Worker in warehouse surrounded by cardboard packaging boxes – PPWR regulation supply chain compliance

08.10.2026

PPWR Regulation: The Most Important Questions and Answers for Companies

The PPWR (Packaging and Packaging Waste Regulation) introduces comprehensive requirements for companies across the entire packaging value chain. In this article, we answer the key questions about the PPWR regulation and outline which obligations will apply for companies starting in 2026.

The PPWR – also known as the new EU Packaging Regulation – covers packaging design, recyclability, labeling, extended producer responsibility (EPR), and packaging waste reduction. Below you will find answers to the most important PPWR questions, structured by topic.

1. What is the PPWR (Packaging and Packaging Waste Regulation)?

The PPWR regulation is a key component of the European Green Deal. As a uniform, directly applicable framework, it replaces the previous Packaging Directive. The regulation aims to strengthen the circular economy across the EU, reduce packaging waste, increase recyclability and material efficiency, and harmonize existing rules throughout the EU.

2. When does the PPWR apply?

The PPWR entered into force on February 11, 2025. It has applied since August 12, 2026, and will be rolled out in stages through 2040, with key milestones in 2028 and 2030.

3. Who is affected by the PPWR regulation?

The PPWR applies to all packaging and packaged products placed on the EU market. Since August 12, 2026, goods packaged in non-compliant packaging may no longer be marketed within the EU.
Exceptions and specific provisions apply to packaging for dangerous goods, medical devices, sensitive food contact materials, and innovative packaging, providing flexibility where safety or innovation considerations justify it.

To the question on PPWR roles: The PPWR has an extremely broad scope. As a result, it affects a wide range of companies, including:

Suppliers of packaging or packaging materials
Manufacturers of packaging or packaged products
Distributors, importers, and fulfillment service providers
Brand owners placing packaged goods on the EU market
Non-EU suppliers delivering products or packaging to the EU

The following sectors are particularly impacted:

FMCG / fast-moving consumer goods (food, beverages, personal care)
Retail, e-commerce, and online marketplaces
Packaging manufacturing
Logistics, fulfillment, and transport packaging
Textiles, apparel, and footwear (packaging-related aspects)
Hospitality, food service, and take-away (HORECA)

4. Which roles does the PPWR regulation define?

The PPWR establishes clear obligations for each economic operator along the supply chain and generally distinguishes between producers, importers, distributors, and suppliers.

Manufacturer

A natural or legal person that manufactures packaging or a packaged product, or has packaging or a packaged product designed or manufactured under its own name or trademark. (This includes packaging manufacturers as well as companies such as Amazon.)

Supplier

Any natural or legal person that supplies packaging or packaging materials to a producer.

Importer

Any natural or legal person established in the EU that places packaging from a non-EU country on the EU market.

Distributor: Any natural or legal person in the supply chain—other than the producer or importer—that makes packaging or packaged products available on the market.

5. What does the PPWR role “Producer” mean, and how does it differ from “Manufacturer”?

This is a quite often asked PPWR question: Under the PPWR regulation, “Producer” refers to any producer, importer, or distributor—regardless of where they are established—that places packaging or packaged products on the market in a Member State for the first time. Producers assume additional obligations, including extended producer responsibility (EPR) for collection and recycling. The term should not be confused with “Manufacturer.” The Manufacturer is one of the roles covered under the broader term “Producer.” There is also potential for confusion in German terminology: in the regulatory context, “Hersteller” refers to the entity responsible for first placing packaging on the market, while “Erzeuger” refers to the entity that manufactures packaging or packaged products.

It is important to understand that within a packaging value chain, there is only one Manufacturer, but there may be multiple Producers. Whether a company qualifies as a Producer must be assessed separately for each Member State, depending on who places the packaging or packaged product on the market first.

6. What does “Extended Producer Responsibility” mean in the context of the PPWR regulation?

A key element of the PPWR is the principle of Extended Producer Responsibility (EPR). EPR compliance requires producers to take responsibility not only for manufacturing and distributing their products, but also for managing the end-of-life treatment of the associated packaging.

For example, online retailers based in Germany that sell goods to end customers in Austria must appoint an authorized representative in Austria, register in the national producer register, and pay the applicable fees there.

7. How will EPR fees change under the PPWR?

Starting 18 months after publication of the EU criteria, EPR fees will be modulated based on environmental performance. This means the fees will be structured according to how sustainable the packaging is. For example, lower fees will apply to packaging with higher recyclability.

8. What obligations does the PPWR regulation introduce for companies?

The PPWR introduces extensive sustainability and information requirements for companies across the entire value chain. These obligations cover packaging design and material selection as well as documentation, labeling, traceability, and reporting.

Key obligations – depending on the company’s role – include:

1. Compliance & chemical safety (from 2026)

Compliance with limits for substances of concern (e.g., PFAS, heavy metals), especially for food contact materials
Conducting conformity assessment procedures
Preparing technical documentation
Issuing an EU Declaration of Conformity (DoC)

2. Labeling & transparency (from 2028 onward)

Harmonized labeling on material composition
Information on compostability, take-back schemes, or deposit return systems
Labeling of reusable packaging
Providing information to authorities and market surveillance bodies
Registration and compliance within the framework of extended producer responsibility (EPR)

3. Design and sustainability requirements (phased in through 2040)

Minimizing weight, volume, and empty space (maximum 50% for transport and e-commerce packaging from 2030)
Ban on certain single-use plastic packaging formats
Recyclability requirements (at least 70% from 2030, 80% from 2038)
Design for recycling to enable material recovery
Minimum recycled content in plastic packaging (10–35% from 2030, up to 65% by 2040)
Compliance with binding reuse targets
Industrial-scale recyclability (from 2035)

4. Specific requirements for certain packaging types

Mandatory compostability for specific applications (e.g., tea bags or fruit labels)
Reuse options in take-away settings
Allowing customers to use their own containers

9. What specific PPWR regulation requirements apply starting in 2026?

If you are the Manufacturer of the packaging or packaged products under the PPWR regulation:

You must carry out a conformity assessment procedure and prepare the technical documentation and EU Declaration of Conformity.
You may not use substances of concern in packaging materials (e.g., PFAS, heavy metals).
You are subject to general labeling requirements.

If you purchase packaging or packaged products downstream from a Manufacturer or from your suppliers, you are subject to due diligence obligations. These include, among other things, verifying compliance of the packaging and ensuring that labeling requirements have been properly fulfilled.

10. What requirements apply regarding empty space and overpackaging?

Starting January 1, 2030, grouped, transport, and e-commerce packaging may contain no more than 50% empty space. Filling material is considered empty space. Packaging weight and volume must be reduced to what is strictly necessary, and cosmetic practices such as double walls or false bottoms are prohibited, with only limited exceptions.

11. What impact does the PPWR have on the supply chain?

The PPWR regulation increases data requirements for suppliers and packaging manufacturers across the entire packaging supply chain. It requires clear allocation of responsibilities within the packaging value chain and leads to greater coordination efforts between procurement, sustainability, quality management, and suppliers. At the same time, risks increase due to incomplete or outdated supplier data. As a result, transparency and a digital, readily accessible data foundation become increasingly important.

12. How should companies prepare for the PPWR regulation now?

Companies should establish transparency at an early stage regarding affected packaging and suppliers, review existing data and supporting documentation, and define clear processes for data collection and maintenance. It is also crucial to involve suppliers in a timely manner and build digital structures to ensure scalable and audit-proof compliance.

Our approach:

Manage packaging master data efficiently
Identify roles and obligations
Capture missing packaging data automatically
Request, create, and send declarations of conformity

13. How does the PPWR relate to other ESG requirements?

Supply chain decarbonization

The PPWR promotes recyclable and material-efficient packaging, reducing the use of virgin raw materials and energy-intensive production steps. This creates a direct lever for lowering Scope 3 emissions.

REACH / RoHS

The PPWR builds on existing chemicals regulations and further specifies substance requirements for packaging, for example by setting limits for PFAS and heavy metals to systematically reduce environmental and health risks.

ESRS E5 – Circular Economy

The PPWR operationalizes ESRS E5 requirements by defining binding criteria for recyclability, material composition, and recoverability of packaging. This enables robust and comparable ESG metrics.

EUDR – Traceability

Similar to the EUDR, the PPWR requires transparent traceability of materials and suppliers to demonstrate regulatory compliance across the supply chain.

Digital Product Passport (DPP)

The PPWR provides key data points for the Digital Product Passport, particularly regarding material composition, substances, recyclability, and compliance. It thus lays the foundation for digital, standardized transparency at product and packaging level.

14. Why should companies implement the PPWR early?

Companies should implement the PPWR at an early stage to reduce compliance, liability, and market access risks, while avoiding last-minute implementation challenges and supply chain bottlenecks. Acting now enables companies to build robust data structures instead of relying on manual, ad hoc solutions and strengthens their positioning toward customers, retailers, and authorities. At the same time, the PPWR can serve as a lever for more efficient and sustainable packaging strategies. Early action also ensures sufficient time for necessary adjustments in research and development, including planning, testing, and scaling.

15. What penalties apply in case of PPWR violations?

In Germany, missing EU Declarations of Conformity, technical documentation, registrations, licensing obligations, or incorrect information may result in fines of up to €200,000. In addition, sales bans may be imposed. Specific penalties for individual PPWR obligations will be further defined through additional legal acts.

Implement PPWR with ease

We hope, we could answer most of your questions! Be aware: Starting in 2026, PPWR compliance will become an operational reality—manual Excel spreadsheets will no longer be sufficient. With the VERSO PPWR software solution, you can centralize and automate data collection, supplier communication, and record-keeping for the PPWR Declaration of Conformity on a single platform.

Want to understand your specific obligations? Take the PPWR Check. In just three minutes and a few clicks, you will see what applies to your company—and receive a practical checklist to help you get started.

Take the PPWR Check now

* This information is summarized editorial content and should not be construed as legal advice. VERSO accepts no liability.

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23.09.2026

EU Forced Labour Regulation: What Companies Need to Know Now

In 2027, the new European regulation on forced labour will start to apply, prohibiting products made with forced labour from being made available on the EU market or exported from the EU. Here’s our summary of what’s behind it – and what it means for your supply chain.

The EU Forced Labour Regulation (FLR) prohibits products made with forced labour from being made available on the EU market or exported from the EU as of December 14, 2027. It applies to all companies, regardless of size or industry. It doesn’t require a report. In the event of suspicion, however, companies must be able to provide information about their supply chain.

The European Commission’s guidelines have been available since fall 2026. They show in much greater detail how authorities will conduct their investigations and what information companies should have ready. We summarize what the regulation says, what the guidelines add, and where it’s best to start.

What is the Forced Labour Regulation

The EU Forced Labour Regulation (Regulation (EU) 2024/3015) prohibits products made wholly or partly with forced labour. It has been in force since December 2024 and will apply from December 14, 2027. From that date on, such products may no longer be placed on the EU market, made available on it, or exported from the EU.

The ban covers all products, whether they originate in the EU or in third countries. It also applies to components and intermediate products: if forced labour was used at any stage – during extraction, harvesting, production, or processing – the final product falls under the ban. Services are not covered.

Unlike the LkSG and CSDDD, the regulation doesn’t require companies to follow specific due diligence processes or publish an annual report. Instead, it focuses on the outcome: a product made with forced labour must not be sold. The burden of proof lies with the authorities. If the suspected forced labour takes place outside the EU, the European Commission leads the investigation; within the EU, the competent national authority is responsible.

Since June 2026, the European Commission’s Forced Labour Single Portal has brought together all information on the regulation, including guidelines, contact points, and support services.

What counts as “forced labour”?

The regulation adopts the definition used by the International Labour Organization (ILO): “Forced labour is all work or service which is exacted from any person under the menace of any penalty and for which that person has not offered themselves voluntarily. This includes state-imposed forced labour.”

In practice, forced labour is rarely as obvious as the term suggests. The ILO indicators of forced labour help identify warning signs:

Exploitation of vulnerable persons
Deception
Restriction of freedom of movement
Insulation
Physical and sexual violence
Intimidation and threats
Retention of identity documents
Withholding of wages
Debt bondage
Abusive working and living conditions
Excessive overtime

Many of these indicators don’t show up on any supplier data sheet. They usually only become visible when companies ask targeted questions, for example through self-assessments, audits, or grievance mechanisms.

Does the Forced Labour Regulation also apply to mid-sized companies?

Yes. The regulation applies to every company that places products on the EU market, makes them available there, or exports them from the EU, including online retailers based in third countries. There are no thresholds based on headcount or revenue.

