ESRS E1 and E5 for Manufacturers: Climate and Resource Use Disclosures
ESRS E1 (Climate change) and ESRS E5 (Resource use and circular economy) are the two European Sustainability Reporting Standards most commonly material for manufacturers, covering greenhouse gas emissions across Scopes 1–3, energy consumption, and how physical products and materials flow through the business. For most manufacturers, the underlying data already exists in energy bills, waste logs, and ISO 14001 or ISO 50001 management systems — the real work is consolidating that operational data into the ESRS format, not collecting it from scratch.
If you run a factory, a production line, or a manufacturing group, you have likely already heard the acronym ESRS attached to CSRD compliance conversations. Among the twelve European Sustainability Reporting Standards, two stand out as almost universally relevant to manufacturing: E1 (Climate change) and E5 (Resource use and circular economy). This article explains what each one covers, why manufacturers are particularly exposed to their requirements, and — most importantly — where the data actually comes from.
What ESRS E1 (Climate Change) Covers
ESRS E1 is the standard dealing with a company's contribution to climate change and its exposure to climate-related risks. For a manufacturer, it centres on three interlinked areas:
1. Greenhouse gas emissions across three scopes
E1 asks companies to disclose emissions organised into the widely recognised GHG Protocol scope structure:
- Scope 1 — direct emissions: emissions from sources the company owns or controls directly, such as on-site combustion in furnaces, boilers, or company-owned vehicles.
- Scope 2 — indirect energy emissions: emissions associated with purchased electricity, steam, heating, or cooling consumed on-site.
- Scope 3 — value chain emissions: emissions occurring upstream and downstream of the company's own operations, including purchased raw materials, transportation and logistics, and the use or end-of-life of sold products.
For manufacturers specifically, Scope 3 is typically both the largest emissions category and the hardest to measure. A manufacturer's carbon footprint is often dominated not by its own furnaces or forklifts, but by the raw materials it buys, the components sourced from a multi-tier supplier network, and the freight moving goods between facilities and customers. Mapping and estimating these emissions reliably requires engaging suppliers, many of whom may not yet track or share their own emissions data — which is precisely why Scope 3 is consistently flagged as the most demanding part of climate disclosure for industrial companies.
2. Climate transition plans
E1 also expects companies to describe their approach to managing climate-related risks and opportunities, including any transition plan aimed at aligning the business with a lower-carbon future. For manufacturers, this typically touches on decisions such as electrification of processes, fuel switching, or efficiency investments — described qualitatively and quantitatively as far as the company's actual plans and decisions allow.
3. Energy consumption and energy mix
Finally, E1 covers disclosure of how much energy the company consumes and where it comes from — the split between renewable and non-renewable sources, and consumption intensity relative to output. For energy-intensive manufacturing operations, this is often one of the more straightforward parts of the standard to populate, because the underlying metering and billing data already exists.
What ESRS E5 (Resource Use and Circular Economy) Covers
Where E1 is about emissions and energy, E5 is about materials — and it maps closely onto how manufacturers already think about their processes.
Resource inflows and outflows
E5 asks companies to disclose the resources they draw into their operations — raw materials, water, and other inputs — and the resources that leave, whether as finished product, by-product, or waste. For a manufacturer, this is a natural extension of production and materials-management data that already sits in ERP and MES systems.
Circular economy practices
This includes material reuse, recycling rates, and how waste streams are managed — diverted from landfill, recovered, or reintroduced into production. Companies with an established waste management programme, particularly one certified or structured under ISO 14001, are likely to already generate much of the raw material this section needs.
Product design for circularity
E5 also covers how circularity is considered at the design stage — for example, whether products are designed to be repaired, disassembled, or recycled at end of life. This dimension is directly relevant to manufacturers making physical products, since design choices made years before a product reaches market shape its eventual circularity outcomes.
The Practical Reality: Most of the Data Already Exists
The single most important thing for a manufacturing compliance or sustainability lead to understand is this: ESRS E1 and E5 rarely require collecting entirely new data. They require structuring data that, in most manufacturing operations, is already being generated somewhere in the business:
- Energy consumption records — utility bills, meter readings, and energy audits, especially where an ISO 50001 energy management system is already in place.
- Waste management logs — records typically already maintained under an ISO 14001 environmental management system, covering waste generation, recycling, and disposal routes.
- Procurement and production data — material volumes, supplier lists, and logistics records that feed into both resource-flow disclosures under E5 and Scope 3 estimation under E1.
