The European Union’s Corporate Sustainability Reporting Directive (CSRD) is extending its reach beyond EU borders, with the upcoming European Sustainability Reporting Standards for Third-Country Groups (ESRS-TC) set to impact UK-headquartered businesses. As the regulatory landscape tightens, UK firms operating within the EU must prepare for rigorous new disclosure requirements regarding their environmental footprint, carbon emissions, and circular economy practices.
Under the CSRD, non-EU companies with significant operations in the bloc—specifically those generating a net turnover of over €150 million in the EU for two consecutive years, and having at least one large subsidiary or branch in the region—will be required to report on their sustainability performance. This reporting must align with the ESRS-TC standards, which are designed to ensure that third-country multinationals operate under the same transparency rules as EU-based firms.
For UK waste management companies, packaging converters, and Turkish recyclers, these standards represent a significant shift in data management. UK packaging converters exporting to the EU, or those owned by larger groups, will need to provide granular data on material sourcing, recyclability, and Scope 3 emissions. Similarly, Turkish recyclers supplying the UK and EU markets will face indirect pressure. As UK and EU buyers are forced to audit their supply chains for compliance, they will increasingly demand verified, high-quality data regarding the carbon intensity and recycled content of polymers imported from Türkiye. Failure to provide this data could lock suppliers out of premium supply chains.
To prepare, businesses must audit their corporate structures and EU-derived revenues to determine if and when they fall under the scope of the ESRS-TC. A practical takeaway for operators is to begin aligning their internal data-gathering systems with EU standards now. This means establishing robust mechanisms to track carbon emissions, waste generation, and material circularity, ensuring that sustainability claims are backed by auditable data before the compliance deadlines arrive.