This is a significant difference from the LkSG and CSDDD: with fewer than 1,000 employees, or fewer than 5,000 employees in the future, many mid-sized companies aren’t directly affected by these laws and therefore haven’t set up their own due diligence processes. Under the Forced Labour Regulation, the only thing that matters is whether a product is affected.

The Walk Free Foundation’s 2023 Global Slavery Index shows how relevant the issue is for Germany: in the five largest product categories alone, Germany imported goods worth USD 44 billion that carry a risk of forced labour. Many of these goods enter mid-sized manufacturers’ supply chains as raw materials or intermediate products.

On top of that comes pressure from customers. Large manufacturers will want to know where the components in their products come from – and will pass this question on to their suppliers.

The European Commission has announced targeted support for smaller companies. A checklist and an overview of freely available supply chain tracing tools are already available on the Single Portal.

What do the European Commission’s guidelines say?

The guidelines show how authorities will apply the regulation and how companies can reduce their risk through due diligence processes. The Commission adopted them on June 26, 2026. They aren’t legally binding, but they give companies and authorities clear direction.Die Leitlinien zeigen, wie Behörden die Verordnung anwenden werden und wie Unternehmen mit Sorgfaltsprozessen ihr Risiko senken können. Die Kommission hat sie am 26. Juni 2026 angenommen. Rechtlich bindend sind sie nicht. Sie geben Unternehmen und Behörden aber eine klare Orientierung.

The key points:

OECD-based due diligence: The regulation doesn’t create any new due diligence obligations. Nevertheless, the guidelines are based on the OECD’s six-step due diligence framework. Companies that align their measures with this framework will be in a better position to demonstrate what they have done to prevent forced labour if suspicions arise.
Risk-based assessment: Authorities prioritize cases based on the scale and severity of the forced labour, the quantity of products placed on the EU market, and the share the suspect component accounts for in the product. Risk factors related to regions, sectors, and companies are also taken into account, as is the quality of a company’s due diligence processes.
Designated contact: Companies should appoint a person or department responsible for handling inquiries from authorities.
Remediation: If forced labour occurs, companies should be prepared to contribute to remediation. If this isn’t realistic in the short term, responsible disengagement from the business relationship may be the only option.
Support for smaller companies: The Commission has published a checklist and an overview of freely available tracking tools. Between September and November 2026, it is also offering webinars, some of them sector-specific.

What happens when authorities investigate a suspected case?

In the event of suspicion, the authority requests information on the measures a company takes to identify and address forced labour risks in its supply chain. This may include supplier lists, proof of origin, or the results of risk assessments. With the consent of the company and the country concerned, the authority can also conduct inspections outside the EU.

If a company is unable or unwilling to provide the information, the authority makes its decision based on the information available to it. In practice, this rarely works in the company’s favor.

If the suspicion is confirmed, the authority can order:

that the product may no longer be placed on the EU market, made available on it, or exported from the EU
that products already made available be withdrawn from the market,
that affected products be disposed of at the company’s expense or that tainted components be replaced.

For supply chains of strategic importance, the authority can instead have the product withheld until the company demonstrates that the forced labour has been eliminated. Products that have already reached end users don’t have to be recalled.

An authority’s decision applies in all EU member states, and customs authorities enforce it at the border. Companies face fines if they fail to comply with such a decision.

How does the Forced Labour Regulation differ from the CSDDD and LkSG?

The LkSG and CSDDD require large companies to implement due diligence processes. The Forced Labour Regulation focuses on the product and applies to all companies.

	LkSG	CSDDD	Forced Labour Regulation
Legal form	German law	EU directive, transposed into national law	EU regulation, directly applicable
Applies from	2023	July 2029	December 14, 2027
Approach	Company-based	Company-based	Product-based
Who is affected?	Planned increase to 5,000 employees and €1.5 billion in revenue	Companies with more than 5,000 employees and more than €1.5 billion in global revenue	All companies that place products on the EU market, make them available there, or export them from the EU
Topics	Human rights and the environment	Human rights and the environment	Forced labour
What is required?	Due diligence processes and internal documentation	Due diligence processes	No process requirement, but forced-labour-free products
Legal consequences	Fines, only enforced for serious violations since fall 2025	Fines of up to 3% of global revenue	Market ban, withdrawal, disposal; fines for non-compliance

The three regulations interlock. Companies that have already set up due diligence processes for the LkSG or CSDDD can build on them. What’s needed then is primarily a closer look at individual products, raw materials, and regions of origin.

Where should supply chain managers start?

There’s enough time until December 2027 to build processes without rushing. It’s best to start where the risk is highest and your information is thinnest.

1. Identify critical products and raw materials: Which raw materials and intermediate products come from regions or sectors with an elevated risk of forced labour? The ILO indicators and, in the future, the Commission’s risk database provide guidance.

2. Review existing supplier information: What do you already know about these suppliers today? Self-assessments, certificates, and supporting documents are often scattered across the ERP system, Excel spreadsheets, and individual inboxes.

3. Clarify responsibilities: Who would be the point of contact if an inquiry from the authorities comes in? And who would then compile the information?

4. Connect to existing processes: Integrate the topic into procurement, compliance, and supplier management rather than setting up a separate process alongside them.

5. Involve suppliers: Communicate your expectations, for example through a code of conduct and targeted questions in supplier surveys.

How does VERSO support companies in implementing the Forced Labour Regulation?

In the event of suspicion, what matters is that you can present your supplier information quickly and transparently. The VERSO Supply Chain Hub maps these processes.

With our due diligence processes, you can survey your suppliers in a structured way, assess risks, and manage measures. All self-assessments, supporting documents, and steps are documented in one place instead of being scattered across inboxes and spreadsheets. This also shows you which suppliers you’re still missing information from.

VERSO has been supporting mid-sized companies in implementing sustainability since 2010, including in their supply chains. Feel free to get in touch if you’d like to know how to integrate the Forced Labour Regulation into your processes.

FAQ on the EU Forced Labour Regulation

When does the EU Forced Labour Regulation apply?

The regulation has been in force since December 2024 and will apply from December 14, 2027. From that date on, products made with forced labour may no longer be made available on the EU market or exported from the EU.

Does the Forced Labour Regulation also apply to mid-sized companies?

Yes. The regulation has no thresholds based on headcount or revenue. For smaller companies, the European Commission has published a checklist and an overview of freely available tools.

Do I have to prepare a report under the Forced Labour Regulation?

No. The regulation provides for neither an annual reporting obligation nor a general audit requirement. In the event of suspicion, however, companies must provide the authority with information about their supply chain and the measures they have taken.

Are the European Commission’s guidelines binding?

No. The guidelines were adopted in June 2026 and published in the EU’s Official Journal in September 2026. They serve as guidance for companies and authorities; only the text of the regulation itself is legally binding.

Who checks whether a product is affected?

If the suspected forced labour takes place outside the EU, the European Commission is responsible; within the EU, the national authorities are. The burden of proof lies with the authorities. Which authority will be responsible in Germany has not yet been determined.

What is the difference between the Forced Labour Regulation and the LkSG?

The LkSG requires companies with 1,000 or more employees to implement due diligence processes. The Forced Labour Regulation focuses on the product: it applies to all companies and excludes affected products from the EU market.

* This information is summarized editorial content and should not be construed as legal advice. VERSO accepts no liability.

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03.09.2026

The Five Biggest Greenwashing Traps and How to Avoid Them

100% sustainable, climate-neutral or bio-plastic – what it says on a product doesn’t always have to be true. There are countless examples of greenwashing that we have all heard of. Greenwashing often happens unknowingly. The list of stumbling blocks is long. Find out what they are and how to avoid them in this article about the five most common pitfalls.

Greenwashing means environmental claims that make a company or product look more sustainable than the evidence supports. Typical greenwashing examples include terms like “climate neutral” without proof, carbon footprints that leave out Scope 3, or a single green initiative presented as the big picture. Most of the time, it happens by accident. Since 27 September 2026, stricter EU rules apply to environmental claims. Here are the five most common traps and how to avoid them.

Traps and examples for greenwashing

1. Confusing data situation and opaque sustainability reports

Data is the basis for a meaningful sustainability report. This allows you to document and underline your sustainability ambitions. It is important that it is accurate, complete and audit-proof. This is because sustainability reports must be checked by an external auditor as part of the CSRD. It is best to maintain your data clearly in a specialized tool; we have developed the VERSO ESG Hub especially for this purpose.

This makes it easier to:

check the data for accuracy,
interpret the key figures correctly,
quickly recognize the actual status quo and
keep track of the development of your company.

This prepares you for active communication free of greenwashing and enables you to answer critical questions confidently and based on data.

Example: A machinery manufacturer states in its sustainability report that it has cut energy consumption by 30%. The figure covers only one of three plants, and there is no reference period. As soon as customers or auditors ask questions, the claim falls apart.

2. Scope 1, 2, 3 – all included?

When you create a carbon footprint, it is already a major challenge to gather all the relevant data from your own company. However, it can be even more challenging if you need climate data from other companies for the CO₂footprint. This is because not only the emissions that a company itself emits have to be taken into account, but also those in the value chain!

Many companies “only” record the emissions in Scope 1 and 2 in their first carbon footprint. This includes, for example, direct emissions from fossil fuels such as gas and heating oil or the company’s own vehicle fleet (Scope 1) and indirect emissions from the generation of purchased electricity, steam, heat and cooling (Scope 2).

However, to make a statement about your actual greenhouse gas emissions, you also need the information from Scope 3, which includes all upstream and downstream emissions along your company’s value chain (purchased goods or raw materials, business trips and transportation).

Example: A supplier advertises that it has “halved CO₂ emissions since 2020”. This only refers to Scope 1 and 2, because the site switched to green electricity. Emissions from purchased components are missing, and that is usually where most of the footprint lies.

Did you know that the majority of CO2 emissions come from Scope 3?

Recording Scope 3 is much more laborious than just Scope 1 and 2, as you need a lot of data from other companies. Nevertheless, you should include this area in your reporting as soon as possible. It helps to engage in dialog with stakeholders and get digital help. The VERSO Supply Chain Hub gives you an overview of the emissions in your supply chain. In this way, you avoid the risk of making false statements about your sustainability due to a lack of data.

3. Don’t exaggerate, stick to the facts!

A careless word is quickly uttered, the data is no longer fully remembered or superlatives and exaggerated statements are added in all the euphoria. Many greenwashing accusations have their origins in marketing activities that portray the company in too good a light. Be careful what you put out there!

Four tips on how to create credible and accurate content:

Four tips for credible sustainability communication: no silos, "we're on our way", precise statements, internal experts

Example: The website says “100% sustainable packaging”. In fact, only the cardboard box is made from recycled material. The plastic film is not. The claim covers the whole package, but the evidence covers only part of it.

4. Cherry-picking makes you look untrustworthy

Precisely because there are so many examples of greenwashing, stakeholders are scrutinizing a company’s sustainability statements more and more closely. Companies must communicate transparently so that stakeholders consider their communication on the topic to be credible and effective.

We advise against “cherry picking”, i.e. communicating a few positive results or activities!

A small positive initiative quickly becomes unnaturally inflated. The key is a holistic approach: talk about the need for action that your organization still has, share your ambitions and goals, communicate the challenges that you still have to overcome as a company. This will show that your company is not treating sustainability as a one-off project, but is striving for serious and holistically effective changes.

Example: A company showcases its new solar installation on LinkedIn. The post doesn’t mention that it covers only a small share of the electricity demand, or that total consumption has gone up.

5. Activities lack reference to the company or product

The activities you communicate about must be appropriate to your company, its products and its size.

Example: Buying your first e-car out of a fleet of 500 diesel vehicles is more likely to attract criticism than applause.

However, if your activities fit into the corporate context, the seriousness of your ambitions will be comprehensible to external stakeholders. And: your employees will also identify with it and be enthusiastic about getting involved. A materiality analysis is helpful here: this allows you to identify the areas in which the company has a high negative or positive impact on the environment and society or which could be relevant from a financial perspective. The findings can then be used to tackle the issues that really make a difference.

Greenwashing examples from court and enforcement cases

“Climate neutral” without explanation (German Federal Court of Justice, 2024)

A confectionery manufacturer advertised in a trade journal that all its products were made climate neutral. This was achieved through offsetting projects, with details available only via a link. The court banned the ad: “climate neutral” is ambiguous, so the explanation has to appear in the ad itself. Since 27 September 2026, product claims like this are generally prohibited in the EU if they rely solely on offsetting.

Sustainability claims without internal substance (2025)

The Frankfurt public prosecutor’s office fined an asset manager EUR 25 million. The company had presented itself as a leader in sustainable investment, but its internal processes did not match. The lesson applies to any company: whatever your communication promises, your data and processes have to back it up.

