Disclosure focus
This disclosure asks an organisation to explain the policies it has in place for resource use and circular economy matters, and how those policies are applied in practice. In plain terms, it is about showing whether the organisation has a clear approach to using materials and resources more efficiently, reducing waste, keeping products and materials in use for longer, and managing the environmental impacts linked to those choices.
The practical focus is on whether the policy coverage is organisation-wide and not limited to a few flagship sites or isolated initiatives. Reporters should be clear about which parts of the business the policy applies to, whether it covers operations, value chain activities or specific product lines, and how it is embedded in day-to-day decision-making. The key question is not just whether a policy exists, but whether it is relevant, implemented and used consistently across the organisation.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official EFRAG source.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
＋ Show E5-1 sub-elements (LRA working checklist)
State which parts of the business and supply chain the policy covers.
Set out the aims the policy is meant to achieve.
Give the policy its name.
Describe how the policy deals with materials, waste, and keeping resources in use.
Explain the design rules used to make products easier to repair and recycle.
Say whether eco-design is used.
Identify the product groups this applies to.
How to prepare it
1Set the boundary first: decide which parts of the business and which parts of the wider value chain you will include, then keep that boundary consistent across the disclosure.
2Confirm the policy details you will report: give the policy a clear name, state what it covers in practical terms, and set out the aims it is meant to achieve.
3Work out whether eco-design is in scope for the period, and if it is, identify the product groups it applies to.
4Translate the design approach into plain business language by describing the principles used, such as making products easier to repair or recycle, without changing the underlying meaning.
5Gather the supporting records and figures behind each item, then compile the final text or data so the scope, coverage and content all line up with the evidence.
6Before sign-off, note any exclusions or changes in approach, and check the completed disclosure against the official source to make sure nothing material has been missed or misstated.
Request the data
Request the policy details from the materials and product design owner
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What written policy or policy summary do we have for materials use, waste handling and circular design, and where does it apply across our own operations and wider supply chain?
Use your organisation’s own terms first, then map them to the reporting fields. For example, if you talk about packaging standards, product design rules, waste playbooks or materials strategy, use those labels in the request and only translate them afterwards for the disclosure pack. This is a possible LRA training template; adapt it to your organisation and check the source before sign-off.
Weak request
Please send the ESRS E5 policy information for E5-1, including scope, objectives, coverage and eco-design details.
Why it fails: This uses framework language that many operational teams will not recognise, so the owner may not know which document or process to pull. It also does not point to the team’s own labels for materials, packaging, product design or waste, so the response may be incomplete or slow.
Better request
Please send the current materials, packaging or product design policy details used by your team, including the document name, what it covers, the aims, where it applies across our sites, products or suppliers, and any design rules for repair, reuse or recycling. If your team uses different labels, keep those and we will map them afterwards.
Industry examples
Draft your disclosure
Notes that turn data into a disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
Explain how the policy was defined, which business areas and upstream or downstream activities were included, how product groups were classified, and what counted as eco-design and each design principle.
Context note
Set out what the figures show about the organisation’s approach to reducing material use and waste, and how far circular design thinking has been built into products and the wider business model.
Fluctuation statement
If the pattern changed from one period to the next, note whether that was driven by a wider policy scope, more product groups being assessed, or a change in how design features were recorded.
Content index entry
E5-1 Policies — [location / page] / [notes]
Download Centre
Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
Figures are stated without the supporting narrative, or narrative without figures.Scope is inconsistent between the text and the numbers.The reporting boundary is left undefined.Material changes since the previous period are not disclosed.Estimates and measured values are not distinguished.Source records for the figures are not identified.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
Chasing the policy from the wrong team means you get a generic answer from sustainability or legal instead of the business owner who can confirm the actual wording and coverage.
Framework language, not business language
Asking for the item in ESRS-style terms can confuse colleagues, so they send back a polished summary that does not match how the organisation names the policy in practice.