The disclosure challenge, in other words, is usually one of consolidation and translation — pulling data that lives in separate operational systems, management-system records, and spreadsheets, and mapping it into the structure and terminology ESRS expects. That is a fundamentally different (and more manageable) problem than starting a data-collection programme from zero.
This is where tools that can search across a company's own compliance and quality documentation earn their keep. IgeraIndustria is built for exactly this kind of task: it answers questions directly from a company's own compliance and quality documents — an ISO 14001 waste register, an ISO 50001 energy report, an internal procurement log — citing the exact source document and passage, rather than requiring someone to manually search through years of records to find where a particular figure or policy was last recorded.
Common Mistakes Manufacturers Make
- Treating Scope 3 as optional or "for later." Because it is the hardest category to measure, some manufacturers deprioritise it — but for most manufacturing value chains it is also the largest emissions category, and starting supplier engagement late compounds the difficulty.
- Duplicating data collection instead of reusing existing systems. Launching a brand-new sustainability data-collection exercise when an ISO 14001 or ISO 50001 system is already producing much of the same information wastes effort and creates inconsistent figures.
- Treating E1 and E5 as purely an environmental team task. Both standards need input from operations, procurement, and finance — emissions and resource data cut across departments that do not always share systems or terminology.
- Assuming design-for-circularity has no place in reporting. Product design decisions are explicitly part of E5, yet design teams are often left out of the reporting process entirely.
A Note on Regulatory Uncertainty
The European sustainability reporting framework, including CSRD and the ESRS standards themselves, has been subject to ongoing legislative review and simplification proposals at EU level. Scope, timelines, and specific reporting requirements have been and may continue to be subject to revision. This article describes the conceptual structure of ESRS E1 and E5 as topical standards; it does not state specific reporting thresholds, exact data-point counts, or applicability dates, as these are precisely the elements most likely to change and should always be confirmed against the current, applicable version of the regulation for your company's specific situation.
Frequently Asked Questions
Do all manufacturers need to report under both ESRS E1 and E5?
Whether a specific standard applies to a given company depends on a materiality assessment and the company's applicability under CSRD, which varies by company size, listing status, and other criteria set out in the regulation. E1 and E5 are commonly identified as material for manufacturing businesses because of their direct relevance to production processes, but this should be confirmed on a case-by-case basis with a qualified advisor.
Is Scope 3 always required, or can manufacturers report only Scope 1 and 2?
The scope of emissions reporting required depends on materiality and the specific requirements applicable to the reporting company. Scope 3 is often material for manufacturers given the weight of value chain emissions, but exact requirements should be verified against the current standard and your company's applicability status.
We already have ISO 14001 certification — does that mean we are already ESRS-compliant?
No. ISO 14001 is an environmental management system standard, not a disclosure framework, and it does not automatically satisfy ESRS reporting requirements. However, the data, processes, and records generated under an ISO 14001 system are often directly useful as source material for populating ESRS E5 (and partly E1) disclosures.
How is Scope 3 data actually gathered from suppliers?
Approaches vary and commonly include supplier questionnaires, engagement programmes, and estimation methods based on spend or activity data where primary supplier data is unavailable. The right approach depends on the size and structure of your supply chain and is best defined with guidance from a sustainability reporting specialist.
What is the difference between resource inflows and outflows under E5?
Inflows generally refer to materials and resources the company brings into its operations (raw materials, water, purchased components), while outflows refer to what leaves the operation — finished products, by-products, and waste streams, including how those waste streams are managed or recovered.
Can an ISO 50001 energy management system be used directly for E1 energy disclosures?
Data generated under ISO 50001 — energy consumption records, audits, and efficiency measures — is frequently a strong data source for the energy consumption and mix elements of E1. It still needs to be mapped into the specific structure and definitions used by the ESRS standard rather than submitted as-is.
How can a company start consolidating this data without a large new project?
Most manufacturers benefit from first mapping which operational systems already hold relevant data (energy records, waste logs, procurement data, existing ISO 14001/50001 documentation), then identifying the gaps. Tools that can search and cite directly from existing internal documents, such as IgeraIndustria, can meaningfully reduce the manual effort of that consolidation stage.
Disclaimer
This article is provided for general informational purposes only and does not constitute legal, regulatory, or certification advice. ESRS and CSRD requirements are subject to ongoing regulatory review and may change. Applicability, scope, and specific obligations depend on your company's individual circumstances. Always consult a qualified compliance consultant or lawyer before making decisions related to ESRS or CSRD reporting obligations.