Which environmental claims are no longer allowed in the EU?

Since 27 September 2026, the EU’s Empowering Consumers for the Green Transition Directive (EmpCo) has applied. Generic claims such as “eco-friendly”, “green” or “climate neutral” are only permitted if they are backed by recognised excellent environmental performance, for example the EU Ecolabel. Product claims of climate neutrality based solely on carbon offsetting are prohibited. The rules cover advertising to consumers. B2B companies are affected as soon as their claims end up in communication with end customers. Avoid these terms or back them up with specific evidence:

Greenwashing examples: generic terms such as CO₂ neutral, eco-friendly, green and ecological

Afraid of greenwashing? No “green silence” please!

You should no longer be afraid of greenwashing. What we are observing: Because companies see how easily sustainability communication can become greenwashing and how much this can damage the company, they don’t talk about their activities in the first place. A domino effect: if no company communicates about sustainability, everyone thinks that the others are doing nothing and therefore does less themselves than they actually could.
This spiral of silence slows down the sustainable transformation of companies and therefore the entire economy.

With this overview, we want to achieve the opposite: We hope to have encouraged you to communicate transparently and effectively about your sustainability strategy and activities.

Frequently asked questions on greenwashing

What are typical greenwashing examples?

Common examples are generic terms like “climate neutral” or “eco-friendly” without proof, carbon footprints without Scope 3 emissions, claims about a whole product when only part of it is more sustainable, and single green projects presented as the whole story.

Can companies still advertise products as “climate neutral”?

Only within narrow limits since 27 September 2026. If a product’s climate neutrality rests solely on offsetting, the claim is prohibited in the EU. Specific, verified statements remain allowed, for example about emissions you have actually reduced.

Do the EU greenwashing rules apply to B2B companies?

EmpCo covers advertising to consumers. Suppliers are still affected when their environmental claims appear on packaging, in catalogues or in their customers’ marketing. Misleading claims towards business customers can also be challenged under national unfair competition law.

Avoid greenwashing? VERSO supports you!

If you need support in communicating and preparing your sustainability report, we will be happy to help you: With our ESG software, you can collect all relevant data and report in compliance with CSRD. We are also on hand to advise you on your journey to sustainable transformation.

Please write to us. We can help you.

* This information is summarized editorial content and should not be construed as legal advice. VERSO accepts no liability.

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19.08.2026

ESG sanctions at a glance: the cost of mistakes in reporting and supply chain obligations

A slap on the wrist and, if it becomes public, a brief outcry from the public: until a few years ago, companies didn’t have to worry too much if they put sustainability on the back burner or engaged in greenwashing. The Omnibus package does little to change that: the EU has pushed back deadlines and reduced the number of companies affected, but it has not abolished the sanctions.

Companies that breach ESG and supply chain obligations risk fines in the millions, penalties calculated as a percentage of annual turnover, seized goods or exclusion from public contracts, depending on the regulation. The EU Omnibus package made some rules less strict in 2026 and narrowed the group of companies they apply to. This article shows which sanctions apply under the CSRD, CSDDD, LkSG, CBAM, EUDR, PPWR, DPP and EmpCo, and from when.

As of September 2026. This article reflects the EU Omnibus I package, the planned reform of the LkSG and the latest postponement of the EUDR. This information is editorial content that should not be construed as legal advice. VERSO accepts no liability.

ESG sanctions at a glance: possible sanctions, companies affected and start date by regulation (as of September 2026)
Regulation	Possible sanctions	Who is affected?	From when?
CSRD	Planned under the HGB: fines of up to €10 million or 5% of annual turnover (capital market-oriented companies), prison sentences of up to 3 years	More than 1,000 employees and over €450 million net turnover	Once the German implementation act enters into force (legislative process ongoing)
CSDDD	Up to 3% of global net turnover, civil liability under national law	More than 5,000 employees and over €1.5 billion net turnover	Applies from 26 July 2029
LkSG	Previously up to €8 million or 2% of global annual turnover, exclusion from public procurement; in future only for serious violations	1,000 or more employees in Germany	In force since 2023, reform in the legislative process
EU ETS	€100 per tonne of CO₂e without an allowance (adjusted for inflation)	Operators of installations covered by emissions trading	In force
CBAM	Same as EU ETS per missing certificate, revocation of declarant status	Importers of 50 tonnes or more of CBAM goods per year	Definitive phase since 1 January 2026
EUDR	At least 4% of annual EU turnover, confiscation of goods, import bans, exclusion from public procurement	Operators and traders handling relevant commodities	30 Dec 2026 (large/medium), 30 June 2027 (micro/small)
PPWR	Fines of up to €200,000 under the German VerpackDG, distribution bans, public register entries	Manufacturers, importers and distributors of packaging	Since 12 August 2026
EmpCo	Warning letters, cease-and-desist claims; fines of up to €50,000 or 4% of the affected annual EU turnover	All companies making environmental claims to consumers	Since 27 September 2026
DPP (ESPR)	Fines (level set nationally), withdrawal and recall, import bans, exclusion from public procurement	Manufacturers and companies placing the relevant product group on the market	Battery passport from 18 Feb 2027, other product groups to follow

What sanctions apply for breaches of the CSRD, EU Taxonomy and SFDR?

There is no EU-wide, uniform set of sanctions for the CSRD. Each member state decides how to penalise errors in sustainability reporting. In Germany, this will be governed by the CSRD Implementation Act, which is still going through the legislative process. Until it enters into force, companies that were already required to report remain subject to the HGB rules on the non-financial statement. The government draft is based on the existing criminal and administrative penalty provisions in §331 and §334 HGB. In figures, this means:

Prison sentences of up to 3 years
For members of authorized representative bodies or supervisory boards of a corporation: prison sentences of up to 3 years; companies face fines of up to 2 million euros or twice the economic benefit they have derived from the incorrect report – whichever is higher.
For capital market-oriented companies: Fines of up to 10 million euros, 5 percent of annual turnover or twice the economic benefit – the highest amount is also chosen here.

On top of this – as the fermented icing on the cake, so to speak – there may also be legal action for breach of competition law, exclusion from public procurement procedures and “naming and shaming”, i.e. publicity including loss of reputation.

Important to know: Only intentional errors and errors due to gross negligence are punishable.

In the next few years, the first court proceedings will show the exact direction of sanctions for breaches of the EU taxonomy, CSRD and SFDR.

Read more:

Sanctions for LkSG and CSDDD

How high are the fines under the CSDDD?

With the Omnibus I package, the EU significantly weakened the CSDDD, the European supply chain directive, in 2026. This also affects the sanctions. Companies that breach their due diligence obligations for people and the environment face:

Fines of up to 3% of global net turnover.
Civil liability for damages. The EU-wide harmonised liability rule was removed; liability is now governed by the law of each member state.
Naming and shaming and exclusion from public procurement.

What does a breach of the German Supply Chain Act (LkSG) cost?

In contrast to the CSDDD, the German Supply Chain Act does not create its own civil liability. The LkSG requires companies to meet human rights and environmental due diligence obligations in their own business operations and towards direct suppliers. For indirect suppliers, the obligations apply as soon as the company has substantiated knowledge of possible violations. Risks must be identified, documented and eliminated or at least minimised.

Previous fine framework: fines of up to 8 million euros. For companies with an annual turnover of more than 400 million euros, the fine increases to up to 2% of global annual turnover. And: companies can be excluded from public procurement.

What is set to change: in September 2025, the German government adopted a reform of the LkSG; the legislative process is still ongoing. Under the reform, the annual reporting obligation is to be abolished retroactively. Fines are only to be imposed for serious violations that lead to grave human rights abuses. The due diligence obligations themselves remain in place. In practice, the Federal Office for Economic Affairs and Export Control (BAFA) has already suspended the reporting obligation. In the medium term, the national implementation of the CSDDD is to replace the LkSG.

Read more:

Factsheet: CSDDD vs. LkSG
Whitepaper: Due Diligence in the supply chain
Practical guide: Risk Analysis in the Supply Chain
How VERSO supports you with the implementation of CSDDD and LkSG

EU ETS and CBAM sanctions

EU ETS

With the EU Emissions Trading System (EU ETS), the EU aims to cap the emissions of the member states. Companies only have a certain amount of freedom to emit emissions – otherwise certificates must be purchased. Non-compliance could result in fines:

100 euros per metric ton of CO2 equivalents emitted without a certificate (adjusted annually for inflation)

In order to avoid certificate prices on the one hand and sanctions on the other, some companies relocated their production to non-EU countries (“carbon leakage”). The CBAM was therefore also introduced as part of the EU ETS reform.

What sanctions apply under the CBAM?

The definitive phase of the CBAM has been running since 1 January 2026. Companies that import certain emission-intensive goods such as steel, aluminium, cement or fertilisers from non-EU countries need the status of authorised CBAM declarant and must buy and surrender CBAM certificates for the embedded emissions.

Relief from the Omnibus package: companies that import less than 50 tonnes of CBAM goods per year are exempt from the obligations. This does not apply to electricity and hydrogen.

The so-called “climate tariff” supplements the EU ETS and provides for the following sanctions:

Missing certificates: in accordance with the EU ETS, fines of EUR 100 per tonne of CO2 equivalent are imposed.
Anyone importing CBAM goods without the status of authorized declarant must expect even higher penalties.
In the event of violations, the authorised declarant status can be revoked. The company may then no longer import CBAM goods.
For the transitional phase (2023 to 2025), incomplete, incorrect or missing CBAM reports were subject to penalties of 10 to 50 euros per tonne of unreported emissions.

Read more:

When do EUDR sanctions apply?

Supply chain officers and buyers must prepare themselves for even more sanctions. If you place products on the EU internal market whose production has come at the expense of forests, you could face the following penalties under the EUDR:

Skimming off profits unlawfully made as a result of non-compliance with the EUDR
Fines in proportion to forest damage and value of goods, but at least 4 % of annual turnover
Seizure of goods or products
Temporary import bans
Exclusion from public funds and public tenders
Inclusion in a public list incl.
Information on the violation

Also important: The EU has postponed the application of the EUDR once again. The obligations apply from 30 December 2026 for large and medium-sized companies and all traders, and from 30 June 2027 for micro and small enterprises. From then on, you may only place the relevant goods on the EU market if geolocation data and proof of origin are available. Keep this in mind today when ordering goods that will reach the EU single market from the end of December.

Read more:

What companies can expect with the EUDR

What fines apply under the PPWR?

The EU Packaging and Packaging Waste Regulation (PPWR) has applied since 12 August 2026. In Germany, the Packaging Law Implementation Act (VerpackDG) governs how violations are penalised. It replaces the previous Packaging Act (VerpackG). Depending on the severity of the violation, companies face:

Fines of up to 200,000 euros, for example for placing packaging on the market without the required participation in a take-back system or for selling despite a distribution ban
Fines of up to 100,000 euros for breaches of registration, reporting and documentation obligations or of take-back and deposit obligations
Fines of up to 10,000 euros for certain formal violations
Distribution bans and public entries in the register

The PPWR introduces new sanctionable offences, such as missing declarations of conformity, missing technical documentation and breaches of the requirements on recyclability and recycled content. The European Commission recommends that authorities initially focus on warnings and corrective measures.

What penalties apply for greenwashing under the EmpCo?

Since 27 September 2026, EmpCo has regulated misleading environmental claims and unlawful sustainability labels more strictly. In Germany, the requirements are implemented through the Act Against Unfair Competition. Violations may therefore primarily result in warnings, cease-and-desist claims, interim injunctions and legal action by competitors or associations.

In certain cases, fines may also apply. For widespread infringements, the fine can amount to up to EUR 50,000. For companies with annual revenue of more than EUR 1.25 million, the fine may amount to up to 4% of the affected EU annual revenue.

The European Commission halted the Green Claims Directive, which was intended to regulate environmental claims in addition, in June 2025. This makes EmpCo the relevant framework for environmental claims.

Read more:

What sanctions apply to the Digital Product Passport (DPP)?

With the Ecodesign for Sustainable Products Regulation (ESPR), the EU is gradually introducing the Digital Product Passport. It brings together information on a product’s materials, origin, reparability and environmental impact. Companies that fail to meet the requirements face sanctions. Member states set the level of fines, but the ESPR already provides for the following measures:

Fines
Withdrawal and recall of products
Import bans
Temporary exclusion from public procurement

The battery passport will be the first mandatory product passport from 18 February 2027. In Germany, incorrect or incomplete information can lead to fines of up to 10,000 euros. For other product groups such as textiles and furniture, the EU has yet to define the requirements.

