Since Omnibus I entered into force on 18 March 2026, the CSRD applies to EU companies with more than 1,000 employees and more than EUR 450 million net turnover. Product data still matters: Scope 3 emissions, substances of concern and circular economy metrics in the ESRS depend on material, weight and composition data held across PLM, ERP and PIM.
The Corporate Sustainability Reporting Directive (CSRD) requires large companies to disclose sustainability information under the European Sustainability Reporting Standards (ESRS), and a significant share of those disclosures depends on product-level data. Since the Omnibus I Directive (Directive (EU) 2026/470) entered into force on 18 March 2026, the CSRD applies only to companies with more than 1,000 employees and more than €450 million net turnover. Suppliers below those thresholds still receive data requests, now limited by a value chain cap.
What changed in the CSRD after the Omnibus simplification
Omnibus I was published in the Official Journal on 26 February 2026, and Member States must transpose the CSRD changes by 19 March 2027. The table summarises the changes most relevant to product data teams.
| Element | Original CSRD | After Omnibus I |
|---|---|---|
| EU scope | Over 250 employees plus turnover or balance sheet criteria | Over 1,000 employees and over €450 million net turnover |
| Listed SMEs | In scope from financial year 2028 | Removed from scope |
| Non-EU groups | Over €150 million EU turnover | Over €450 million EU turnover, plus EU subsidiary or branch over €200 million |
| Sector-specific ESRS | Required | Requirement deleted |
| Assurance | Limited, with planned move to reasonable | Limited assurance only |
| Value chain requests | No explicit cap | Capped at the voluntary standard for companies with 1,000 or fewer employees |
Timing follows the stop-the-clock Directive (EU) 2025/794. Wave 2 companies that remain in scope report in 2028 on financial year 2027, and non-EU groups report in 2029 on financial year 2028. Member States may exempt wave 1 companies that fall below the new thresholds for financial years 2025 and 2026.
How the revised ESRS change data requests
The ESRS themselves have been simplified. EFRAG submitted technical advice on 3 December 2025 that cut mandatory datapoints by 61% (where material). The European Commission adopted the delegated act on the revised ESRS on 3 July 2026, together with a Voluntary Sustainability Reporting Standard (VS) for undertakings with 1,000 or fewer employees, based on EFRAG's VSME. The revised ESRS apply to financial years beginning on or after 1 January 2027, after scrutiny by Parliament and Council and publication in the Official Journal, with early application permitted for 2026.
For product data teams, fewer datapoints means fewer but more focused requests. The topics that rely on product information remain.
Which ESRS topics depend on product data
Several topical standards draw directly on attributes that typically sit in PLM, ERP or PIM:
- ESRS E1 (climate change): Scope 3 emissions from purchased goods (category 1) and use of sold products (category 11) need material weights, bills of materials and use-phase energy consumption.
- ESRS E2 (pollution): disclosures on substances of concern and substances of very high concern require composition data per product.
- ESRS E5 (resource use and circular economy): resource inflows and outflows rely on recycled content, durability, repairability and packaging material data.
- ESRS S4 (consumers and end-users): product safety and information practices draw on labelling and safety content.
Reporting is at company level, so product data is aggregated. Aggregation only works when each product record holds consistent units, methods and reference years.
Where product sustainability data should live
No single system covers the full chain. PLM holds design-stage composition and ecodesign data, ERP holds volumes sold and purchased, and PIM holds the validated, customer-facing version of sustainability attributes. A pragmatic model assigns each attribute one system of record and one owner, documented in a product data governance framework.
The same attributes feed other regulations. Recycled content, material composition and substance flags are also required for the digital product passport under ESPR and for PPWR packaging data. Modelling them once, with methodology and evidence fields, removes the need for a separate dataset per regulation. For a dedicated PLM vendor comparison, see PLM Vendors.
How suppliers below the thresholds should respond
Manufacturers and wholesalers with 1,000 or fewer employees can decline requests that go beyond the voluntary standard, contract clauses that conflict with the cap are not binding, and customers may rely on self-declarations. In practice, large retailers and brands still ask for product carbon footprints, recycled content and substance data, because those figures feed their own ESRS E1 and E5 disclosures and other regulatory obligations. A standard supplier data pack aligned with the VS standard keeps responses consistent across customers.
Practical next steps
- Confirm whether the company, its customers and its parent group fall inside the new thresholds.
- Map ESRS E1, E2 and E5 datapoints that require product-level input.
- Add sustainability attributes to the PIM data model with unit, method, reference year and evidence fields.
- Assign a system of record and owner for each attribute across PLM, ERP and PIM.
- Prepare a reusable supplier data pack aligned with the voluntary standard.
- Align the work with DPP and PPWR programmes to reuse the same data.
Frequently asked questions
Who is in scope of the CSRD after the Omnibus simplification?
EU undertakings and groups with more than 1,000 employees and more than EUR 450 million net turnover, plus non-EU groups with more than EUR 450 million EU turnover and an EU subsidiary or branch above EUR 200 million. Listed SMEs are no longer in scope.
When do wave 2 companies first report under the CSRD?
Following the stop-the-clock Directive (EU) 2025/794, wave 2 companies that remain in scope report in 2028 on financial year 2027 data. Non-EU groups report in 2029 on financial year 2028.
Do suppliers below the CSRD thresholds still need product sustainability data?
Yes, in practice. Customers in scope still request data, although the value chain cap allows companies with 1,000 or fewer employees to decline requests beyond the voluntary standard. Other rules such as ESPR, PPWR and the battery regulation also require product-level data.