Do You Need to Know Your CO₂ Emissions If Your Company Has Fewer Than 250 Employees?
Even if your company has fewer than 250 employees, you may still be asked to provide CO₂ emissions data. Large clients subject to ESG reporting requirements must account for Scope 3 emissions generated throughout their supply chain. That means plastics processing companies, even without a formal obligation, are often expected to report their carbon footprint. Knowing your emissions is no longer optional—it's a business necessity.
Why Small Manufacturing Companies Can't Ignore CO₂ Emissions Reporting
As of early 2024, new ESG reporting regulations are in force across the European Union, initially targeting the largest enterprises. However, although small and medium-sized enterprises (SMEs) are not yet formally obligated to report, market practice increasingly demands that even companies with up to 250 employees supply data on their CO₂ emissions—regardless of whether they are prepared or not.
This article explains who is formally required to report, the regulatory criteria, and—most importantly—why even small companies must understand their environmental data if they want to remain in the supply chains of larger clients or continue developing their export business.
What Is ESG?
ESG stands for Environmental, Social, and Governance. In practice, this means that companies must report not only financial data but also information about their environmental impact, social responsibility, and governance structures.
ESG reports include, among other things, energy consumption, greenhouse gas emissions (CO₂e), employment policies, diversity and inclusion practices, stakeholder engagement, and legal compliance.
Who Is Obligated to Report Under ESG?
According to the CSRD (Corporate Sustainability Reporting Directive), obligations are phased in:
-
From January 1, 2024 – Applies to the largest firms with over 500 employees (listed companies, banks, insurers).
-
From January 1, 2025 – Applies to all large enterprises that meet at least two of the following three criteria:
-
Over 250 employees,
-
Annual revenue over €50 million,
-
Balance sheet total over €25 million.
-
-
From January 1, 2026 – Listed SMEs are included, with a two-year deferral option.
What About Companies with Fewer Than 250 Employees?
At this stage, most Polish SMEs, especially non-listed ones, are not formally required to publish ESG reports. However, this is a false sense of relief. In practice, more and more companies within the supply chains of large clients are being asked to provide environmental data, including CO₂ emissions.
If your company supplies components, materials, or products to a larger client subject to CSRD, you will likely be asked to provide data on emissions associated with your operations.
Why Are Large Companies Asking Their Suppliers for Emission Data?
Companies subject to ESG reporting must disclose not only their own direct emissions (Scope 1 and Scope 2), but also the indirect emissions generated throughout their supply chain (Scope 3). This includes emissions from raw material suppliers, subcontractors, and service providers.
This means that even if your company is not required to file an ESG report, you may still be obligated to provide emissions data to your client who must submit such a report. Failure to do so creates a problem for them—and a risk of losing business for you.
CBAM – Another Regulatory Challenge
In addition to ESG, companies must also prepare for CBAM – the Carbon Border Adjustment Mechanism. This EU regulation is designed to prevent carbon leakage by imposing a CO₂ cost on imported goods such as steel, aluminum, fertilizers, hydrogen, cement, and electricity.
Although plastics are not yet subject to CBAM, experts agree that the list of covered goods will expand. It’s therefore worth preparing now for the possibility that plastics processing will also become subject to such reporting.
What Does This Mean for You?
If your company:
-
employs fewer than 250 people,
-
is not listed on a stock exchange, and
-
does not import CBAM-covered goods,
you currently have no formal ESG obligation. However, if you:
-
supply products or semi-finished goods to larger companies,
-
subcontract for international clients,
-
or participate in tenders where product carbon footprint is evaluated,
then you are effectively expected to know and monitor your emissions—even if not yet required by law.
How to Prepare?
You don’t need a full-scale ESG reporting system yet, but you should:
-
Determine which plastics you process (virgin granules, regranulate, regrind) and in what quantities,
-
Identify the processing technologies you use (injection molding, extrusion, thermoforming) and estimate energy consumption,
-
Define your energy source (grid mix, green energy, photovoltaics),
-
Analyze logistics, transport distances, and packaging materials,
-
Start using tools to estimate and manage your carbon footprint.