Frequently asked questions about ESG sanctions

Which ESG regulations provide for sanctions?

Sanctions apply under the CSRD, the CSDDD, the German Supply Chain Due Diligence Act (LkSG), the Carbon Border Adjustment Mechanism (CBAM), the EU Deforestation Regulation (EUDR) and the EmpCo directive against greenwashing, among others. The type and amount of sanctions differ by regulation.

What is the highest possible fine?

The highest fines are set by the turnover-based regulations. Under the CSDDD, fines of up to 3% of global net turnover are possible; under the EUDR, the maximum is at least 4% of annual EU turnover. On top of that come consequences such as exclusion from public contracts or confiscation of goods.

Has the EU Omnibus package changed the sanctions?

Yes. The Omnibus I package weakened the CSDDD: it now only applies to companies with 5,000 or more employees and 1.5 billion euros in turnover, from 26 July 2029, with a maximum fine of 3% instead of 5% and without EU-wide harmonised civil liability. For the CSRD, the group of companies required to report was reduced, and the CBAM now has an exemption for imports below 50 tonnes per year.

Does the German Supply Chain Act still apply?

Yes. The due diligence obligations under the LkSG continue to apply. A reform is set to abolish the reporting obligation and limit fines to serious violations; in practice, BAFA has already suspended the reporting obligation. In the medium term, the national implementation of the CSDDD is to replace the LkSG.

Are mid-sized companies affected by ESG sanctions?

Directly, mainly through the CBAM, EUDR and EmpCo, because these rules are not tied to company size. The CSRD, CSDDD and LkSG usually affect mid-sized companies indirectly: large customers pass their obligations on to their suppliers through contracts and data requests.

Save money and nerves with VERSO

To ensure that companies do not approach the sustainable transformation too carelessly, the EU provides for “effective, proportionate and dissuasive” measures in any case.

In view of the possible sanctions, we are happy to believe this – and help you to correctly implement the guidelines and regulations that apply to you. Not only our top software, but also our experienced consultants and our specialized partners are at your side. Feel free to get in touch with us!

Get in touch now!

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Update LkSG und CSDDD - die wichtigsten Änderungen

04.08.2026

CSDDD and LkSG Implementation: Why Companies Need Resilient Supplier Processes Now

What’s changing with LkSG and CSDDD, what the timeline for CSDDD implementation in Germany means, and why companies should integrate due diligence obligations into resilient supplier processes.

In brief

CSDDD implementation refers to transposing the European due diligence directive into national law
Affected companies must systematically identify, prioritize, and address human rights and environmental risks in their supply chains
In Germany, the CSDDD will replace the LkSG; it applies from July 26, 2029, for companies with 5,000 or more employees and €1.5 billion or more in revenue.

The rules around corporate due diligence obligations are in flux. CSDDD implementation was adjusted through the Omnibus package. As a result, the scope, individual requirements, and timeline have changed.

For many companies, one thought seems obvious: wait until it’s finally clear who has to meet which requirements and when.

But that reduces the European supply chain directive, the CSDDD, too much to thresholds and deadlines. The underlying task remains the same: companies must identify, prioritize, and appropriately address human rights and environmental risks in their supply chains. Directly affected companies need their own due diligence processes, and smaller companies and suppliers will continue to be drawn in through their customers’ data requests, evidence, and measures.

Waiting to build resilient structures doesn’t automatically buy time. Supplier data can’t be completed on short notice, responsibilities can’t be clarified overnight, and supplier relationships can’t be developed through a one-time questionnaire.

For efficient LkSG and CSDDD implementation, companies shouldn’t treat due diligence as an isolated compliance task. It makes more sense to embed it firmly into existing supplier and risk management.

What does CSDDD implementation mean?

CSDDD stands for Corporate Sustainability Due Diligence Directive. In German, it’s often referred to as the EU supply chain law or European supply chain directive.

The directive obligates the companies it covers to embed human rights and environmental due diligence into their own operations, subsidiaries, and relevant business relationships. The goal is to identify negative impacts on people and the environment and, where possible, prevent, mitigate, or end them.

Core due diligence obligations include, in particular:

integrating due diligence into policies and risk management systems,
identifying and prioritizing actual and potential negative impacts,
implementing prevention and remediation measures,
enabling complaint and grievance mechanisms,
monitoring the effectiveness of measures,
and documenting implementation in a traceable way.

The CSDDD therefore doesn’t describe a one-time review process. Due diligence forms a cycle: risks are identified, measures are decided, progress is reviewed, and processes are adjusted as needed.

A completed supplier questionnaire can provide information for a risk analysis. However, it replaces neither the prioritization of risks nor the tracking of measures nor continuous supply chain monitoring.

What are the differences and similarities between CSDDD and LkSG?

Germany’s Supply Chain Due Diligence Act, known as LkSG, has been in effect since 2023. It currently forms the German legal framework for human rights and certain environmental due diligence obligations in supply chains.

The CSDDD applies a similar underlying logic at the European level. It, too, requires systematic risk management, prevention and remediation measures, complaint mechanisms, and monitoring of effectiveness.

Criterion	LkSG	CSDDD
Legal level	German law	EU directive, to be transposed nationally
Applicable from	Since 2023	July 26, 2029 (first wave)
Threshold	Currently 1,000 employees (restructuring planned)	5,000 employees / €1.5 billion revenue
Core obligations	Risk analysis, prevention/remediation, complaints, documentation	Largely equivalent, risk-based approach

What do LkSG and CSDDD implementation have in common?

For companies in Germany, LkSG and CSDDD aren’t two entirely separate tasks. Existing structures from LkSG implementation can form an important foundation for CSDDD implementation. These include, for example:

defined responsibilites,
structured supplier and risk analyses,
prevention and remediation measures,
complaint procedures,
as well as documentation and effectiveness monitoring.

What changes with the CSDDD?

While the LkSG is a German law, the CSDDD creates a common European framework. It must be transposed into national law by member states, which will further develop Germany’s existing regulations.

Until national transposition takes place, the LkSG formally remains in effect, though enforcement has already become more restrained. Details on implementation status can be found in the timeline section.

What matters for you in procurement: don’t build a separate process for every new law — build one resilient system for corporate due diligence obligations.

When does the CSDDD apply? Germany’s implementation timeline

The CSDDD is already in force and was adjusted as part of the Omnibus package. The changes affect, among other things, the scope, individual due diligence obligations, and the timeline.

The following requirements remain particularly relevant for companies:

systematically identifying and prioritizing human rights and environmental risks,
implementing appropriate prevention and remediation measures,
providing a complaint mechanism,
monitoring the effectiveness of measures,
and documenting implementation in a traceable way.

In Germany, the amended CSDDD still needs to be transposed into national law. Until a corresponding new regulation is in place, the LkSG remains the existing legal framework. It’s expected, however, that Germany will implement the CSDDD largely in close alignment with the European requirements.

The direction in Germany is now clear: the federal government has decided to transpose the CSDDD into German law on a one-to-one basis. The LkSG will be restructured accordingly; its scope is set to be limited to companies with 5,000 or more employees and revenue exceeding €1.5 billion. The external LkSG reporting obligation is effectively already obsolete: BAFA has not reviewed it since fall 2025, and its formal repeal is underway.

For preparation purposes, waiting for every regulatory detail makes little sense. The operational fundamentals are already clear: companies need resilient supplier data, a risk-based approach, documented measures, and clear responsibilities.

Companies that wait to build these structures until after the legislative process concludes will then be starting with the most time-intensive tasks.

Which companies are affected by the EU supply chain law?

Following the adjustments made through the Omnibus package, the so-called EU supply chain law, the CSDDD, applies from July 2029 to companies with more than 5,000 employees and worldwide net revenue exceeding €1.5 billion. This covers both companies headquartered in the EU and certain companies from non-EU countries, provided they meet the relevant revenue criteria in the European single market.

In practice, however, direct legal applicability isn’t the only factor that matters. Smaller companies and suppliers can also have requirements passed on to them through their business relationships. This makes it worth distinguishing between direct and indirect applicability.

Which companies are directly affected by the CSDDD?

Directly affected companies must integrate the statutory due diligence obligations into their organization and risk management. These include, among others:

identifying risks and negative impacts,
prioritizing them,
implementing prevention and remediation measures,
providing complaint mechanisms,
monitoring the effectiveness of measures,
and documenting implementation.

These tasks can’t be handled by legal, compliance, or sustainability teams alone. They directly affect procurement, supplier, and risk processes.

Are mid-market companies affected by the CSDDD?

Mid-market companies generally don’t fall directly within the CSDDD’s scope. Even so, they can be affected through their business relationships.

Large customers need information to assess their own risks and meet their due diligence obligations. As a result, they may request from suppliers, for example:

information on production sites and supply chains,
evidence of human rights or environmental standards,
self-disclosures and risk information,
contractual assurances,
and participation in prevention or improvement measures.

This doesn’t create automatic legal equivalence with directly affected companies. In practice, however, requirements are passed down through the supply chain. Not being directly affected doesn’t automatically mean there’s no need to act.

What does CSDDD implementation mean for procurement and supplier management?

Responsibility for the CSDDD sits at the company level. For operational implementation, though, procurement plays a central role: this is where suppliers are selected and assessed, requirements are communicated, and measures are carried out within the business relationship.

A resilient data foundation comes first. Companies need to know which suppliers and production sites they work with, and which countries, industries, or activities may carry elevated risks. Often, however, this information is scattered across ERP systems, spreadsheets, emails, and various departments.

The task, therefore, isn’t just about collecting more data. Information needs to be current, plausible, and clearly assigned to a supplier or site. Only then can companies meaningfully assess and prioritize risks.

Why supplier questionnaires aren’t enough for CSDDD implementation

One-time supplier questionnaires only capture a snapshot. Production conditions, sites, and risk situations can change, evidence can become outdated, and new information can emerge. Completeness and quality of responses also often vary considerably.

Above all, the due diligence process doesn’t end with data collection. When risks are identified, companies must initiate appropriate prevention or remediation measures, assign responsibilities, and review effectiveness.

For procurement, this means in particular:

bringing supplier and risk data together in a usable way,
continuously assessing and prioritizing risks,
clearly communicating requirements and evidence needed,
tracking measures and deadlines,
and documenting decisions and supplier communication in a traceable way.

Supplier management shouldn’t be reduced to control, though. Smaller suppliers in particular may not yet have the systems or resources to meet every requirement immediately. Effective due diligence therefore pairs clear expectations with targeted supplier development.

How are companies preparing for CSDDD implementation?

The CSDDD’s core requirements are set. Companies should now align their existing supplier and risk processes to systematically capture risks, track measures, and document implementation in a traceable way.

Five areas are especially important here:

1. Clarify responsibilities

Procurement, sustainability, compliance, legal, and management need to be clearly aligned. Companies should define who assesses risks, requests information, decides on measures, escalates critical cases, and documents effectiveness.

2. Bring supplier and risk data together

Much of the relevant information already exists — supplier master data, audit reports, certificates, or quality assessments, for example. What’s often missing is a shared view. Companies should therefore check what data exists, how current it is, and where gaps remain.

3. Establish continuous risk management

Risk assessments should be updated regularly and whenever specific triggers arise. New suppliers, changed production sites, incidents, or complaints can all call for a renewed assessment. A risk-based approach helps focus limited resources on the most important cases.

4. Document measures and evidence centrally

Risk analyses, supplier communication, evidence, measures, deadlines, and effectiveness checks should be documented in one shared process. This keeps companies audit-ready and avoids time-consuming reconstruction from emails and spreadsheets.

5. Automate recurring processes

Requests, reminders, deadlines, and monitoring are difficult to manage manually on an ongoing basis for large supplier bases. Automation reduces the burden of recurring tasks and creates a consistent documentation history.

Companies shouldn’t build a separate structure just for the CSDDD. A more sustainable approach is supplier management that can accommodate different due diligence obligations, customer requirements, and other regulatory requirements (EUDR, PPWR, CBAM, etc.).

Software for LkSG and CSDDD implementation

Efficient implementation requires connecting supplier data, risk analyses, requests, measures, and evidence.

VERSO Supply Chain Hub helps companies map these tasks into one central process. You can:

bring supplier and risk data together in a structured way,
assess and prioritize suppliers based on relevant risks,
automate requests and reminders,
continuously monitor risks,
manage prevention and remediation measures,
track responsibilities and deadlines,
and centrally document evidence and supplier communication.

This doesn’t create an additional standalone solution for the CSDDD. Requirements are embedded where supplier relationships are already managed.

