, and material classifications;
• supporting evidence (invoices, manifests, certificates) is linked directly to each reported figure;
• updates can be made continuously instead of only once per year.

With geoFluxus, the hours once spent collecting and checking waste data shrink to minutes. The platform automatically verifies information, organises it under the ESRS E5 framework, and delivers reports that are ready for CSRD submission.

How geoFluxus Simplifies ESRS E5 Reporting

With geoFluxus, the hours once spent collecting and checking waste data shrink to minutes. The platform automatically verifies information, organises it under the ESRS E5-5 framework, and delivers the required figures — ready for CSRD submission.

All waste streams are linked to their processor, treatment method, and destination, then translated into material categories. This allows you to truly understand your waste — not just report the final number. More importantly, due to the materials translation of waste, it helps connect your E5-5 (waste outflows) to E5-4 (resource inflows) and see how materials circulate through the business.

Within the platform, companies can also define and monitor E5-3 targets related to waste — tracking verified data on recycling, landfill, incineration, and separation. The Goals dashboard provides a clear view of progress over time.

Beyond delivering the numbers, our 10+ years of waste and circularity expertise help organisations define E5-1 policies and E5-2 actions that create the biggest impact — focusing efforts where waste reduction and circular improvements matter most.

Ready to cut weeks of manual work down to just a few minutes?
Start simplifying your ESRS E5 reporting with geoFluxus.

Common Pitfalls to Avoid in ESRS E5 Reporting

Even with clear requirements, ESRS E5 can be challenging to apply in practice. The biggest issues usually appear when waste data is inconsistent, incomplete, or only collected for compliance purposes.

1. Inconsistent reporting across countries
Different languages, waste codes, and classifications make it hard to consolidate data across regions. Even the naming of processing or treatment methods can vary, leading to mismatched categories and unreliable totals.

2. Relying only on invoices for waste data
Invoices are useful for tracking costs but rarely include the full information needed for ESRS E5. Verified reporting requires supporting evidence — such as entries from national registries, processor documentation, or bills of lading — to prove where and how waste was treated.

3. Focusing just on totals
Waste totals alone don’t say much. Important insights and improvement opportunities often hide behind those high-level numbers. When you’ve already invested effort to collect the data, taking a small extra step to analyse by material, process, or site can unlock real circular progress.

Conclusion

ESRS E5 marks a turning point in how companies report on waste and resource use.
It moves sustainability reporting from isolated waste figures to a connected view of how materials are used, recovered, and kept in circulation.

Meeting the standard takes effort — especially in collecting verified data across sites, suppliers, and countries — but it also creates value. Companies that build reliable waste data foundations gain not just compliance, but insight: they can see where resources are lost, where recovery adds value, and where circular improvements make the biggest difference.

Done well, ESRS E5 turns reporting from an administrative task into a tool for better resource management and measurable circular progress.

👉 Book a demo to see how geoFluxus automates ESRS E5 reporting with verified waste and resource data.

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FAQs

What is ESRS E5?
It’s the European Sustainability Reporting Standard on Resource Use and Circular Economy, developed under the Corporate Sustainability Reporting Directive (CSRD) which is a part of the EU Green Deal.
The standard requires companies to disclose how they use materials, manage waste, and apply circular economy practices across the entire value chain to enhance sustainability and reduce environmental impacts.

What data is required under ESRS E5?
Companies must collect and verify quantitative data on resource inflows (materials used) and resource outflows (products and waste), along with targets related to their circular strategy.
Required information includes:

• the total weight and composition of key materials, including recycled materials and recycled content;
• how waste is treated and recovered; and
• the policies, circular economy initiatives, and resources allocated to improve material efficiency.
  This data helps assess material resource use, resource depletion, and related financial effects under the ESRS standards.

How does ESRS E5 link to circular economy principles?
ESRS E5 measures how effectively materials are kept in circulation through circular business models, take-back schemes, and sustainable products. It aligns CSRD reporting with the EU Circular Economy Action Plan — a key pillar of the European Green Deal — and focuses on improving resource efficiency and circular economy practices across the value chain.

How can companies verify waste and resource data?
Verification involves reliable data collection and linking reported figures to supporting documentation such as invoices, manifests, processor certificates, and government registries. This ensures that reported waste and material data is deemed material, traceable, and auditable — essential for demonstrating CSRD compliance and understanding circular economy related impacts across operations. Platforms like geoFluxus automate this process — ensuring each dataset is complete, traceable, and audit-ready.

How does geoFluxus support ESRS E5 compliance?
geoFluxus simplifies ESRS E5 reporting by automating waste-data verification for E5-5 (resource outflows) and linking those verified datasets to company targets under E5-3. The platform standardises data across sites, contractors, and countries — connecting waste records to processors, treatment methods, and material categories. This provides a complete, traceable view of waste, helping companies meet CSRD and ESRS standards efficiently and consistently.

What is a double materiality assessment?
A double materiality assessment helps companies determine which environmental and financial impacts are most relevant to disclose.
It looks at:

• Impact materiality: how the company contributes to or depends on topics such as resource use, climate change, and biodiversity loss;
• Financial materiality: how these issues create material risks, affect cash flows, or have anticipated financial effects on business performance.
  Under EU law, companies must report on topics that are material in either sense, or both, ensuring transparency on material impacts and financial impact alike.

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