Our sustainability report needs product compliance data

Sustainability reporting sits in the Accounting Directive, Directive 2013/34/EU, as amended by the Corporate Sustainability Reporting Directive and, in February 2026, by Directive (EU) 2026/470. The directive is addressed to Member States and applies through national law. In the consolidated text of 18 March 2026, Article 19a(1) requires undertakings that exceed a net turnover of EUR 450 million and an average of 1 000 employees to include in the management report the information needed to understand their impacts on sustainability matters and how sustainability matters affect them. Member States must transpose the 2026 amendments by 19 March 2027 (Directive (EU) 2026/470 Article 5(1)), and apply the new thresholds for financial years starting on or after 1 January 2027 (Directive (EU) 2022/2464 Article 5(2), as amended).^[1][2]

The content list in Article 19a(2) reaches into products. It covers the business model and strategy, time-bound targets, policies, the due diligence process, the principal actual or potential adverse impacts connected with the undertaking's own operations and its value chain, including its products and services, its business relationships and its supply chain, and indicators for these. Article 19a(3) adds that the information covers the value chain where applicable.^[1]

The 2026 amendment also set a value chain cap. A protected undertaking, with up to 1 000 employees and in the value chain of a reporting undertaking, may decline to provide information that exceeds the voluntary standards; the reporting undertaking may rely on its self-declaration and must tell it which requests go beyond the standards (Article 19a(3)). The standards were set by Commission Delegated Regulation (EU) 2026/1560, whose Article 3 on the cap applies from financial years beginning on or after 1 January 2027.^[1][5]

Product laws add their own disclosures that can be placed in the report. Under the Ecodesign for Sustainable Products Regulation, economic operators that discard unsold consumer products disclose yearly the number and weight per category, the reasons, the share sent to reuse, recycling, recovery or disposal, and their prevention measures, and those subject to sustainability reporting may include this there (Regulation (EU) 2024/1781 Article 24(1)). From 19 July 2026, large enterprises may not destroy the unsold apparel, clothing accessories and footwear listed in Annex VII (Article 25(1)), except under the derogations in Commission Delegated Regulation (EU) 2026/296.^[3][6]

Under the EU Deforestation Regulation, operators that are not SMEs report publicly every year on their due diligence system and may do so in reporting under other Union value chain due diligence acts (Regulation (EU) 2023/1115 Article 12(3)).^[4]