No clear boundary
If you do not pin down whether the policy covers materials, waste and circularity across the business, the source pack may mix unrelated rules and leave gaps.
Wrong period basis
Pulling the latest version without checking the reporting cut-off can bring in a policy that was not in force for the period being reported.
Mixed counting basis
If one person counts only the core business and another includes the wider supply chain, the coverage figure becomes inconsistent and cannot be reconciled.
Original labels lost
When source file names and section headings are stripped away, it becomes hard to trace each answer back to the exact policy document or clause.
Separate groups merged
Combining product lines or operating units that should be kept apart can hide where eco-design applies and where it does not.
Evidence trail missing
If the extract is saved without the date, version and approver details, reviewers cannot tell which source was used or whether it was checked before submission.
No sign-off record
Collecting the data without a clear approval trail leaves no proof that the policy owner reviewed the figures and text before they were handed over.
Where judgement is often needed
Set the policy boundary after a buy-in or sale mid-year
Explain whether newly acquired or sold activities are included from the deal date or from the start of the reporting period, and keep the same cut-off across the policy name, scope, coverage and design-principles fields.
Choose one business definition where local labels differ
If countries or business units use different terms for the same materials, waste or circularity practice, map them to one group for reporting and say which local variations were folded into that group.
Decide how to treat teams or sites that sit partly inside scope
State the rule used for borderline operations, joint activities or mixed-use sites, and disclose whether they are counted in full, partly, or left out, with the same approach used across all policy items.
Fix the basis for coverage before you calculate it
Describe whether coverage is measured by headcount, spend, sites, revenue, product lines or another internal basis, and explain any estimate used where complete records are not available.
Separate what is directly checked from what is estimated
Say which parts of the policy information come from source records and which are modelled, sampled or otherwise approximated, and note the main assumptions behind any estimate.
Use one timing rule for when the policy is treated as in force
Clarify whether a policy counts only once approved, once communicated, or once applied in practice, and apply that timing consistently to the narrative and any yes/no field.
Round figures and percentages in a consistent way
State the rounding rule used for counts, shares or coverage percentages, and make sure the rounded figures still reconcile with the underlying totals.
Aggregate sensitive detail where naming a site or team would expose people
If privacy or confidentiality means you cannot name a specific location, product line or team, group the information at a higher level and explain the aggregation choice so readers understand what has been combined.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Household appliances manufacturing
We have a synthetic, illustrative policy on materials use, waste handling and circular design, aimed at cutting virgin input demand and keeping products and packaging in use for longer. It applies across our own operations and selected upstream and downstream activities, and we have started applying design-for-repair and design-for-recycling principles to three product families: kettles, vacuum cleaners and microwaves. - The policy is called our circular materials policy. - Its focus is on material efficiency, waste reduction and keeping resources circulating. - It covers our factories, warehousing and product design teams, plus key suppliers and end-of-life partners. - Eco-design is in place for 3 of 3 product families (100%). - The design rules we use prioritise easier repair and better recyclability.
Synthetic illustration only. Shows a named internal policy, its practical scope, where it applies in the business and value chain, and a simple eco-design rollout across product families.
Illustrative (synthetic) example — Commercial printing services
We use a synthetic, illustrative resource recovery policy to reduce paper losses, improve reuse and limit disposal from our print sites and related service activities. The approach reaches our production sites and logistics operations, and it also extends to paper sourcing and customer take-back arrangements; eco-design is applied to two of four service lines: short-run books and retail point-of-sale materials. - The policy title we use internally is resource recovery policy. - It addresses paper, packaging waste and circular use of materials. - The aim is to lower waste, increase reuse and support recovery of materials. - It covers our own sites, transport activities and relevant parts of the supply and customer chain. - Eco-design is in place for 2 of 4 service lines (50%). - The product groups covered are short-run books, retail point-of-sale materials, brochures and folded leaflets, with design choices focused on repairability where relevant and recyclability at end of use.
