The first wave of mandatory filings under the European Union's Corporate Sustainability Reporting Directive, covering the 2024 fiscal year for companies already subject to the Non-Financial Reporting Directive, is revealing the depth of data gaps that persist in corporate plastic measurement and setting the stage for a significant expansion in demand for plastic footprint accounting services and, ultimately, plastic credits.
Approximately 11,700 large companies are required to file CSRD-compliant sustainability reports for the 2024 fiscal year, ahead of the broader rollout that will eventually encompass more than 50,000 entities across the European Economic Area. Those reports must comply with the European Sustainability Reporting Standards, and in particular ESRS E5, which addresses resource use and the circular economy. ESRS E5 requires companies to disclose material flows of plastic packaging and products across their value chain, including for the first time Scope 3 upstream and downstream plastic use embedded in third-party products and services.
The practical challenge is formidable. Unlike Scope 1 and Scope 2 greenhouse gas emissions, where established protocols and utility-level data support reasonably accurate measurement, Scope 3 plastic data does not exist as a standardised category in most corporate enterprise resource planning systems. The vast majority of first-cycle filers are relying on estimation methodologies rather than primary measurement, a fact noted with concern in a guidance note published by the European Financial Reporting Advisory Group (EFRAG) in November 2024.
The two most common proxy approaches are spend-based estimation, in which companies apply industry-average plastic intensity coefficients to procurement spend by category, and Bill of Materials extrapolation, in which product-level material data is scaled across sales volumes. Both introduce substantial uncertainty ranges. EFRAG's guidance note observed that spend-based plastic estimates for consumer goods companies can carry uncertainty bands of 40 to 60 percent, a range that renders the figures of limited analytical value for investment or policy purposes.
Major audit firms have been candid about the limitations. EY and Deloitte have each issued internal guidance to their sustainability assurance practices warning that plastic footprint disclosures are likely to attract qualified or emphasis-of-matter opinions in the first reporting cycle, given the material uncertainty inherent in estimation-based approaches. We are seeing clients present numbers with a precision that the underlying methodology does not support, a senior Deloitte sustainability partner noted at a roundtable in Brussels in January 2025.
Several of Europe's largest consumer goods companies have nonetheless published Scope 3 plastic estimates as part of their CSRD filings. Unilever disclosed a total plastic footprint of approximately 700,000 tonnes for its 2024 operations, of which roughly 60 percent relates to packaging purchased from third-party suppliers. Nestle reported an estimated 1.2 million tonnes of plastic used across its supply chain. AB InBev quantified its Scope 3 plastic intensity at 4.2 grams of plastic per litre of beverage produced.
For the plastic credits market, CSRD creates a powerful structural catalyst. Credible measurement is the necessary precondition for responsible credit purchasing: a company cannot plausibly claim to be offsetting its plastic footprint if it cannot quantify that footprint with reasonable confidence. As data quality improves through successive reporting cycles, driven by auditor pressure, investor scrutiny, and the maturation of plastic accounting software, demand for plastic credits as a residual-footprint management tool is expected to grow in parallel.