CSRD and ESPR Overlap: What EU Manufacturers Must Disclose About Their Supply Chains

Two Regulations, One Supply Chain

EU manufacturers face supply chain transparency requirements from two directions at once. Directive (EU) 2022/2464 (the CSRD) requires qualifying companies to report sustainability information, including due diligence processes and principal risks, in a dedicated section of the management report under Article 19a(1) and (2)(f) and (g) of Directive 2013/34/EU. The Regulation (EU) 2024/1781 (ESPR) and the Battery Regulation, Regulation (EU) 2023/1542, require product-level data to travel with the product through a Digital Product Passport. The CSRD and ESPR overlap is real, but the two sets of obligations are not identical. Understanding where they share source data, and where they diverge, determines how much duplicate work your team does.

Who Must Comply and When

The CSRD scope has changed. Directive (EU) 2026/470 narrowed the rules. For financial years starting between 1 January 2024 and 31 December 2026, large public-interest entities with more than 500 employees report under Article 5(2) of Directive (EU) 2022/2464. Member States may exempt those below the new thresholds for financial years 2025 and 2026. From financial years starting on or after 1 January 2027, the scope covers undertakings, and parent undertakings of groups on a consolidated basis, that exceed both EUR 450 million net turnover and 1,000 employees. Directive (EU) 2026/470 also removed listed SMEs from scope and must be transposed by 19 March 2027. From financial years starting on or after 1 January 2028, Article 40a of Directive 2013/34/EU requires certain subsidiaries and branches in the EU of third-country undertakings to publish a sustainability report.

Battery passport duties under Article 77 of Regulation (EU) 2023/1542 carry no size exemption. Any manufacturer placing a battery in scope on the EU market must comply, regardless of turnover or headcount. The battery due diligence chapter is different: Article 47 excludes operators with net turnover below EUR 40 million in the financial year preceding the last financial year that are not part of a group exceeding that limit on a consolidated basis, and the due diligence obligations in Article 48(1) apply from 18 August 2027. For products under the ESPR Regulation 2024/1781, passport duties come from each delegated act for the relevant product group, and the ESPR provisions on disclosing unsold consumer products and the destruction ban do not apply to micro and small enterprises under Articles 24(1) and 25(1).

Where the CSRD and ESPR Overlap on Supply Chain Data

Both regimes pull data from the same upstream source: your suppliers. The CSRD requires disclosure of due diligence processes and principal sustainability risks under Article 19a(2)(f) and (g) of Directive 2013/34/EU. Where climate change is assessed as material, ESRS disclosure requirement E1-6 requires Scope 3 emissions, including category 1 (purchased goods and services), following the materiality assessment process in ESRS 1, paragraphs 29 to 32. That means collecting emissions data from suppliers.

Battery passports require responsible sourcing information. Annex XIII, point 1(d) of Regulation (EU) 2023/1542 requires the passport to include information on responsible sourcing as indicated in the report on battery due diligence policy referred to in Article 52(3). Operators within the scope of Article 47 must produce that report once Article 48(1) applies, from 18 August 2027. The underlying supplier audit data, conflict mineral checks, and human rights assessments that feed the Article 52(3) report are the same categories of information that a CSRD reporter needs for its due diligence disclosure under ESRS S1 to S4 and G1.

This is the practical overlap. A manufacturer producing EV batteries and reporting under the CSRD is collecting supplier-level data for two purposes simultaneously. The data does not need to be collected twice. What differs is the form in which it is disclosed and the level of granularity required for each purpose.

Where the Two Regimes Diverge

The form of disclosure is fundamentally different. CSRD sustainability information sits in a dedicated section of the management report. It follows the European Sustainability Reporting Standards (ESRS 1 and 2, plus topical standards E1 to E5, S1 to S4 and G1). It must be prepared in the single electronic reporting format, with digital tagging required once the tagging rules are adopted, under Article 19a(1) and Article 29d of Directive 2013/34/EU. This is a company-level report, published annually.

A Digital Product Passport is product-level data. It connects through a data carrier to a persistent unique product identifier. ESPR Article 10(1)(a) and (d) of Regulation (EU) 2024/1781 require passport data to be machine-readable as appropriate. Article 77(5) of Regulation (EU) 2023/1542 requires battery passport information to be machine-readable. The passport travels with the product and is updated throughout the product lifecycle. It is not a report; it is a live data record.