Synthetic illustration only. Shows a different sector, a different internal policy framing, broader operational and value-chain coverage, and partial eco-design adoption across service lines.
How companies report E5-1 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Covivio
Real Estate · France · 2025
Covivio’s 2025 Sustainability Report includes a covered numeric value related to policies on the circular economy, resource, and waste management, applying to all activities, found on page 103. The report also references policies covering all activities with supervision and links to third-party standards or initiatives on page 77, though this is unclear as a direct disclosure. Notably, several narrative items expected for this disclosure are not found or are missing from the report.
Sanoma Oyj
Education Services · Finland · 2025
Sanoma Oyj’s 2025 Annual Report provides evidence of identifying actual impacts related to resource use and circular economy within its upstream value chain and operations, as noted on page 78. The report includes some supporting context on policies addressing these issues, with references to key contents, scope, accountability, and third-party standards, though these are presented partially and without headline values (pp. 102, 118). However, a clear, comprehensive disclosure of specific data points or headline metrics related to resource use and circular economy is not found, and some narrative items remain unclear or missing.
Leonardo S.p.A.
Aerospace and Defense · Italy · 2025
Leonardo S.p.A.'s 2025 Integrated Annual Report includes a clear statement of its integrated Health, Safety and Environment (HSE) Policy related to resource use and circular economy on page 120. The report also references metrics and targets concerning resource use and circular economy, including non-recycled waste and policies on resource inflows, as noted on pages 462, 463, and 154. However, the report lacks clear numeric disclosures specifically related to workers in the value chain and supply chain development, with related context on page 121 being unclear, and several narrative items are not found in the report.
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Check your understanding
Scenarios to work through
A group has one written approach for cutting material use, reducing waste and improving circular use of resources. The draft mentions factory sites and suppliers, but it does not yet say whether the approach also covers product design.
QHow should you decide what to include so the policy description is complete enough for this disclosure?
Reveal model answer →Hide answer ↑Set out the policy name, then explain in plain terms what it covers across materials, waste and circular use. Make clear whether it applies only inside the business, or also across the wider supply chain, and state the aims it is meant to achieve. If the policy also reaches product design, that should be reflected in the coverage description rather than left implied.
Why this matters · Describe the policy in business language, and make the reach and purpose clear rather than assuming the reader will infer them.
A preparer is reviewing a resource-efficiency policy that applies to manufacturing sites and selected suppliers. The draft says the policy exists, but it does not say whether it is meant to influence product design choices.
QWhat should you check before finalising the scope statement?
Reveal model answer →Hide answer ↑Check that the scope covers the relevant topics named for this disclosure and that the wording shows whether the policy is limited to operations or extends into the value chain. If product design is part of the approach, include that in the scope in a way that matches the organisation’s actual practice. Do not broaden the statement beyond what the policy really covers.
Why this matters · The scope should match the real reach of the policy, including any link to design decisions and the value chain.
A company has a circularity policy for packaging and selected product lines. The team has agreed that some products are designed for easier repair, but other lines are not yet covered by those design rules.
QHow should you record the design-related part of the policy without overstating it?
Reveal model answer →Hide answer ↑State whether eco-design principles are used, and if so, identify the product groups they apply to. Then describe the design ideas in ordinary terms, such as making items easier to repair or easier to recover at end of use, but only for the categories actually covered. If the approach is not used across all products, say so clearly.
Why this matters · Be precise about which product groups are covered and avoid implying a wider design programme than exists.
A reporting team has a policy that aims to reduce virgin material use, increase reuse and improve recycling outcomes. The policy applies to owned sites and also to some outsourced activities, but the draft does not clearly separate those two areas.
QWhat is the right way to present the coverage so the reader can tell where the policy operates?
