Glossary · Emissions & reporting
CSRD and what it means for a produce importer
Also known as Corporate Sustainability Reporting Directive.
The EU sustainability reporting rule that reaches importers through their retailers rather than directly — and which now caps what a retailer may demand from a small supplier.
Published
The Corporate Sustainability Reporting Directive is the EU rule requiring large companies to publish audited sustainability information, including the Scope 3 emissions in their supply chains. It reaches most produce importers indirectly: not as an obligation, but as a questionnaire from a customer who does have one.
Who has to report, after the 2026 rewrite
This is the part that changed, and most of what was written about CSRD before 2026 is now wrong. The Omnibus I Directive entered into force in March 2026 and cut the population of reporting companies sharply.
Reporting is required only of companies with more than 1,000 employees and more than €450 million of net turnover, for financial years starting from January 2027. Your retailer is above that line. Almost no fresh produce importer is.
The value-chain cap
The more useful half is what an in-scope company may now ask of the companies below it.
A reporting company may not require sustainability information from a value-chain company of 1,000 employees or fewer beyond a defined, limited set aligned to a voluntary standard for smaller businesses. You may declare that you are under the threshold and the declaration is taken at face value. You have a right to refuse a request that goes past the cap, and the buyer is treated as compliant for having respected it.
So a twelve-page ESG questionnaire is a request, not a requirement.
What to do about it anyway
The commercial pressure is real even where the legal pressure is not, because listings are decided on preference. What answers the question is a per-shipment record of mode, distance and weight, built while containers are moving rather than reconstructed a year later. Food miles are misleading sets out what actually drives the number.
FAQ
Does CSRD apply to my import business?
Almost certainly not directly. Since the Omnibus I Directive of March 2026, only companies with more than 1,000 employees and more than €450 million of net turnover report, from financial years starting January 2027. You will still meet CSRD through customers who are in scope — but if you are at or under 1,000 employees, they may not require information from you beyond a capped, limited set, and you may decline the rest.