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In 2026 sustainability reporting has become a core requirement for many companies in the German waste paper and recycling industry. The Corporate Sustainability Reporting Directive (CSRD) significantly expands who must report and what must be disclosed.
For recyclers, this means moving from voluntary sustainability statements to structured, auditable ESG reporting.
CSRD increases the number of companies required to report sustainability information from around 12 000 to nearly 50 000 across the EU. In Germany this includes many medium and large recycling companies that meet at least two of the following thresholds: more than 250 employees, over €40 million in turnover, or more than €20 million in total assets.
Reports must follow the European Sustainability Reporting Standards (ESRS) and be published alongside financial statements. This places sustainability data on the same level of importance as financial performance.
The waste paper industry sits at the center of the circular economy, making it highly visible under CSRD. Recyclers must report not only on emissions and energy use, but also on material flows, recycling rates, and resource efficiency.
This includes applying the double materiality principle. Companies must show how sustainability risks affect their business and how their operations impact the environment and society. For recyclers, this often means detailed data on recovered paper volumes, contamination rates, and emissions per tonne processed.
Large companies already began reporting for the 2024 financial year, with reports published in 2025. For many recyclers, 2026 is a preparation and transition year as reporting obligations expand to additional company groups in the following years.
Industry surveys show that more than 60 percent of EU companies still struggle with ESG data availability and consistency, making early preparation critical. Many German recyclers are using 2026 to test data systems, define KPIs, and align internal reporting processes.
Rather than treating CSRD as a compliance exercise, leading recyclers are integrating sustainability reporting into daily operations. This includes linking production data with ESG metrics, improving traceability of recovered paper streams, and aligning sustainability targets with investment decisions.
External assurance is also becoming standard, increasing pressure on data accuracy and documentation quality.
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Germany is not “out” of waste paper. But in 2026 the industry is feeling pressure on high-quality recovered paper supplies.
We work closely with various partners in industry, trade and local governments. Focusing on the purchase and sale of secondary raw materials.
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