Assess CSDDD requirements and implement them efficiently with us

Want to know which requirements are relevant for your company and how to integrate them into existing supplier processes?

In a no-obligation conversation, we’ll show you how VERSO Supply Chain Hub supports you with LkSG and CSDDD implementation.

Frequently asked questions about LkSG and CSDDD

What does CSDDD stand for?

CSDDD stands for Corporate Sustainability Due Diligence Directive. The EU directive is often referred to as the EU supply chain law and governs human rights and environmental due diligence obligations for large companies.

What is the CSDDD, simply explained?

The CSDDD requires affected companies to systematically identify and prioritize risks to people and the environment across their operations and business relationships. This must be followed by appropriate prevention or remediation measures and regular effectiveness checks.

What’s the difference between CSDDD and LkSG?

The LkSG is an already applicable German law. The CSDDD creates a common European framework that member states transpose into national law. Both regimes require, among other things, risk management, prevention and remediation measures, complaint procedures, and documentation.

Is the CSDDD already in force?

Yes. The CSDDD entered into force on July 25, 2024, and its scope was significantly reduced through the Omnibus package (Directive (EU) 2026/470, finalized March 18, 2026). Member states must transpose it into national law by July 26, 2028; the obligations apply uniformly to affected companies from July 26, 2029.

When do I need to implement the CSDDD?

Application starts July 26, 2029, for the largest companies. Germany has also decided on a one-to-one transposition of the CSDDD, combined with a restructuring of the LkSG. That doesn’t mean you should wait until then, though: since you’ll need a lot of information from your supply chain, you should start preparing your data foundation and processes well before that.

What changes for mid-market suppliers?

Mid-market companies generally aren’t directly covered by the CSDDD. They can, however, be indirectly affected when larger customers request information, evidence, contractual assurances, or improvement measures to meet their own due diligence obligations.

How do mid-market suppliers meet the requirements?

As a supplier, you demonstrate due diligence through self-disclosures on human rights and environmental risks within your own operations. This is supplemented by concrete evidence such as certificates, audit reports, or questionnaires that your customers may request. When risks are identified, this often leads to involvement in the customer’s prevention or remediation measures. Ideally, your customers set clear expectations and support you with targeted supplier development.

Which industries does the CSDDD affect?

The CSDDD applies across industries in principle. The specific need for action, however, depends heavily on supply chain structure, production countries, raw materials used, and the human rights and environmental risk profile.

What data do I need for CSDDD implementation?

You fundamentally need resilient supplier and site data. You’ll also need risk indicators by country or industry, evidence, and the status of measures on hand.

What does due diligence mean in the context of the CSDDD?

Due diligence means systematically identifying, prioritizing, and appropriately addressing risks and negative impacts on people and the environment. Companies must also enable complaints, monitor measures, and document implementation in a traceable way.

What does the CSDDD require for risk management?

Companies must systematically identify actual and potential negative impacts and prioritize them by severity and likelihood. Based on this, suitable measures must be defined, reviewed regularly, and adjusted as needed.

What complaint mechanisms does the CSDDD require?

Companies must establish appropriate procedures through which affected individuals, employee representatives, or relevant organizations can submit reports and complaints. These reports must be reviewed, handled, and factored into risk management in a structured way.

What happens in the event of CSDDD violations?

Violations can result in regulatory action and financial penalties. Companies also face liability, reputational, and business risks — for example, if customer requirements aren’t met or supply chain risks aren’t adequately addressed.

What changes does the CSDDD Omnibus bring?

The Omnibus package adjusted the CSDDD’s scope, individual requirements, and timeline. The core obligation remains, though: affected companies must establish a risk-based process for identifying, addressing, and monitoring human rights and environmental impacts.

What criticism has the CSDDD faced?

Critics point mainly to added administrative burden, high implementation costs, and indirect strain on smaller suppliers. Supporters, on the other hand, expect more consistent European standards, greater transparency, better protection for people and the environment, and more systematic risk management.

Which tools support CSDDD implementation?

Suitable CSDDD software connects supplier data, risk analysis, continuous monitoring, and measure management. Automated requests and reminders are also important, along with central documentation of evidence, deadlines, and supplier communication.

* This information is summarized editorial content and should not be construed as legal advice. VERSO accepts no liability.

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Mann mit Bart sitzt konzentriert vor mehreren Bildschirmen mit Datenübersichten und Diagrammen im Büro, sinnbildlich für die Recherche zum ESG-Software-Vergleich.

22.07.2026

ESG Software Comparison: What Mid-Sized Companies Should Look for When Choosing a Solution

Between spreadsheets and enterprise suites lies a broad field of ESG software that can be difficult to tell apart at first glance. This article breaks down what really matters and provides five questions to ask when comparing ESG software solutions.

In brief

The ESG software market has settled into roughly six categories, ranging from spreadsheets to specialized climate tools and supplier platforms to enterprise and all-in-one solutions.
The license fee is only part of the cost: onboarding, internal time investment, support, and scalability all factor into the true cost of ownership.
Support models vary widely, from pure self-service to hourly consulting to included expert customer support.
Anyone comparing ESG software today should check whether a solution will still fit as the regulatory landscape shifts, and whether their own data remains exportable in case of a switch.
Before deciding, it’s worth asking every vendor five specific questions covering support, pricing, target-audience fit, regulatory coverage, and cancellation flexibility.

What should you look for when comparing ESG software?

When comparing ESG software for the mid-market, you should consider more than just feature scope: what matters is broad coverage instead of isolated point solutions, cost transparency instead of cost surprises, expert guidance instead of pure tool operation, and mid-market suitability instead of enterprise complexity. Checking these four points during your comparison helps you avoid the most common purchasing mistakes.

Note: This article deliberately compares categories, not individual software solutions. Which provider within a category is right for you can’t be answered in general terms, the providers are simply too different for that. What can be answered in general terms is what you should look for when making your selection. That’s exactly what this article addresses.

In detail, this means:

Broad coverage instead of isolated point solutions

Companies using three separate tools for carbon accounting, supply chain management, and ESG reporting lose time on data reconciliation and quality control: data has to be maintained twice, and figures have to be checked manually against each other. This costs time and is prone to error. Software that centrally covers multiple requirements eliminates exactly this friction, provided that usability stays simple and clear despite the broader feature scope.

Cost transparency instead of cost surprises

What matters when comparing ESG software isn’t just the quoted price, but what it covers: Is human support included, or does every inquiry cost extra? Does the price stay fixed for the contract term, or can it change later? How does the price develop if you want to scale usage? Are there limits on users, data volume, or calculations? Clarifying these points before signing a contract helps you avoid unpleasant surprises after implementation.

Support as a success factor, not an add-on

Whether it’s CSRD (Corporate Sustainability Reporting Directive) reporting with its many data points, supply chain data and the supplier engagement it requires, or climate accounting with its demanding calculation logic: good software usability isn’t enough without expert guidance. This guidance should be part of the software offering, not something that has to be purchased separately at extra cost.

Mid-market suitability instead of enterprise complexity

Not every company has a ten-person sustainability team. What matters is clear processes, intuitive usability, and support that thinks along with you, rather than oversized setups and months-long implementation projects.

What types of ESG software are there?

The market has settled into roughly six categories of ESG software: Excel and manual processes as a starting point, specialized climate tools for corporate emissions accounting (Scope 1 through 3) or individual products (PCF, LCA), supplier platforms, pure reporting tools, enterprise solutions for complex corporate structures, and all-in-one platforms that centrally cover several of these areas. Which ESG software provider is the right fit depends primarily on how many ESG requirements you need to meet simultaneously and how much internal expertise you already have in-house.

The overview below shows which category covers which requirements:

Criteria	Excel / manually	Climate tools	Supplier platform	Reporting tool	Enterprise	All-in-One for mid-sized companies (e.g. VERSO)
Modules
Carbon accounting	No	Yes	No	No	Yes	Yes
Supply chain management	No	No	Partly	No	Yes	Yes
ESG report (CSRD/ESRS)	No	No	No	Yes	Yes	Yes
Materiality analysis	No	No	No	Partly	Yes	Yes
Target and action management	No	Yes	No	No	Yes	Yes
Suuitability
Suitable for mid-sized companies	No	Partly	Partly	Partly	No	Yes
For complex corporate structures	No	No	No	No	Yes	No
Usage without deep expert knowledge	No	No	No	Partly	No	Yes
Support and guidance
Expert guidance included in prize	No	Partly	Partly	Partly	No	Yes
Dedicated point of contact insetad of a ticketing system	No	Partly	Partly	Partly	No	Yes

The columns from Excel to Enterprise each describe the category as a whole – within each category, providers differ significantly. The right-hand column shows VERSO specifically as an example of an all-in-one platform. Details on this are in the “How VERSO Meets These Criteria” section.

Excel and manual processes are usually a good starting point, but not a long-term solution: without centralized data collection, the workload grows with every new regulation. Climate tools and supplier platforms each solve one problem very well, but naturally cover only a slice of your ESG requirements. Companies that need both areas require either two ESG software providers or a more broadly positioned solution. Enterprise solutions cover a lot functionally, but are rarely designed for lean teams. So the difference between categories shows up less in feature scope than in the question of who the solution is actually built for.

All-in-one platform or specialized point solutions: What fits when?

The rule of thumb is simple: if you only need to cover a single ESG area, a specialized tool is usually the better fit. Once two or more areas come into play at the same time, the calculation tips in favor of a centralized solution.

The reason lies less in feature scope than in the work in between. Two tools mean two data sets, two logins, two points of contact, and above all: manual reconciliation everywhere both systems need the same number. Your emissions data from the climate tool has to end up in the report, and so does your supplier data. This reconciliation is invisible work that appears in no proposal, but comes up every month.

The case for specialized point solutions:

a clearly defined use case, deeper functionality within the given specialty, and often a faster start.

The case for a centralized solution:

one data set instead of several, no reconciliation work at the interfaces, one point of contact instead of several, and the option to add further areas later without switching systems.

What we observe at VERSO:

Across several hundred mid-market projects, a recurring pattern emerges. Most customers come to us driven by regulation and for exactly one use case: one because of CSRD reporting obligations, the next because of due diligence obligations under the Supply Chain Due Diligence Act (LkSG). A year or two later, they’re often affected by additional requirements, such as packaging requirements under the PPWR or customer requests for CO₂ footprints on individual products. The use case a company buys for is rarely the one it actually has a few years later. Companies with multiple areas on one platform can cover such new requirements directly, instead of adding a second tool alongside the first.

The condition for mid-sized companies: a broader solution has to stay manageable despite its larger feature scope. A platform that can do everything but that nobody on the team wants to use doesn’t solve a problem, it just shifts it.

For your ESG software comparison, this means: the question isn’t just how many areas you need to cover today, but how much effort it becomes when another one is added tomorrow. This exact simultaneity of multiple requirements is described by one VERSO customer:

With VERSO, we can strengthen our own ambitions for sustainable development and at the same time meet increasing external requirements such as the LkSG and CSRD.

Marieke Köhler

Head of Corporate Responsibility at Borussia Dortmund

What should you look for in ESG software pricing?

The license fee is only part of the actual cost of ESG software. Anyone who only compares quoted prices when evaluating ESG software often overlooks the bigger cost items, especially the internal effort that arises after signing the contract.

You should factor in the following cost blocks:

License/subscription costs: the actual software price, usually tiered by feature scope or company size
Onboarding & implementation: effort for initial setup, data migration, and integration with existing systems
Internal time investment: data preparation, training for specialist departments, ongoing maintenance
Expert guidance & support: often the most underestimated item: either included in the price or offered as expensive add-on consulting
Scaling: additional costs when new modules or locations are added

The more of these blocks are already included in the ESG software provider’s license price, the more predictable the project becomes, and the fewer surprises there are after implementation.

Two questions bring more clarity in a sales conversation than any price comparison: What does the solution cost over the entire planned contract term, not per month? And: Which items can change later, and under what conditions? Software providers who can answer these concretely will spare you uncomfortable conversations in later years.

What role does support play in an ESG software comparison?

The market broadly breaks down into three support models. Which one you get has more influence on implementation speed than the software’s usability itself.

Pure self-service

You get access to the software. You have to acquire or already bring the expertise needed to work through ESRS (European Sustainability Reporting Standards) data points, supplier communication, or the calculation logic behind a climate footprint yourself. The ESG software provides the tool, not the expertise behind it.

Hourly consulting

The software alone covers usability, while expert guidance can be booked as a separate, usually paid consulting package. This can make sense if you need occasional expert support, but quickly becomes expensive if questions come up regularly.

