CSRD affects food producers in two distinct ways, and most guidance addresses only one of them.
The first is direct: food producers that meet the CSRD thresholds are in-scope reporters, required to disclose Scope 1, 2, and 3 emissions under ESRS E1 with auditable methodology and year-on-year tracking. The second is indirect but increasingly operationally significant: food producers that supply CSRD-obligated retailers, foodservice operators, and manufacturers are being asked for verified emissions data as a condition of maintaining those commercial relationships—regardless of whether they're in scope themselves.
Understanding both dimensions, and where they overlap, is what CSRD preparation looks like for food producers specifically.
Following the EU Omnibus amendments adopted in early 2026, CSRD now applies to large undertakings with more than 1,000 employees and net annual turnover above €450 million. For most food producers, this means:
Large food manufacturers and processors: National or multinational companies meeting the thresholds are in scope for CSRD reporting, with the first disclosures covering financial year 2025 for the largest companies.
Mid-size and smaller food producers: Most are not directly in scope under the revised thresholds, but face CSRD indirectly through their buyers' supply chain data requirements.
For food producers directly in scope, CSRD requires:
• ESRS E1 climate disclosures: Scope 1, 2, and 3 emissions with traceable methodology, documented under the GHG Protocol Corporate Value Chain Standard
• Double materiality assessment: Determining which sustainability topics are material from both an impact perspective and a financial risk perspective; for food producers, Scope 3 Category 1 (purchased agricultural inputs) and Category 11 (use of sold products) are typically material
• Third-party verification: Limited assurance from an external auditor covering the accuracy and consistency of disclosed figures
• Year-on-year tracking: Comparison against a documented baseline, with a transition plan for material emission categories
For a full preparation framework covering all food business types, see How Food Businesses Can Prepare for CSRD Reporting.
Most CSRD guidance focuses on Scope 3 Category 1, i.e. purchased goods and services. For food producers, Category 1 covers the agricultural inputs, ingredients, and raw materials purchased. This is where most of the upstream supply chain emissions sit.
But food producers face an additional category that many other industries don't: Scope 3 Category 11, use of sold products.
Category 11 covers the greenhouse gas emissions associated with how customers use a food producer's products after purchase. For food ingredients sold to manufacturers, this typically means the emissions from processing and preparation downstream. For food products sold directly to consumers or foodservice operators, it covers cooking and preparation emissions.
Whether Category 11 is material for a specific food producer depends on the product type and the downstream processing involved. For food ingredient manufacturers whose products undergo significant further processing by buyers—dairy ingredients, fats and oils, protein ingredients—Category 11 is likely material and requires a methodology for calculating downstream use-phase emissions. For producers of minimally processed products sold directly to end consumers, the materiality assessment may conclude Category 11 is less significant.
The practical implication: food producers in scope of CSRD need a product-level carbon footprint (PCF) calculation as an input—not just for communicating product credentials to buyers, but as the data foundation for their own Category 11 assessment.
For food producers not directly in scope, the practical pressure comes from buyers. Retailers, foodservice operators, and manufacturers that are CSRD-obligated need verified Scope 3 Category 1 data from their supply chains. Every ingredient and product they purchase contributes to their Category 1 inventory—and auditors increasingly expect primary supplier data rather than spend-based estimates for material categories.
The result is a data requirement flowing down the supply chain from CSRD-obligated buyers to their food producer suppliers, regardless of whether those suppliers are in scope themselves.
What buyers are asking for:
• Product carbon footprints: Calculated to ISO 14067, with documented methodology and system boundaries. This is the primary data that replaces spend-based Category 1 estimates in buyers' CSRD disclosures.
• FLAG emissions coverage: Explicit confirmation that land-use change is included in PCF calculations for high-FLAG commodities like beef, dairy, palm oil, cocoa, and soy. Buyers with SBTi FLAG commitments need this separation. For a practical guide to engaging food suppliers for emissions data, see Scope 3 Supplier Engagement for Food Businesses.
• Origin and production method data: Where a full PCF is not yet available, this allows buyers to apply more accurate secondary emission factors.
• Year-on-year trend data: For established supplier relationships, buyers tracking progress against SBTi targets need emissions trend data from key suppliers.
For food producers, meeting these requirements is increasingly a commercial necessity—not just for existing contracts but as a prerequisite for winning new ones. For a full guide to what procurement teams now require, see What Procurement Teams Now Require from Food Suppliers on Sustainability.
Alongside CSRD, the EU Empowering Consumers Directive (Directive 2024/825/EU, EmpCo), which Member States must enforce from September 2026, creates a parallel obligation for food producers making environmental claims about their products.
EmpCo prohibits environmental claims that cannot be substantiated with robust, recognized scientific evidence. For food producers willing to communicate the carbon footprint of their products in product marketing, on-pack communication, or commercial pitches, a PCF calculated to ISO 14067 is the documented, methodologically grounded basis those claims require.
Claims made without verified data carry direct legal risk under EmpCo—enforcement action and reputational exposure. The connection to CSRD is direct: the same PCF data that supports CSRD-adjacent buyer requirements is the substantiation that EmpCo demands for product-level claims.
This creates a strong practical case for food producers to calculate PCFs now rather than waiting for a regulatory deadline: the data serves CSRD supply chain requirements, EmpCo claim substantiation, and commercial tender scoring simultaneously.