A CO₂ Emissions Calculator Specifically for Plastics Processing Companies
That’s why I’m developing a sector-specific tool—a CO₂ emissions calculator dedicated to plastics processing companies. It includes:
-
Differentiation between virgin, recycled, and regrind materials,
-
Editable emission values (including PlasticsEurope data),
-
Manual input options for custom materials and emissions data,
-
Selection of processing technologies,
-
Specification of energy sources and country of production,
-
A dynamic table to input multiple material batches or production processes.
This tool is not designed for bureaucratic compliance, but to help companies like yours maintain competitiveness and prepare for inevitable regulatory shifts.
Summary
Even if you're not formally obligated to report ESG data yet, market pressures mean you must already know your CO₂ emissions. Sooner or later, someone will ask. And if you don’t have an answer, you may be excluded from key partnerships.
Knowing your emissions today is not just about environmental responsibility—it is part of serious business strategy.
Want to Join the Beta Program for Our Plastics CO₂ Calculator?
Our calculator will be free and available online. It’s built specifically for plastics processors and tailored to the realities of your production: types of plastics used (granules, regranulate, regrind), processing technologies (injection, extrusion, blow molding, thermoforming, pultrusion), energy source, logistics, and location.
If you'd like early access to the beta version, get in touch.
Companies willing to provide real data to help calibrate the calculator (anonymized if needed) will receive free access to the online course:
“CO₂ Emissions in Plastics Processing – How to Calculate, Report, and Reduce Them”
In the course, I cover:
-
How to identify emissions in typical production processes (extrusion, molding, drying, cooling, blow molding, packaging),
-
How to calculate CO₂ emissions based on your own data, PlasticsEurope values, or default assumptions,
-
The differences between Scope 1, 2, and 3 emissions—and which ones you should care about,
-
How to deliver reliable data to clients requesting ESG supply chain reporting,
-
How to avoid mistakes and use environmental data as part of your sales strategy,
-
Practical ways to reduce emissions—not by theory, but by real technological and organizational improvements,
-
How to build a competitive advantage through environmental awareness and compliance with incoming ESG and CBAM regulations.
This is not an academic theory course—it’s a practical tool designed for the real needs of plastics processing companies.
As of early 2024, new ESG reporting regulations are in force across the European Union, initially targeting the largest enterprises. However, although small and medium-sized enterprises (SMEs) are not yet formally obligated to report, market practice increasingly demands that even companies with up to 250 employees supply data on their CO₂ emissions—regardless of whether they are prepared or not.
This article explains who is formally required to report, the regulatory criteria, and—most importantly—why even small companies must understand their environmental data if they want to remain in the supply chains of larger clients or continue developing their export business.
What Is ESG?
ESG stands for Environmental, Social, and Governance. In practice, this means that companies must report not only financial data but also information about their environmental impact, social responsibility, and governance structures.
ESG reports include, among other things, energy consumption, greenhouse gas emissions (CO₂e), employment policies, diversity and inclusion practices, stakeholder engagement, and legal compliance.
Who Is Obligated to Report Under ESG?
According to the CSRD (Corporate Sustainability Reporting Directive), obligations are phased in:
-
From January 1, 2024 – Applies to the largest firms with over 500 employees (listed companies, banks, insurers).
-
From January 1, 2025 – Applies to all large enterprises that meet at least two of the following three criteria:
-
Over 250 employees,
-
Annual revenue over €50 million,
-
Balance sheet total over €25 million.
-
-
From January 1, 2026 – Listed SMEs are included, with a two-year deferral option.
What About Companies with Fewer Than 250 Employees?
At this stage, most Polish SMEs, especially non-listed ones, are not formally required to publish ESG reports. However, this is a false sense of relief. In practice, more and more companies within the supply chains of large clients are being asked to provide environmental data, including CO₂ emissions.
If your company supplies components, materials, or products to a larger client subject to CSRD, you will likely be asked to provide data on emissions associated with your operations.
Why Are Large Companies Asking Their Suppliers for Emission Data?