Carbon footprint is a clear example of where the data overlaps but the rules do not. Supplier emissions data gathered for ESRS E1-6 Scope 3 category 1 can be a starting point for battery carbon footprint work, but it does not by itself meet the battery carbon footprint rules. The battery carbon footprint declaration is made for each battery model per manufacturing plant under Article 7(1) of Regulation (EU) 2023/1542. Annex II, point 5 requires activity data for the anode, cathode, electrolyte, separator and cell casing that refer to that specific model and plant, with no default activity data permitted, combined with PEF-compliant secondary datasets. A company-level Scope 3 figure is too aggregated to satisfy that requirement. For products under ESPR, any carbon footprint information requirement is set in the relevant delegated act under ESPR Article 7(2)(b)(i) of Regulation (EU) 2024/1781.

ESPR Article 9 does not itself require supply chain data in a product passport. Any such data comes from the delegated act for that product group, under Article 9(2)(a) and Annex III of Regulation (EU) 2024/1781. Manufacturers should check the specific delegated act for their product group rather than assuming ESPR automatically requires supply chain disclosure at product level.

Building a Shared Data Collection Layer

The practical answer to managing both obligations is to collect supplier data once and map it to both sets of fields. This means building a shared data collection layer that serves CSRD ESRS fields and DPP passport fields from the same source records.

Start with supplier onboarding. When you request data from a tier-1 supplier, ask for the fields that both regimes need: emissions by activity, sourcing origin, audit status, and human rights due diligence records. Tag each data point at collection with the regulatory field it satisfies. A cobalt sourcing audit record, for example, maps to the Article 52(3) due diligence report for the battery passport and to ESRS S3 (affected communities) for the CSRD report.

Maintain the distinction between company-level aggregates and model-level activity data. Your CSRD Scope 3 category 1 figure is an aggregate across all purchased goods. Your battery carbon footprint calculation under Annex II, point 5 requires model-specific and plant-specific activity data for named battery components. These are related but separate datasets. Store them separately and link them by supplier and material, not by merging them into a single figure.

Check the access rules for each disclosure. CSRD sustainability information is public, in the management report. Battery passport data under Annex XIII of Regulation (EU) 2023/1542 has differentiated access: point 1 data is accessible to the public, while point 2 data is accessible only to persons with a legitimate interest and the Commission, and point 3 data is accessible only to notified bodies, market surveillance authorities and the Commission. Responsible sourcing information under Annex XIII, point 1(d) is in the public tier. Some commercially sensitive supplier data may sit in point 2 or point 3 and need not be disclosed publicly, even though the underlying audit process feeds both the passport and the CSRD report.

Size Thresholds Create Asymmetric Obligations

A mid-sized battery manufacturer with EUR 200 million turnover and 600 employees falls below the CSRD threshold from 1 January 2027 (EUR 450 million and 1,000 employees, both required). That company is not required to publish a CSRD sustainability report for financial years starting on or after that date. But if it places EV batteries on the EU market, it must still comply with Article 77 of Regulation (EU) 2023/1542, because the battery passport has no size exemption. It must also comply with the due diligence obligations under Article 48(1) from 18 August 2027, unless its net turnover in the financial year preceding the last financial year is below EUR 40 million and it is not part of a group exceeding that limit under Article 47.

This asymmetry matters for planning. Smaller manufacturers may escape CSRD reporting but still face product-level passport obligations. They should not assume that falling below the CSRD threshold removes all supply chain transparency requirements. The passport obligations are tied to the product, not the company’s size (with the limited Article 47 exception for due diligence).

Practical Steps for Compliance Managers

1. Confirm whether your company meets the CSRD thresholds for the relevant financial year, using the rules in Article 5(2) of Directive (EU) 2022/2464 as amended by Directive (EU) 2026/470.
2. Identify which product groups you manufacture and check whether a delegated act under ESPR Article 9(2)(a) has been adopted for those groups, and what supply chain data it requires in the passport.
3. For batteries, map your data collection to Annex XIII of Regulation (EU) 2023/1542, noting which points are public and which are restricted, and prepare for the Article 48(1) due diligence obligations from 18 August 2027.
4. Separate your company-level Scope 3 aggregate from your model-level and plant-level activity data for carbon footprint purposes, as Annex II, point 5 of Regulation (EU) 2023/1542 requires the latter with no defaults permitted.
5. Design supplier questionnaires that capture fields for both ESRS topical standards and DPP passport fields in a single request, then tag responses to the correct regulatory destination.
6. Check the CSRD tagging requirements under Article 29d of Directive 2013/34/EU once the single electronic reporting format rules are finalised, and ensure your reporting system can produce tagged output.

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