Expert guidance included

Support is part of the license price, often with a dedicated point of contact. For teams tackling reporting, supply chain due diligence, or climate accounting for the first time, and without their own ESG department, this significantly shortens the time to a first reliable result. One VERSO customer describes how this plays out in practice:

With the automated risk analysis and the professional support, we can efficiently meet the requirements of the LkSG as well as other regulations.

Michelle Dietrich

Product Management at dennree

None of the three models is inherently wrong. What matters is that it fits your internal capacity. A team without ESG experience is often overwhelmed by pure self-service, while an experienced team may end up paying for included guidance it doesn’t actually need.

What ESG software meets all requirements?

The regulatory framework for ESG is in motion overall: the 2025 Omnibus package reshaped reporting obligations, the EUDR was postponed in the supply chain space, and product and packaging requirements keep evolving as well. So when choosing ESG software today, the question shouldn’t be “Does it meet current requirements?” so much as “What happens when requirements change or new ones are added?”

Three points are decisive here:

Who keeps up with changes? Does the provider automatically update standards, data points, and templates, or do you have to keep track yourself and trigger the changes?

Does the solution hold up even without a mandate? Even companies without a direct reporting obligation receive ESG questionnaires from customers, banks, and insurers. The trigger shifts from regulation to the supply chain, but the data requirements remain. A solution built only around the mandate falls short here.

Is your data actually yours? Clarify server location, GDPR compliance, and export formats before signing a contract. What matters is that you can fully export your data in a common format at any time, otherwise switching providers becomes practically impossible, regardless of what the contract says about the notice period.

5 quiestions to ask every ESG software providor (including us)

The following five questions can be asked of any provider during an ESG software comparison, and they cover the four key criteria: broad coverage, cost transparency, expert guidance, and mid-market suitability.

What does post-purchase support actually look like? Is there a dedicated point of contact and active help with onboarding, or do inquiries end up in a general support inbox?
What’s included in the price, and what costs extra? Clarify before signing what gets billed separately as an add-on service.
Is the solution built for teams without a large ESG department? Ask specifically for references from companies of similar size and team structure.
How does the software provider handle new regulatory requirements? Are changes automatically rolled out in the ESG software, or do you have to keep track yourself?
How flexible is cancellation, and what happens to your data if you switch? Long minimum contract terms and burdensome data export make switching difficult after the fact.

How does VERSO’s ESG software meet the four criteria from this comparison?

Measured against the four criteria, broad coverage, cost transparency, expert guidance, and mid-market suitability, VERSO’s ESG software can be assessed as follows:

Broad coverage instead of isolated point solutions

With ESG Hub, Climate Hub, and Supply Chain Hub, VERSO brings together reporting, climate accounting, and supply chain management, so data doesn’t need to be reconciled across multiple tools. Across all three areas, this has produced several thousand climate footprints, sustainability reports, and supply chain risk analyses over more than 15 years.

Cost transparency instead of cost surprises

The price is fixed and calculable for the entire contract term, with human support already included in the license price. Additional consulting services from our Consulting team can be booked separately if needed.

Support als Erfolgsfaktor

Customers get a dedicated Customer Success team instead of a general ticketing system, complemented by built-in guides on PCF and CCF calculation, on reporting standards like ESRS, GRI, and the SDGs, and on regulations like EUDR, PPWR, CBAM, CSRD, and more, right inside the software.

Our customers highlight exactly this combination of experts and software in their feedback:

With its software and its consulting and customer success team, VERSO is a reliable partner on our way to the finished sustainability report.

Auris-Nadine Hillen

Sustainability Manager at PROTEGO®

Mid-market suitability instead of enterprise complexity

VERSO has been focused on mid-sized companies since 2010, is usable even without an existing ESG department or prior expertise, and grows alongside your requirements thanks to its modular structure.

Where another solution might be a better fit: VERSO’s ESG software is deliberately built for the mid-market, though the platform can also be used by larger companies. This focus shows up mainly in who benefits most from it: teams without a large ESG department gain the most from its guided, easy-to-understand usability. Companies that already have many in-house experts for individual sustainability topics, or that need to map very complex, far-reaching corporate group structures, may do just as well with a specialized enterprise solution and may need VERSO’s deliberate simplicity less.

How do I find the right ESG software for my company?

Finding the right ESG software is less about the largest feature scope and more about the right fit for your company. Approach your ESG software comparison in this order:

Clarify your needs before you look at providers: which ESG areas do you actually need to cover, both today and over the next two years?
Narrow down the category first, not the provider. One area points to a specialized tool, several point to a centralized solution.
Examine costs and the support model in detail, both have a bigger impact on project success than feature scope.
Ask every provider the five questions from this article and compare who answers concretely and who deflects.

This makes it easy to quickly narrow down which solution truly fits your team size and requirements, and which one only looks convincing at first glance.

Frequently asked questions about comparing ESG software

Do I actually need ESG software as a mid-sized company, or is Excel enough?

For getting started with a small number of data points, Excel is often enough. Once reporting obligations, multiple departments, or supply chain data come into play, manual maintenance quickly becomes error-prone and time-consuming. That’s when a centralized solution pays off. A good indicator: if you’re maintaining the same number in more than one place, you’re already working against your tool.

What makes ESG software expensive, and how can I spot that in advance?

It’s not the license, it’s what isn’t listed: onboarding, internal time investment, paid inquiries, and surcharges for additional modules or locations. So ask about the total price over the planned contract term rather than the monthly price, and get it in writing which services are included and which are billed separately.

How long does implementing ESG software typically take?

This depends heavily on feature scope and the state of your company’s data. As a rough guide: lean, specialized solutions are often ready to use within a few weeks, while large enterprise systems, especially when multiple data sources need to be merged, can require several months of preparation. During the selection process, ask specifically for a realistic timeline for your use case and which preparatory work will remain in-house.

What’s the difference between ESG software and an ESG rating tool?

ESG software supports you with internal management of your sustainability data, from collection through to reporting. A rating tool, by contrast, evaluates your company from the outside and assigns a score, usually on behalf of your customers or investors. A good rating is generally the result of solid internal management, not a substitute for it.

Is all-in-one ESG software better than several specialized point solutions?

Companies that only need to cover a single ESG area are often well served by a specialized tool. Once multiple requirements exist simultaneously, a centralized solution saves time at the interfaces between systems, provided it stays manageable despite its larger feature scope. What matters isn’t the category itself, but whether the number of your requirements justifies the coordination effort between two systems.

Do I still need additional external consulting despite having ESG software?

If expert guidance is already included in the license price, that covers most ongoing questions. With pure self-service, or for occasional specialized topics, such as a particularly complex materiality assessment or industry-specific edge cases, additional consulting can still make sense. At VERSO, ongoing guidance through a dedicated Customer Success team is included in the price; in-depth consulting can be booked separately if needed.

Can ESG software grow with my company as requirements change?

Before choosing a solution, check whether additional areas like supply chain management or climate accounting can be added later without switching to an entirely new system. Also ask what that would cost. Modules added later are the most common reason a price changes over the course of a contract.

Where is my ESG data stored, and who owns it?

Clarify server location, GDPR compliance, and export formats before signing a contract. What matters is that you can fully export your data in a common format at any time. If export is cumbersome or incomplete, switching providers becomes practically impossible, no matter how short the contract’s notice period is.

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Graphic of a Product Life Cycle which ist monitored within a LCA, PCF and EPD

02.07.2026

LCA vs. PCF vs. EPD: What Are the Differences and When Do You Need Which Tool?

LCA vs. PCF vs. EPD: Anyone working with product environmental impact will quickly come across these three abbreviations. But what do they mean? When does each tool make sense? This article gives you an overview. Plus: What role does the CCF play?

LCA vs. PCF vs. EPD: an overview

Before we take a closer look at each tool for calculating and presenting product environmental impact, we want to give you a brief overview in table form. This way, you can see at a glance what to consider when comparing Product Carbon Footprint vs. Life Cycle Assessment vs. Environmental Product Declaration.

	PCF	LCA	EPD
Written out	Product Carbon Footprint	Life Cycle Assessment	Environmental Product Declaration
What does it measure?	Greenhouse gas emissions from a product, expressed in CO₂e	Multiple environmental impacts: climate, water, resources, acidification, land use, and more	A product environmental profile, third-party verified and published
Standard	ISO 14067	ISO 14040, ISO 14044	ISO 14025, EN 15804 (construction)
Verification	Optional	Optional	Mandatory third-party verification
Impact scope	Climate	Multiple impact categories	Multiple, depending on the product category

LCA vs. PCF vs. EPD: the tools briefly explained

Let’s now take a closer look at PCF, LCA, and EPD. PCF, LCA, and EPD all describe product environmental impacts, but in different ways. One measures only climate impact, another covers a whole set of impacts, and the third presents results in a publicly comparable format. If you mix them up, you may end up providing too much or too little. Here are the three in detail:

Product Carbon Footprint (PCF)

The Product Carbon Footprint (PCF) measures only a product’s greenhouse gas emissions, expressed in CO₂e. The established standard here is ISO 14067. A PCF is especially useful when customers ask for specific CO₂ values, CBAM data is required, or a climate hotspot needs to be identified. By the way: The PCF should not be confused with the Corporate Carbon Footprint, which refers to the entire company. However, the PCF can feed into the CCF.

Life Cycle Assessment (LCA)

When it comes to LCA vs. PCF, one thing is clear: the Life Cycle Assessment goes far beyond the PCF. It looks not only at climate impact in the form of emissions, but also at water consumption, resources, acidification, and land use. Common standards here include ISO 14040 and ISO 14044. When deciding between Product Carbon Footprint vs. Life Cycle Assessment, the LCA is especially useful when you want to make product decisions across several environmental impacts, for example in redesign or material selection.

Environmental Product Declaration (EPD)

When comparing LCA vs. PCF, the EPD also comes into play. An Environmental Product Declaration is a third-party verified, public document based on an LCA. The classic standard for this is ISO 14025, while construction products, for example, are also subject to EN 15804. An EPD is often necessary when you want to communicate environmental data externally — in tenders, for building certifications, or to customers who require verified comparability.

Put simply: The LCA is the comprehensive method for calculating product environmental impact. The PCF is the climate-related part within the LCA. And the EPD is the verified format for public communication.

And the CCF?

The Corporate Carbon Footprint (CCF) does not quite fit into the LCA vs. PCF vs. EPD comparison because it does not look at a single product, but at greenhouse gas emissions from an entire company. It is calculated across Scopes 1, 2, and 3 based on the GHG Protocol, from office heating to the supply chain. PCF and CCF complement each other: product data from the PCF can feed into the Scope 3 part within the CCF. You can learn how to calculate your Corporate Carbon Footprint in our blog post on the CCF.

LCA vs. PCF vs. EPD: Which one do you need when?

Whether a PCF is enough or whether you need an LCA or EPD depends on the reason behind the request: Who is asking, what are the data needed for, and what format must the results ultimately take? This is a good way to determine whether a PCF is sufficient, an LCA is necessary, or an EPD is required. Three questions usually lead you to the answer quickly:

1. Who is asking, and for what purpose?

If the request comes from a customer’s procurement team, it is usually about CO₂ data for that customer’s own Scope 3 inventory or supply chain reporting. A PCF is sufficient. If it is about a public tender or building certification, an EPD is usually required. If it is about internal product decisions, an LCA provides the more robust basis.

2. Is a CO₂-only view enough, or do several environmental impacts need to be considered?

For CBAM, decarbonization strategies, and most customer requests, the PCF is sufficient. Anyone comparing materials, rethinking packaging, or assessing circular solutions will not get far with climate data alone. In those cases, the LCA is the right tool.

3. Do the data need to be publicly comparable in a standardized format?

Not for internal management and most customer requests. But they do for tenders, building certifications, or market communication where products are directly compared. This is exactly where the EPD shows its strength: uniform product category rules make products within the same category truly comparable.

How are PCF, LCA, EPD, and CCF connected?

In brief:

LCA vs. PCF is actually the wrong framing, because the PCF is part of the LCA: the LCA covers several environmental impacts, while the PCF focuses on greenhouse gas emissions.
And the EPD is not a fully separate tool either. The EPD brings LCA results into a standardized, public format.
The CCF sits one level higher, at company level. PCF and EPD provide product data for its Scope 3 inventory.

LCA vs. PCF vs. EPD: How are the tools for calculating product environmental impact connected?

PCF, LCA, EPD, and CCF do not simply stand side by side; they build on each other. The LCA is the method behind the scenes: it assesses a product’s environmental impacts across its entire life cycle. The PCF is one impact category within the LCA, namely global warming potential, expressed in CO₂e. The EPD, in turn, presents LCA results in a standardized, third-party verified, and public format.