Companies subject to ESG reporting must disclose not only their own direct emissions (Scope 1 and Scope 2), but also the indirect emissions generated throughout their supply chain (Scope 3). This includes emissions from raw material suppliers, subcontractors, and service providers.
This means that even if your company is not required to file an ESG report, you may still be obligated to provide emissions data to your client who must submit such a report. Failure to do so creates a problem for them—and a risk of losing business for you.
CBAM – Another Regulatory Challenge
In addition to ESG, companies must also prepare for CBAM – the Carbon Border Adjustment Mechanism. This EU regulation is designed to prevent carbon leakage by imposing a CO₂ cost on imported goods such as steel, aluminum, fertilizers, hydrogen, cement, and electricity.
Although plastics are not yet subject to CBAM, experts agree that the list of covered goods will expand. It’s therefore worth preparing now for the possibility that plastics processing will also become subject to such reporting.
What Does This Mean for You?
If your company:
-
employs fewer than 250 people,
-
is not listed on a stock exchange, and
-
does not import CBAM-covered goods,
you currently have no formal ESG obligation. However, if you:
-
supply products or semi-finished goods to larger companies,
-
subcontract for international clients,
-
or participate in tenders where product carbon footprint is evaluated,
then you are effectively expected to know and monitor your emissions—even if not yet required by law.
How to Prepare?
You don’t need a full-scale ESG reporting system yet, but you should:
-
Determine which plastics you process (virgin granules, regranulate, regrind) and in what quantities,
-
Identify the processing technologies you use (injection molding, extrusion, thermoforming) and estimate energy consumption,
-
Define your energy source (grid mix, green energy, photovoltaics),
-
Analyze logistics, transport distances, and packaging materials,
-
Start using tools to estimate and manage your carbon footprint.
A CO₂ Emissions Calculator Specifically for Plastics Processing Companies
That’s why I’m developing a sector-specific tool—a CO₂ emissions calculator dedicated to plastics processing companies. It includes:
-
Differentiation between virgin, recycled, and regrind materials,
-
Editable emission values (including PlasticsEurope data),
-
Manual input options for custom materials and emissions data,
-
Selection of processing technologies,
-
Specification of energy sources and country of production,
-
A dynamic table to input multiple material batches or production processes.
This tool is not designed for bureaucratic compliance, but to help companies like yours maintain competitiveness and prepare for inevitable regulatory shifts.
Summary
Even if you're not formally obligated to report ESG data yet, market pressures mean you must already know your CO₂ emissions. Sooner or later, someone will ask. And if you don’t have an answer, you may be excluded from key partnerships.
Knowing your emissions today is not just about environmental responsibility—it is part of serious business strategy.
Want to Join the Beta Program for Our Plastics CO₂ Calculator?
Our calculator will be free and available online. It’s built specifically for plastics processors and tailored to the realities of your production: types of plastics used (granules, regranulate, regrind), processing technologies (injection, extrusion, blow molding, thermoforming, pultrusion), energy source, logistics, and location.
If you'd like early access to the beta version, get in touch.
Companies willing to provide real data to help calibrate the calculator (anonymized if needed) will receive free access to the online course:
ONLINE COURSE “CO₂ Emissions in Plastics Processing – How to Calculate, Report, and Reduce Them”
In the course, I cover:
-
How to identify emissions in typical production processes (extrusion, molding, drying, cooling, blow molding, packaging),
-
How to calculate CO₂ emissions based on your own data, PlasticsEurope values, or default assumptions,
-
The differences between Scope 1, 2, and 3 emissions—and which ones you should care about,
-
How to deliver reliable data to clients requesting ESG supply chain reporting,
-
How to avoid mistakes and use environmental data as part of your sales strategy,
-
Practical ways to reduce emissions—not by theory, but by real technological and organizational improvements,
-
How to build a competitive advantage through environmental awareness and compliance with incoming ESG and CBAM regulations.
This is not an academic theory course—it’s a practical tool designed for the real needs of plastics processing companies.
Also check out:
on CO₂ footprint, ESG, and sustainability
– Online courses: [Read more here →]
– Our blog articles: [Read more here →]
By Dr. Magdalena Laabs
Plastics Processing Industry Expert
Rolbatch Academy