Reveal model answer →Hide answer ↑Explain the coverage in two parts if needed: what happens within the organisation’s own operations and what extends into the value chain. Use plain wording to show where the policy is active, and keep the description aligned with the actual boundaries of implementation. If the policy reaches suppliers or other external partners, that should be stated explicitly rather than bundled into a vague general statement.
Why this matters · Show clearly whether the policy works inside the business, across external relationships, or both.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
What do I need to gather for E5-1 before I start drafting the disclosure?+−
Start with the page’s datapoints to prepare: policy title, policy coverage, policy aims, coverage share, eco-design use, product groups and design features. The page also gives a step-by-step preparation flow, so you can turn those inputs into a first draft rather than starting from a blank page.
How do I use the E5-1 step-by-step preparation section in practice?+−
Use it as a working sequence for collecting the right inputs, checking scope, and shaping the narrative. It is designed to help a sustainability manager or data owner move from raw information to a draft disclosure with fewer gaps.
What does ‘coverage share’ mean for the E5-1 page, and how should I source it?+−
The page treats coverage share as one of the datapoints to prepare, so you should be able to evidence how much of the relevant scope the policy or practice covers. The page does not define the metric further, so use the workbook and your internal evidence pack to document the method you applied.
Which teams should own the E5-1 data collection and evidence pack?+−
The page is written for sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with whoever controls the underlying policy and supporting evidence. The key is to assign clear responsibility for each datapoint and each assurance claim before drafting.
What evidence should I keep ready for assurance on E5-1?+−
The page includes an evidence pack with five items and six assurance claims to verify, each with a claim, risk and evidence angle. Use those materials to show where the data came from, how it was checked, and why the disclosure is supportable.
How do I check the six E5-1 assurance claims without overcomplicating the file?+−
Work through each claim against the related risk and the evidence the page says to keep. That gives you a simple assurance-ready trail: what you are claiming, what could go wrong, and what proof you have to back it up.
What are the most common mistakes people make when drafting E5-1?+−
The page lists common reporting gaps and mistakes, so it is meant to help you spot missing scope, weak evidence, or incomplete drafting before sign-off. Use that section as a pre-submission check against your own draft and workbook outputs.
How do I use the E5-1 workbook download to build the disclosure?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is intended to help you organise the preparation and assurance work. Use it alongside the printable Library Card to capture the datapoints, evidence, and review notes needed for a draft.
What is the printable Library Card for E5-1 useful for?+−
The printable Library Card is a quick-reference download for working through the disclosure offline or in meetings. It is useful for checking the key datapoints, the assurance items, and the main drafting points before you finalise the text.
Can I use the synthetic example disclosure on the E5-1 page as a template for my own draft?+−
Yes, as a drafting aid only: the page includes synthetic illustrative example disclosures and a quantitative table to show how the information can be presented. Treat it as a model for structure and clarity, not as a source of requirements or a substitute for your own data.
How should I turn E5-1 data into a draft narrative and content-index line?+−
The page includes draft-output support such as visualisation ideas, narrative starters and a content-index line. Use those prompts to convert your prepared datapoints into a concise narrative and a clear signpost for readers.
More questions this page can help with
E5-1 disclosure checklist: what datapoints, evidence and review steps should I have before sign-off?How do I assign ownership for E5-1 policy title, coverage share and product-group data?What should go into an E5-1 assurance evidence pack for a first draft?How do I avoid common E5-1 reporting gaps when using the workbook?What is the best way to use the E5-1 Prep & Assurance workbook and Library Card together?How do I write the E5-1 narrative starter from the prepared datapoints?Can the E5-1 synthetic example help me structure my own disclosure table?What should an assurance reviewer look for in an E5-1 draft output?Where can I find real company report examples for E5-1 on the page?How do I check whether my E5-1 scope and methodology are consistent across the draft and evidence pack?What visualisation ideas does the E5-1 page suggest for presenting the disclosure?How do I use the ‘From company reports’ table without treating it as a standard mapping?
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