The CCF looks at a different level: not a single product, but company-wide emissions across Scopes 1, 2, and 3. This is where the connection to the product closes the loop, because product data from the PCF can feed into the Scope 3 part within the CCF.

One data foundation for PCF, LCA, EPD, and CCF

PCF, LCA, EPD, and CCF do not compete with each other; they answer different questions. Which tool you need depends on the occasion, and over time you will often need several of them: a PCF for a customer today, an LCA for a redesign tomorrow, and later an EPD for a tender. The better you understand the differences, the more precisely you can deliver what is needed without wasting effort.

What connects all four is the data behind them: they rely on largely the same product data or build on one another. Once you have reliably collected a product’s CO₂ value, you have already completed a large part of the work needed for the LCA, and those results in turn form the basis for an EPD. The real effort rarely lies in the individual proof point, but in building a robust, traceable data foundation. If the data is scattered or incomplete, every new request starts from scratch. If it is well-structured and available, the right proof point can be derived depending on the occasion.

This is exactly where the VERSO Climate Hub comes in: It brings product calculations, from PCF to LCA, together on one shared data foundation.

Let’s talk about your products’ environmental impact.

* This information is summarized editorial content and should not be construed as legal advice. VERSO accepts no liability.

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18.06.2026

10 CSRD Tips for
ESG Managers

“CSRD – what exactly do we need to do?” Many companies are faced with this question. The scope of the reporting obligation and the associated ESRS standards is very challenging. Don’t lose your nerve right away – these 10 CSRD tips will help you get started.

10 CSRD tips from our experience

Taking a first look at the requirements of the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS)—or their revised version, the ESRS Simplified—can certainly raise a sustainability manager’s pulse. The CSRD is challenging, no question, but that’s hardly a reason to panic! Here are 10 CSRD tips to help you as you tackle Europe’s reporting obligation for the first time.

CSRD tip 1: Take a closer look at the ESRS reporting standard

To understand the scope and requirements that the CSRD places on your sustainability report, it’s important to have at least a rough overview of the framework, the ESRS. Don’t worry, you don’t have to read and understand every single data point to do so. The best place to start is by reviewing how an ESRS report is structured. If you’d like to learn more about the revised ESRS, you’ll find everything you need to know in our article on the ESRS Simplified. And if you do want to dig deeper, you can download all ESRS standards in their original version on EFRAG’s website.

CSRD tip 2: Build the resources and know-how for your CSRD project

The CSRD is a major undertaking, not a one-off project. A single sustainability manager often isn’t enough. When preparing your report, you’ll work in close coordination with HR, IT, Finance, Procurement, Risk Management, and other departments. Foster strong, efficient collaboration and take a realistic look at the to-dos: What resources do we need for implementation? Are additional skills or training necessary? Do we need to hire someone? And if it comes down to a lack of know-how: the VERSO Academy is sure to offer the right training for you. Regular courses and workshops also sharpen awareness of sustainability throughout the organization. Bring other departments on board and keep everyone involved informed about the latest requirements.

CSRD tip 3: Plan the process in detail

Several steps in CSRD reporting require a great deal of time, a lot of coordination with internal stakeholders, or both. That’s why it’s essential to keep your process realistic and forward-looking. Be sure to factor in buffer time, too—and feel free to plan a little generously. Keep the following milestones in mind:

When do we want to publish the report?
Are there any time constraints we need to consider (vacations, other projects)?
When will we write the report?
Who needs to be brought into the process, and when?
When will we collect the data?
When will we carry out the double materiality assessment?
When do we need to start?

Well-defined, proven workflows lead to faster data collection and reduce the risk of errors. Regularly reviewing and adjusting these processes ensures they hold up even as requirements increase. So those who invest early in clean processes can meet their regulatory obligations far more efficiently and quickly over the long term.

You also need to be aware: data collection in particular is a real time drain. People often underestimate how long it takes to gather the essential information. Don’t forget that for many departments in your company, your request comes on top of their actual day-to-day work. And with business partners and suppliers, you should also allow some time for their responses.

One more tip on this: calculate your deadline “from back to front”! First, determine when the sustainability report should be published—in the case of the CSRD, alongside the management report. From there, work backward through the individual steps—drafting the text, collecting the data, and conducting the double materiality assessment—until you reach the starting point. Add a little buffer for each task, and you’ll know the latest possible date to begin.

CSRD tip 4: The double materiality assessment, the cornerstone of your CSRD report

The foundation of a CSRD report is the double materiality assessment. Materiality assessments have been around for a while, but the principle of double materiality—used to identify the sustainability topics relevant for reporting—only became mandatory with the CSRD. For this, the ESRS prescribe a specific process that must be documented. Here it pays to ask yourself some critical questions: How do we stand in terms of knowledge and capacity for the materiality assessment? Can we manage it in-house, or do we need external help?

The double materiality assessment forms the basis for your data collection, your CSRD sustainability report, and your ESG management. That’s why it deserves special attention. Mistakes can lead to missing or inaccurate data. A substantive assessment, on the other hand, guides you purposefully through the reporting process.

Our experience shows that bringing in external consultants is definitely helpful—if only to draw on their experience when evaluating and selecting topics. Whatever you decide, we’ve outlined the process for the assessment here. You’ll also find a good overview of the methodology in EFRAG’s Implementation Guidance and in the supporting documents from the DNK (German Sustainability Code). Our AI-powered software solution offers valuable support for the double materiality assessment as well, saving you time in the process.

CSRD tip 5: Optimize data collection with digital tools

You’ll need lots and lots of data for your CSRD-compliant sustainability report. That quickly raises the question: How do we collect the data? Set up a process that’s as seamless as possible. And then: Where do we collect the data? Yes, it could be an Excel list — but experience shows those quickly become unwieldy. You’ll find yourself scrolling back and forth between individual data points for ages. It’s a nerve-wracking exercise you’d be wise to avoid. Our recommendation: use a sustainability software instead.

Software-supported reporting is easier, more effective, and more data-driven. And we’re not just saying this from our own experience — EFRAG points it out as well.

Digital tools, especially those with AI support, help you standardize processes and ensure that all material data is captured and processed correctly.

CSRD tip 6: Identify data sources and assign responsibilities

Reporting is teamwork: implementing the CSRD calls on a wide range of areas across the company, not just sustainability managers. Identify your contacts within the teams early on, bring them on board, and clarify responsibilities. We’ve summarized which teams are involved in the CSRD, why, and how in a graphic.

When it comes to data collection in particular, it’s not only important to know which information the CSRD requires, but also who—or which department—can provide it. So build out your processes and communication channels and define clear responsibilities. This creates clarity, avoids delays, and ensures that data collection runs efficiently and smoothly in the future as well.

In the VERSO ESG Hub, for example, you can assign responsibilities for each topic. Every year, when data collection starts up again, each person in charge can enter their data directly into the tool.

CSRD tip 7: Use a gap analysis to identify and close data gaps

Has your company already published a sustainability report? Is it based on a standard such as GRI or the DNK? Then you already have a solid foundation to compare against the CSRD requirements.

Conduct a gap analysis and find out which data you reported in previous years, whether it aligns with the ESRS formulas, and which data is still missing. This tells you which processes already exist and which data collection efforts still need to be established or adjusted.

That said, you can also carry out a gap analysis without a prior report. In that case, you start by reviewing which data you already have available, and then determine where there’s still room for improvement.

CSRD tip 8: Check your data for reliability

High data quality is the key to a CSRD-compliant sustainability report. That’s why it’s important to set up internal control systems that work similarly to those used in financial reporting. These controls ensure that your ESG data is accurate, complete, and reliable. Data quality plays a central role especially with a view to the external assurance required under the CSRD.

To ensure high data quality, you should prepare thoroughly and read the disclosures in the standards carefully. There you’ll find the Application Requirements (AR), which provide detailed instructions. They specify how certain information must be disclosed or measured.

CSRD tip 9: Take a strategic view of sustainability

The CSRD actively asks for a sustainability strategy—you need a policy for each individual material sustainability matter. Beyond that, you must show how sustainability is embedded in your corporate strategy.

So don’t get lost in the reporting tunnel: think of sustainability as part of your corporate strategy from the very beginning, and plan the appropriate resources for it. Not only your CSRD report, but also the future viability of your company, will thank you for it!

CSRD tip 10: Learn from mistakes and from other reports

Many companies have already published a CSRD report. You can learn from them and get a sense of what your own report might look like. That said, every company is so unique that you can’t follow any one of these reports step by step. Each report did different things well.

But here’s a spoiler: the CSRD report will likely sit closer to the financial report than most previous reporting under GRI or the DNK. There’s currently a lot of discussion about which direction sustainability reporting will take.

Now to your own report: your first report doesn’t have to be perfect either—you need to understand and accept that. To start with, it’s about establishing efficient data collection under the CSRD and setting up new processes or improving existing ones. Don’t try to force in descriptions of concepts and measures you haven’t yet introduced. Instead, set yourself a target for when you intend to publish the corresponding data, and communicate that openly in your report.

Dos & don’ts for your CSRD report

Dos:

Structure your sustainability reporting clearly:
define clear responsibilities for reporting processes, data delivery, review, communication, and so on—much like in financial reporting.
Involve internal and external experts:
run workshops and interviews to gather well-founded input, especially for your material topics.
Communicate the scope, goal, and purpose of the report both internally and externally:
a shared understanding of the CSRD reporting obligation promotes consistent data quality and a coherent, readable report.

Don’ts:

Avoid aggregating your data too heavily:
if you summarize data, processes, and descriptions too broadly or briefly, relevant information can get lost.
No purely subjective assessments:
greenwashing is a thing of the past—the CSRD demands evidence for your claims. Always back up qualitative information with data-based proof.
Don’t report superfluous data points:
avoid including more data points than necessary, as this can distract from the information that matters.

Our bonus CSRD tips:

Finally, we have two bonus CSRD tips for you: How should the process of creating a sustainability report be optimized? The guide with 7 steps to the sustainability report will help you. And if you want to delve deeper into CSRD reporting, we have a comprehensive guide for you: CSRD practice guide.

More CSRD tips needed? Contact us here.

* This information is summarized editorial content and should not be construed as legal advice. VERSO accepts no liability.

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Meeresschildkröte, die durch Plastikmüll schwimmt: Mit der neuen EU-Richtlinie gegen Greenwashing sollen solche Bilder seltener werden

10.06.2026

From the Green Claims Directive to EmpCo: The New Rules Against Greenwashing Starting September 2026

Green claims directive & EmpCo: Tools against greenwashing

The Green Claims Directive was intended to establish clear, EU-wide rules against greenwashing, but it was withdrawn in June 2025. Instead, EmpCo becomes binding. As a result, new requirements take effect on September 27, 2026, governing which environmental claims companies are still permitted to make. In this article, we provide an overview of the developments surrounding greenwashing regulation and take a closer look at the requirements introduced by the new EmpCo.

Many environmental claims do not hold up to scrutiny

In January 2023, DIE ZEIT and The Guardian published an investigation into Verra, the leading provider of carbon credits. According to their findings, a portion of the emission credits that companies used to offset their greenhouse gas emissions did not deliver real reductions. A study by the European Commission painted a similar picture: more than half the environmental claims made by companies in the EU were vague or misleading, and roughly 40% were entirely unsubstantiated. Many green labels are of little help either, since half of them are barely verified, if at all.

The result is something most people know from their own experience: consumers can barely tell which claim actually delivers on its promise. And companies that properly substantiate their statements get lost in the jungle of labels and claims.

The green claims directive was meant to adress this, but It’s off the table

On March 22, 2023, the EU Commission presented a draft of the Green Claims Directive (GCD). It was intended to require companies to substantiate their environmental claims scientifically, have them independently verified, and communicate them transparently.

But it didn’t get that far. In June 2025, the EU Commission withdrew the proposal after it lacked a majority in the trilogue and, among others, Italy and the EPP withdrew their support. The main criticism centered on the anticipated bureaucratic burden and the planned inclusion of micro-enterprises.

Anyone breathing a sigh of relief now, however, is mistaken. The Green Claims Directive is not the only regulation against greenwashing, just the best known. The requirements that will actually affect companies starting in fall 2026 have long been settled.

What is now binding: The EmpCo directive

The Empowering Consumers Directive (EmpCo, an EU directive) already entered into force on March 26, 2024. Member states had to transpose it into national law by March 27, 2026, and it must be applied as binding law starting September 27, 2026. In Germany, implementation takes place through an amendment to the Act Against Unfair Competition (UWG).

