CSRD Reporting for Textile Businesses

Textile businesses face a particular version of the CSRD problem. The reporting entity is usually a brand that designs and sells, and almost every material impact occurs in facilities it has never visited.

Where the impact actually is

The distribution of impact across a textile value chain is consistent enough to plan around, and it is not where most attention historically went.

The fourth row is where brands have relationships and audits, and it carries relatively little of the environmental impact. The rows above it carry most of it and are where visibility is weakest.

Wet processing is the hotspot

Dyeing, printing and finishing consume large volumes of water, chemistry and thermal energy, and they are performed by mills that frequently serve many brands without any one of them being a major customer.

This is the structural reason textile Scope 3 figures rest so heavily on averages. The primary data would come from a facility the reporting brand has no contractual relationship with.

Fibre choice moves the number most

Between two garments of similar construction, fibre selection typically changes the footprint more than manufacturing location, transport mode or factory efficiency.

That has a useful consequence for reporting. Fibre composition is data a brand already holds, at product level, for every item it sells — which makes it the one high-impact input that does not require reaching upstream to obtain.

What ESRS E5 asks that E1 does not

Climate reporting under E1 is the familiar part. Resource use and circular economy reporting under E5 asks different questions, and product data is the only credible source for several of them.

• Resource inflows — the material entering products, by type and by whether it is virgin or secondary.
• Resource outflows — what leaves as product, by durability and recyclability characteristics.
• Waste — including production waste, which for cutting operations is substantial.
• Circular design characteristics — what the products are actually designed to enable.

The first two are effectively a bill of materials aggregated across everything sold in the period. A business that holds fibre composition per product can produce them; one that holds it per range cannot.

Where the passport work overlaps

The data a textile passport requires and the data ESRS E5 requires are substantially the same, gathered at the same granularity, from the same suppliers.

Running these as separate programmes means asking the same mills the same questions months apart, and the second request reliably gets worse answers than the first.

Data quality is disclosed, not hidden

ESRS requires disclosure of methodology and data quality alongside the quantitative result, which changes what a partial dataset means for a report.

A figure resting largely on sector averages is reportable if it is described as such. The failure mode is presenting an average-derived number as though it were primary, which assurance will test and which the passport’s provenance record makes unnecessary.

What to do about it

Start with fibre composition at product level, because it is the highest-impact input you already hold and it feeds both obligations directly.

Then work on wet processing visibility specifically rather than on suppliers generally, since that is where the impact is and where a cascade will not reach. Nominating dyehouses, or buying fabric rather than garments, are the mechanisms that actually create the relationship.

And specify the passport and the reporting data requirements in one supplier request. The mill does not care which internal obligation the question serves and will judge you on how many times you ask.

This requires the sustainability and compliance functions to agree a single data specification before either approaches a supplier, which is an internal coordination problem rather than a technical one. It is also the cheapest improvement available to either programme.

Where those functions report to different executives, the coordination usually fails quietly — each team assumes the other’s request covered what they needed, and the gap surfaces during assurance when there is no time left to close it.