Food producers setting Science-Based Targets face additional requirements under the SBTi FLAG framework. FLAG (Forest, Land, and Agriculture) emissions—covering land-use change, deforestation, and agricultural production impact—must be reported and targeted separately from fossil fuel emissions. For food businesses also managing EUDR compliance, see EUDR and Food Businesses—the traceability data EUDR requires overlaps significantly with FLAG and CSRD Category 1 data infrastructure.
For food producers, this means:
• Calculating FLAG emissions specifically, with LCA methodology that explicitly covers land-use change
• Setting a separate FLAG reduction pathway alongside a fossil fuel reduction target
• Demonstrating year-on-year progress against both targets
The data foundation for SBTi FLAG reporting is the same ingredient-level, activity-based procurement data that CSRD Category 1 disclosures require. Investing in that data infrastructure once serves both frameworks rather than building parallel processes for each.
For a full guide to FLAG emissions specifically, see FLAG Emissions: A Complete Guide for Food Businesses.
Determine whether you're directly in scope under the revised CSRD thresholds, and identify which of your buyers are in scope—as their requirements flow to you regardless of your own status. Map the data requests already arriving from buyers to understand which requirements are most urgent.
For in-scope food producers, PCF data is needed for Category 11 assessment. For all food producers, it's the data buyers need for their Scope 3 Category 1 inventory. Start with the products that generate the most procurement revenue or that are sold to buyers with the most stringent data requirements.
Ensure PCF calculations cover FLAG emissions explicitly for high-risk commodity categories—this is increasingly required by both buyers and SBTi validation.
Food producers who submit verified PCF data to the Klimato database make that data available automatically to foodservice buyers using Klimato's platform for their own Scope 3 Category 1 reporting. This removes the manual data request cycle with multiple buyers and embeds the producer's data into buyer workflows directly.
For in-scope reporters, CSRD requires a complete Scope 1, 2, and 3 inventory. Scope 1 (direct emissions from manufacturing) and Scope 2 (purchased energy) are typically less data-intensive than Category 1 but need to be documented consistently alongside procurement data.
CSRD requires third-party verification of disclosed figures. Every calculation decision—system boundaries, emission factor sources, data gaps and proxy approaches—needs to be documented clearly enough for an auditor to follow the trail from raw data to disclosed figures. Building this documentation from the start is significantly less work than reconstructing it retrospectively under audit pressure.
Q: Does CSRD apply to all food producers?
A: After the EU Omnibus amendments in early 2026, CSRD applies directly to companies with more than 1,000 employees and annual turnover above €450 million. Most small and mid-size food producers are not directly in scope. However, food producers that supply CSRD-obligated buyers face indirect requirements—those buyers need verified emissions data from their supply chains regardless of the supplier's own reporting status.
Q: What is Scope 3 Category 11 and does it apply to food producers?
A: Category 11 covers the greenhouse gas emissions associated with how customers use a food producer's sold products. For food ingredient manufacturers whose products undergo further processing downstream, Category 11 is likely material under CSRD's double materiality assessment and requires a methodology for calculating downstream use-phase emissions. Whether it's material for a specific producer depends on the product type and the extent of downstream processing.
Q: Why do food producers need a PCF even if they're not in CSRD scope?
A: Product carbon footprints serve three purposes simultaneously: they provide the primary data that CSRD-obligated buyers need for their own Scope 3 Category 1 inventory, they substantiate sustainability claims under the EmpCo Directive, and they support SBTi FLAG target-setting for producers with science-based commitments. Calculating a PCF once, to ISO 14067, satisfies all three requirements—making it the most efficient single investment for food producers managing multiple sustainability obligations.
Q: What is EmpCo and how does it affect food producers?
A: The EU Empowering Consumers Directive (EmpCo, Directive 2024/825/EU), enforced from September 2026, prohibits environmental claims that cannot be substantiated with robust scientific evidence. Food producers making sustainability claims in product marketing, on-pack communication, or commercial pitches need a PCF calculated to a recognized standard as documented substantiation. Claims without verification carry legal risk under EmpCo.
Q: How does CSRD connect to SBTi FLAG for food producers?
A: Companies setting Science-Based Targets through the SBTi FLAG framework must report and target land-use and agricultural supply chain emissions separately from fossil fuel emissions. The ingredient-level, activity-based data required for SBTi FLAG reporting is the same data needed for CSRD Category 1 and Category 11 disclosures. Building the data infrastructure once serves both frameworks.
Q: How does Klimato support food producers with CSRD preparation?
A: Klimato's Product Carbon Footprinting service calculates ISO 14067-aligned PCFs for food producers—with FLAG coverage, full methodology documentation, and methodology reviewed by Bureau Veritas. Verified PCF data can be submitted to the Klimato database, making it available to foodservice buyers using Klimato's platform for their own CSRD Scope 3 Category 1 reporting. For food producers that are in-scope CSRD reporters, Klimato Carbon Accounting supports full Scope 1–3 inventory management and ESRS E1-aligned reporting outputs.
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Klimato's Product Carbon Footprinting service calculates verified, ISO 14067-aligned PCFs for food producers, with FLAG coverage and direct integration into the Klimato database for buyer use.