Sustainable Swag
2026 Sustainability Reporting Requirements for Branded Products
What global companies must disclose under sustainability regulations, including the EU’s CSRD, CSDD, and DPP.
TLDR; Key Insights
Large enterprises are already subject to mandatory sustainability and supply-chain reporting obligations under regulations such as the EU Corporate Sustainability Reporting Directive (CSRD), California’s Climate Corporate Data Accountability Act (SB 253), and modern slavery legislation in the UK and Australia.
These frameworks require companies, where material and within scope, to disclose information on Scope 3 emissions, including emissions from purchased goods and services; supply-chain structure and sourcing practices; labour and human rights risks, and environmental impacts linked to procurement.
New EU rules, including the Corporate Sustainability Due Diligence Directive (CSDDD) and the Digital Product Passport (DPP) under the Ecodesign for Sustainable Products Regulation, further increase expectations around traceability, due diligence, and product-level transparency.
While scope and timelines continue to evolve, it’s clear that large companies must move from narrative sustainability reporting to structured, verifiable data across their supply chains, including for branded products.
Contents
Why branded products fall under regulatory scope
Corporate Sustainability Reporting Directive (CSRD)
California Climate Corporate Data Accountability Act (SB 253)
UK Modern Slavery Act 2015
Australian Modern Slavery Act 2018
Fighting Against Forced Labour and Child Labour in Supply Chains Act, Canada
Corporate Sustainability Due Diligence Directive (EU)
Digital Product Passport (EU)
Key Takeaway
For many years, branded products such as sales materials, promotional merchandise, employee apparel, and welcome packs sat outside formal regulatory scrutiny. They were often treated as discretionary marketing spend, managed locally, and ordered through fragmented supplier networks.
However, across major jurisdictions, sustainability regulation has expanded to cover procurement, supply chains, and downstream environmental impact. As a result, branded products are now captured within legally mandated disclosures on emissions, sourcing, labour practices, and product transparency. This shift is driven by corporate sustainability, climate, and supply-chain laws that treat branded products as purchased goods and physical products placed on the market.
This article explains:
- Which sustainability regulations are already in force and relevant to branded products
- Which additional requirements are coming into effect
- What companies must report in practice
- Why branded products are increasingly a compliance issue for global enterprises and how to solve it.
Why branded products fall into regulatory scope
Most sustainability regulations do not mention “branded products” explicitly. Instead, they regulate purchased goods and services, supply chains, products placed on the market, and upstream and downstream environmental impact.
Branded products typically meet all of these definitions. Apparel, printed materials, promotional items, and employee kits are:
- Procured from third-party suppliers
- Manufactured using regulated materials and processes
- Transported across borders
- Distributed within regulated markets
As a result, they are captured under climate disclosure rules, supply-chain transparency laws, and product sustainability frameworks.
Sustainability regulation is moving from published company policies to proving, with data, how products are sourced, produced, and distributed.
Regulations already in force
Corporate Sustainability Reporting Directive
The Corporate Sustainability Reporting Directive (CSRD) significantly expands the scope and depth of sustainability reporting in the European Union.
The CSRD applies to large undertakings and certain non-EU companies operating in the EU, as defined in Directive (EU) 2022/2464 and subsequent EU simplification measures adopted in 2025.
Under CSRD, companies must report in accordance with the European Sustainability Reporting Standards (ESRS).
Of particular relevance to branded products is ESRS E1 (Climate Change), which requires disclosure of:
- Scope 1, 2, and Scope 3 greenhouse gas emissions
- Scope 3 Category 1: Purchased goods and services
Branded products, including promotional merchandise, printed sales materials, and apparel, fall squarely within Scope 3 purchased goods and services. Companies must disclose emissions associated with their production and, where material, their transport and distribution.
CSRD also requires disclosure of:
- Supply-chain characteristics
- Material sourcing and waste
- Governance and control over sustainability impacts
California Climate Corporate Data Accountability Act (SB 253)
The California Climate Corporate Data Accountability Act applies to companies doing business in California with annual revenues exceeding USD 1 billion, regardless of where they are headquartered.