EmpCo regulates much of what the Green Claims Directive set out to do, just through a different mechanism: not through a new verification procedure, but through existing competition law. Certain environmental claims will henceforth be considered inherently unfair. This means there is no longer any need for a case-by-case assessment of whether a claim is misleading, it is simply prohibited.

Which claims EmpCo prohibits starting September 2026

EmpCo identifies four categories that will no longer be permitted without solid evidence:

General environmental claims without recognized proof of performance
Terms such as “environmentally friendly,” “green,” “eco,” “sustainable,” “climate-friendly,” or “biodegradable” may only be used if backed by recognized, outstanding environmental performance. This also applies to implicit claims: green leaves, globe symbols, or water droplets on packaging likewise fall under this rule if they suggest an environmental benefit that is not substantiated.
Carbon-neutrality claims based on offsetting
Statements such as “climate-neutral” or “carbon-neutral” that rely on purchased credits are no longer permitted. Climate-related claims must refer to real emission reductions within the company’s own value chain.
Self-created sustainability labels
In-house “eco” or “green” logos without an independent basis are prohibited. Only labels based on a system recognized by authorities or certified by independent third parties remain permissible.
Whole-product claims for a partial aspect
Anyone who prints “made with recycled material” on a product when only the packaging is meant leaves themselves open to challenge. The precise version that transparently states the scope remains permitted, for example, “packaging is made from 90% recycled PET.”

One important point here: forward-looking promises such as “climate-neutral by 2030” are not prohibited outright, but they are subject to conditions. They must be based on a measurable, verifiable implementation plan and monitored by an independent body.

Who does EmpCo apply to?

The directive affects all companies that market products or services to consumers in the EU, regardless of size, revenue, or industry. Manufacturers based outside the EU are also covered as soon as they target EU end customers. Unlike the Green Claims Directive that was under discussion, EmpCo does not exempt micro-enterprises.

What’s at stake for violations of EmpCo

Advertising with unsubstantiated environmental claims will be subject to cease-and-desist actions and can be penalized with fines. In the case of serious violations, fines of up to 4% of annual revenue in the member state concerned are possible. On top of this come reputational risks: a publicly challenged claim often damages credibility more than any fine.

This is not an entirely new risk, by the way. Back in June 2024, the Federal Court of Justice ruled that advertising a product as “climate-neutral” without explaining whether this is based on avoidance or offsetting is misleading. EmpCo merely makes enforcement considerably easier starting September 2026.

What you should do now

The deadline for implementing EmpCo is no longer far off. Anyone planning product packaging, campaigns, or website copy with a longer lead time is already working today on material that will go live in September 2026.

Three steps are worth taking now:

Claim inventory: Which environmental claims are you currently using—on packaging, your website, in advertising, and in your sustainability report?
Evidence mapping: For each claim, check whether solid evidence exists and where it is located.
Approval process: Define who signs off on an environmental claim before it is published, so that marketing, legal, and sustainability work together.

The core principle remains simple: you may only claim what you can prove. And that requires a solid data foundation. Greenwashing rarely stems from intent. It usually arises when sustainability is communicated without a sound data basis.

We support you with your sustainability communication

Solid claims require solid data. With the VERSO ESG Hub, you capture your sustainability data in a structured and traceable way, from the data source through to the reporting basis. This makes it possible to demonstrate what each claim is based on. For the communication itself, our Sustainability Consultants support you. They help you publish meaningful information while staying truthful, whether in your sustainability report or in other internal and external formats.

Please write to us. We can help you.

* This information is summarized editorial content and should not be construed as legal advice. VERSO accepts no liability.

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09.06.2026

Sustainable Development Goals (SDGs): What the Sustainability Goals Mean for Companies

This overview tells you everything you need to know to put the Sustainable Development Goals (SDGs) into context for your company.

Sustainability: Licence to operate

Customers, employees, and other stakeholders are asking about the societal, social, and environmental impacts your business activities have. It is becoming increasingly clear that corporate sustainability is turning into a “license to operate.” ESG management therefore needs to be approached (more) strategically, or even for the very first time. This article explains how the Sustainable Development Goals, or SDGs, can help you do exactly that.

Whenever the implementation of sustainability in companies is discussed today, the United Nations Sustainable Development Goals (SDGs) are a firm part of the agenda. This framework helps to shape ESG management strategically within a company. At the outset, however, it is often unclear how the SDGs can actually be operationalized and integrated into a company’s sustainability strategy.

In this overview article, you will learn everything you need to know to put the Sustainable Development Goals (SDGs) into context for companies for the first time. We introduce the origins of the SDGs as well as the role companies play. Above all, though, we give you answers to one key question: How can your company become a proactive part of sustainable development? But let’s start at the beginning.

The history of the SDGs: From the Brundtland report to the 2030 agenda

The debate around the sustainable development of society, the economy, and the environment, which reached a broader public with the publication of the so-called Brundtland Report “Our Common Future” in 1987 (World Commission on Environment and Development), remains as relevant today as ever. Over several stages of development, the global objectives of this debate have found their way into the Sustainable Development Goals (SDGs) published by the United Nations.

Sustainable Development Goals today: Current status of the SDGs and their relationship to the CSRD

Adopted in 2015, the SDGs are now ten years old, and the midpoint assessment is weak. According to the Sustainable Development Report 2025 and the 2025 UN progress report, not a single one of the 17 goals is on track to be achieved globally by 2030. Fewer than one in five targets is on schedule. Progress is being made primarily on foundational issues such as health and access to electricity, while the structurally difficult goals are lagging behind.

For companies, the role of the SDGs has shifted during this period. Today they serve above all as an understandable, communicable framework: 17 goals, memorable icons, recognized worldwide. This makes them useful for putting your own sustainability work into context and telling its story, whether in reports, on your website, or in your strategy. This connection is still frequently seen.

Actual management, however, now runs through other instruments. The CSRD and ESRS, along with supply chain laws ranging from the LkSG to the CSDDD, the EUDR, and CBAM, now set the pace. These requirements are mandatory; the Sustainable Development Goals are not. Referencing the SDGs alone is therefore no longer a hallmark of a frontrunner. It has largely become standard, and without robust data to back it up, it quickly starts to look like greenwashing.

The SDGs after 2030: What comes next for the UN sustainability goals?

As the name suggests, the 2030 Agenda expires in 2030. This raises the question of what comes next, and the discussion about it has already begun. At the SDG Summit in September 2027, official negotiations on the post-2031 framework will begin, prepared in part by the Pact for the Future adopted in 2024.

A complete break is not to be expected. Most countries are sticking with the Sustainable Development Goals. What is more likely to be added are additional focus areas such as digital cooperation, the handling of artificial intelligence and data, or intergenerational equity. The SDGs are therefore more likely to be sharpened than replaced.

For companies, this changes little about the actual task at hand. Anyone who builds a clean data foundation and clear responsibilities now will also be well positioned for an adapted framework from 2031 onward. The effort pays off through robust ESG data, not through the SDG logo in a report.

SDGs and companies: What role the economy plays

This also establishes a framework that defines companies as important actors in sustainable development and offers them support in implementing measures at the regional and operational level. The SDGs emphasize the need for active participation by private companies and appeal to their creativity and innovation to create value for the common good. This includes, for example, reducing poverty, eradicating hunger, and protecting biodiversity.

The United Nations 2030 Agenda and its 17 Sustainable Development Goals present companies with the new challenge of aligning their operations and strategies with the requirements of the SDGs.

Tackling the Sustainable Development Goals (SDGs) in your company

So what exactly do you need in order to meaningfully dedicate yourself to the Sustainable Development Goals and to sustainability in general? Two foundational pillars are decisive to begin with:

Organizational and substantive responsibility assigned to an ESG/sustainability officer.
A single place to consolidate all sustainability-relevant data.

Without these two basic prerequisites, it is virtually impossible for an organization to engage further with the topic.

But even with clear substantive responsibility and consolidated data, tackling the Sustainable Development Goals strategically is a task that should not be underestimated and that must be designed on a highly individual basis, depending on company size, industry, and stakeholders.

Consulting firms in the field of sustainability and sustainability reporting, including us here at VERSO, therefore support companies and ESG managers with practical advice every step of the way.

Implementing the Sustainable Development Goals (SDGs) with the GRI and the UN Global Compact

Various internationally recognized guidelines are available to achieve the implementation of the SDGs and their sub-targets within companies’ supply chains. Two of them:

the Global Reporting Initiative (GRI)
the UN Global Compact

Both guidelines propose indicators and key figures for measuring companies’ sustainability performance for each of the UN Sustainable Development Goals. Companies can therefore work toward implementing the global development goals by taking the route of adopting the GRI indicator system.

How seriously do companies really take the SDGs?

Some companies already integrate the SDGs deeply into their sustainability strategy and underpin them with concrete indicators and data. For many others, the connection remains superficial. This commitment is usually related to a company’s commitment to other sustainability-related topics, as well as to its size and level of sustainability maturity.

From this, one can conclude that commitment to the Sustainable Development Goals stems partly from regulatory reasons, where existing laws are simply being followed. On the other hand, there are often institutional reasons behind such commitment. A qualitative review of individual sustainability reports shows that company participation is largely symbolic and not yet substantial. This suggests that many companies regard the SDGs—much like the Global Compact—as a framework with non-binding implications.

Conclusion: Why the Sustainable Development Goals remain a useful tool

Despite all the shift toward the CSRD and the like, the SDGs have not lost their value. They give sustainability work a tangible framework, help with prioritization, and create a common language for explaining commitment both internally and externally. That is precisely what they are still good for.

What they do not provide is binding management. That requires robust data, clear responsibilities, and the appropriate reporting standards. Anyone who combines the two—the Sustainable Development Goals as orientation and solid ESG data as a foundation—turns sustainability into more than a box-ticking exercise. And is prepared for what comes after 2030.

* This information is summarized editorial content and should not be construed as legal advice. VERSO accepts no liability.

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PPWR Regulation: The Most Important Questions and Answers for Companies

1. What is the PPWR (Packaging and Packaging Waste Regulation)?

2. When does the PPWR apply?

3. Who is affected by the PPWR regulation?

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4. Which roles does the PPWR regulation define?

Manufacturer

Supplier

Importer

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5. What does the PPWR role “Producer” mean, and how does it differ from “Manufacturer”?

6. What does “Extended Producer Responsibility” mean in the context of the PPWR regulation?

7. How will EPR fees change under the PPWR?

8. What obligations does the PPWR regulation introduce for companies?

1. Compliance & chemical safety (from 2026)

2. Labeling & transparency (from 2028 onward)

3. Design and sustainability requirements (phased in through 2040)

4. Specific requirements for certain packaging types

9. What specific PPWR regulation requirements apply starting in 2026?

10. What requirements apply regarding empty space and overpackaging?

11. What impact does the PPWR have on the supply chain?

12. How should companies prepare for the PPWR regulation now?

Software and consulting services for PPWR compliance

13. How does the PPWR relate to other ESG requirements?

Supply chain decarbonization

REACH / RoHS

ESRS E5 – Circular Economy

EUDR – Traceability

Digital Product Passport (DPP)

14. Why should companies implement the PPWR early?

15. What penalties apply in case of PPWR violations?

Implement PPWR with ease

* This information is summarized editorial content and should not be construed as legal advice. VERSO accepts no liability.

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EU Forced Labour Regulation: What Companies Need to Know Now

What is the Forced Labour Regulation

What counts as “forced labour”?

Does the Forced Labour Regulation also apply to mid-sized companies?

What do the European Commission’s guidelines say?

What happens when authorities investigate a suspected case?

How does the Forced Labour Regulation differ from the CSDDD and LkSG?

Where should supply chain managers start?

How does VERSO support companies in implementing the Forced Labour Regulation?

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The Five Biggest Greenwashing Traps and How to Avoid Them

Traps and examples for greenwashing

1. Confusing data situation and opaque sustainability reports

How do I create a sustainability report?

2. Scope 1, 2, 3 – all included?

Did you know that the majority of CO2 emissions come from Scope 3?

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3. Don’t exaggerate, stick to the facts!

4. Cherry-picking makes you look untrustworthy

5. Activities lack reference to the company or product

CSRD: New requirements for sustainability reports

Greenwashing examples from court and enforcement cases

“Climate neutral” without explanation (German Federal Court of Justice, 2024)

Sustainability claims without internal substance (2025)

Which environmental claims are no longer allowed in the EU?

Afraid of greenwashing? No “green silence” please!

Frequently asked questions on greenwashing

Avoid greenwashing? VERSO supports you!

* This information is summarized editorial content and should not be construed as legal advice. VERSO accepts no liability.

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