Packages and closures for packaging

ESG - are you ready?

The packaging world is undergoing a transformation driven simultaneously by concern for the climate, rising consumer expectations, and regulatory pressure from the European Union. At the heart of these processes is ESG - a set of environmental, social, and corporate-governance criteria.


ESG expands on the original idea of CSR - corporate social responsibility, and revolves around three pillars: environmental impact, social responsibility, and governance. This means that issues such as CO₂ emissions, human rights in the supply chain, and anti-corruption mechanisms now appear in companies’ annual reports alongside financial results.


Key regulations include the SFDR regulation, the CSRD directive on sustainability reporting, and the CSDDD directive, which aims to counteract the negative human-rights and environmental impacts of business activity. In Poland, their provisions were transposed into an amendment to the Accounting Act of 6 December 2024. The new law introduced the concept of “sustainability reporting” and linked it to the National Court Register. It requires companies’ sustainability reports to describe their business model clearly, present key non-financial performance indicators, explain supply-chain risk-control procedures, and provide full emissions data. Greenhouse-gas disclosures must cover both direct emissions (Scope 1) and indirect emissions (Scopes 2 and 3), necessitating data collection not only from a firm’s own operations but also from its entire supply chain.


Implementation deadlines arrive in waves. The first wave covers all large entities listed on the Warsaw Stock Exchange that employ more than 500 people (reporting for the 2024 fiscal year). The second wave encompasses all large undertakings that meet two of three criteria: more than 250 employees, annual net turnover of at least €50 million, or total assets of at least €25 million; they will report for 2025. The third wave extends the obligation to small and medium-sized listed companies, using data for 2026. From 2029, reporting will also cover certain non-EU entities that generate a significant share of their revenue in the EU market.


In April 2025, the European Parliament adopted the so-called Omnibus package, which included the StopTheClock mechanism that postponed the obligations for the second and third waves by two years. While this eases the burden on smaller businesses, it adds pressure on market leaders to implement robust data-collection systems during the reprieve. This underscores that the ESG trend is irreversible, even if we have been granted a short window to adapt our tools.


The technical side of reporting sets a high bar. Companies must switch to digital, continuous monitoring of indicators to gather comprehensive emissions data across the entire value chain. The document must be signed with a qualified electronic signature and submitted to the court register within fifteen days of the financial statement’s approval. Without integrating their ERP system with ESG modules and automatically importing data from production sites or warehouses, meeting these requirements will be nearly impossible.


ESG therefore presents businesses with a new challenge. Remember, it is not a one-off project but a process that requires ongoing monitoring. Moreover, the forthcoming PPWR will tighten rules on packaging and packaging waste across the EU. The packaging sector faces a major shift and should prepare now to avoid last-minute corrections and comfortably meet the new requirements when they take effect.