SB 253 requires covered companies to report Scope 1 and Scope 2 emissions from 2026, with Scope 3 emissions reporting to follow from 2027, subject to implementing regulations adopted by the California Air Resources Board.
Scope 3 disclosures explicitly include emissions associated with procurement activities. Branded products, therefore, contribute to a company’s reportable emissions inventory.
Disclosures must be made publicly and follow recognized greenhouse gas accounting standards.
UK Modern Slavery Act 2015
Section 54 of the UK Modern Slavery Act requires commercial organisations carrying on business in the UK, with global turnover above GBP 36 million, to publish an annual Modern Slavery Statement.
The statement must describe steps taken to ensure that slavery and human trafficking are not taking place in the organisation’s own operations and in its supply chains
Although the Act does not mandate specific disclosures, official guidance makes clear that companies should report on:
- Supply-chain structure
- Risk assessment
- Due diligence processes
- Effectiveness of actions taken
Textiles, apparel, and promotional products are widely recognised as higher-risk categories due to complex global supply chains.
Australian Modern Slavery Act 2018
The Australian Modern Slavery Act requires entities with consolidated revenue of at least AUD 100 million to submit an annual Modern Slavery Statement to a central government register.
Unlike the UK regime, the Australian Act sets out mandatory reporting criteria, including:
- Description of operations and supply chains
- Identification of modern slavery risks
- Actions taken to assess and address those risks
- How effectiveness is assessed
Branded products, particularly apparel and merchandise, are routinely included within scope due to their manufacturing characteristics.
Canada: Fighting Against Forced Labour and Child Labour in Supply Chains Act
Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act came into force on 1 January 2024.
The Act establishes an annual transparency reporting obligation focused on disclosure of steps taken to address forced and child labour risks, rather than prescriptive due-diligence requirements.
Regulations coming into force or expanding
Corporate Sustainability Due Diligence Directive (EU)
The Corporate Sustainability Due Diligence Directive (CSDDD) entered into force in 2024 and will apply in phases from 26 July 2029, subject to company size and turnover thresholds, requiring covered companies to conduct environmental and human-rights due diligence across their supply chains.
Companies included:
- Large EU corporations with more than 5,000 employees and a net annual turnover of over EUR 1.5 billion
- Non-EU companies generating more than EUR 1.5 billion in turnover within the EU.
They should only ask for information from business partners with fewer than 5,000 employees when the information for in-depth assessment cannot be obtained another way.
CSDDD requires covered companies to:
- Identify actual and potential adverse impacts
- Prevent or mitigate those impacts
- Monitor effectiveness
While CSDDD is not product-specific, branded products are affected insofar as they are procured from global suppliers and contribute to environmental and social impacts.
Digital Product Passport (EU)
The Digital Product Passport (DPP) is introduced under the Ecodesign for Sustainable Products Regulation (ESPR) and will become mandatory on a product-group basis through delegated acts adopted by the European Commission. Compliance timelines will vary by product category.
Textiles and apparel are identified by the Commission as priority product categories, but no single universal DPP start date applies across all products.
The DPP will require digital, structured information on:
- Product identity
- Manufacturing location
- Materials used
- Environmental performance
- Compliance attributes
Any company placing products on the EU market, including non-EU companies distributing branded products in the EU, will be affected.
Learn more about the DPP and how it impacts branded products here.
What companies must report and operational implications
In line with these regulations, global companies are increasingly required to report:
- Where branded products are produced
- Which suppliers and regions are involved
- Emissions associated with production and logistics
- Labour and human rights risks in supply chains
- Waste and overproduction exposure
- Evidence supporting sustainability claims
Regulations are changing from those requiring narrative statements or estimates to ones with traceable, verifiable, and repeatable data.
For many organisations, branded product procurement remains decentralised or centralized with products shipped worldwide. When orders are placed by local teams, suppliers vary by region, and documentation is inconsistent. As regulatory scrutiny increases, these models introduce risk. Decentralized set ups make it difficult to substantiate Scope 3 disclosures, limit supply chain visibility, and require substantive effort to prepare audit-ready documentation. On the other hand, companies with centralizes ordering experience far higher emissions due to long shipping distances and waste.
As regulations evolve, branded products increasingly require the same level of governance as other regulated procurement categories.
Key Takeaway
Sustainability regulation has moved decisively from voluntary reporting to mandatory disclosure, and from high-level metrics to product-level transparency. Branded products are no longer peripheral. They are physical goods, procured globally, and distributed into regulated markets.
For global enterprises, this shift requires better visibility, stronger data foundations, and alignment between marketing execution and compliance obligations.
Understanding how branded products intersect with sustainability regulation is now a core requirement for compliance. As reporting standards tighten and supply-chain obligations expand, enterprises need greater control over how branded products are sourced, produced, and distributed.
Sustainable branded products
Ciloo enables organizations to align branded product procurement with sustainability goals and reporting requirements through local production, supplier visibility, and structured order-level data. Book a demo today to see how your branded product operations can become more sustainable, transparent, and reporting-ready.
Frequently Asked Questions
What are Scope 3 emissions, and why do they matter for branded products?
Scope 3 emissions are indirect greenhouse gas emissions that occur across a company’s value chain, outside of its own operations. This includes emissions from purchased goods and services, transportation, and waste. For branded products, Scope 3 emissions typically include the environmental impact of manufacturing apparel, merchandise, and printed materials, as well as the emissions associated with transporting them. For many large companies, Scope 3 represents the majority of total emissions.
Does the Digital Product Passport apply to branded products?
The Digital Product Passport (DPP) will apply to specific product categories through delegated acts adopted by the European Commission. Priority categories include textiles and other high-impact products. Where branded products fall within those categories, companies placing them on the EU market will need to ensure product-level transparency, including information on manufacturing location, materials, and environmental performance.
What is the difference between CSRD and CSDDD?
The Corporate Sustainability Reporting Directive (CSRD) focuses on reporting. It requires companies to disclose structured sustainability information, including Scope 3 emissions and supply-chain impacts, where material.
The Corporate Sustainability Due Diligence Directive (CSDDD), by contrast, focuses on conduct. It requires in-scope companies to identify, prevent, and mitigate adverse environmental and human rights impacts across their value chains. In short, CSRD governs disclosure, while CSDDD governs due diligence and risk management.
Do CSRD, CSDDD, and the DPP apply only to companies in the EU?
No. While the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD), and the Digital Product Passport (DPP) originate from EU law, they do not apply exclusively to companies headquartered in the EU.
CSRD applies to large EU undertakings and can also apply to non-EU companies that generate significant turnover within the European Union through subsidiaries or branches.
CSDDD similarly applies to certain non-EU companies that meet defined turnover thresholds within the EU market.
The Digital Product Passport applies to products placed on the EU market, regardless of where the company is headquartered. If a non-EU company manufactures or distributes products — including branded products — that fall within regulated categories and are sold or distributed in the EU, the relevant DPP requirements will apply.
As a result, large multinational enterprises operating globally may be subject to EU sustainability and product transparency rules even if they are not EU-based.
Do companies need full product-level traceability today?
There is currently no single global rule requiring full product-level traceability for all companies. However, large enterprises subject to sustainability and supply-chain regulation are already required to disclose emissions, sourcing practices, and supply-chain risks where material. Emerging EU product transparency frameworks, including the Digital Product Passport, indicate a clear regulatory shift toward more granular, product-level information over time.
Additional resources
Article References
European Commission CSRD hub
Council of the EU press release (simplification agreement)
European Sustainability Reporting Standards (ESRS – E1 Climate)
European Commission CSDDD summary
Official CSDDD text (Directive (EU) 2024/1760)
Omnibus Directive
European Commission – Ecodesign for Sustainable Products
Official ESPR Regulation (EU) 2024/1781
Digital Product Passport policy explanation
Official California Legislative text SB 253
California Air Resources Board – implementation overview
UK Government guidance on Modern Slavery Act (official)
Modern Slavery Act 2015 – legislation text
Australian Government – Modern Slavery Act overview + Official Act text
Modern Slavery Statements Register
Official Act text (Justice Canada)
Public Safety Canada – reporting obligations
Government guidance on preparing a report