How to Write an ESG Report for the Packaging Industry? 5 Essential Disclosures for the Packaging Section

I first encountered writing the packaging section of an ESG report in 2023, when I helped an A-share listed food company with an internal review. They sent me the previous year's draft ESG report and asked me to check whether the "Packaging and Environment" subsection was written correctly. I opened the document, skimmed through it, and laughed — the entire section contained only two sentences:

"The Company attaches importance to environmental protection, and prioritizes the use of environmentally friendly materials in the packaging process."

"Going forward, the Company will continue to advance green packaging initiatives."

This is a textbook example of "box-ticking" disclosure. The three reasons why packaging sections in listed companies' ESG reports most often get sent back for rewriting — this company hit all three:

First, no quantified data. "Prioritizes the use of environmentally friendly materials" is a qualitative statement; readers (investors, regulators, media) learn nothing from it. Second, no baseline for comparison. How many tonnes of environmentally friendly materials were used this year? Was that more or less than last year? What is the proportion? Third, no third-party verification. Saying "we are green" versus "a third-party organization has verified that we are green" carries a credibility gap of roughly tenfold.

This article aims to walk you through how to write the packaging section of an ESG report — not by giving you a complete framework (too broad), and not by handing you boilerplate, but by giving you the 5 mandatory disclosure items, along with 3 real samples we helped clients write (anonymized).

Why the Packaging Section Is Becoming Increasingly Important in ESG Reports

Many people assume that ESG reports mainly address "carbon emissions" and "social responsibility," with packaging being only a small subsection. In reality, however, packaging is becoming a "small-item, high-weight" indicator that ESG rating agencies are focusing on closely.

In MSCI's ESG rating model, "Product Carbon Footprint" and "Packaging & Plastics" are two independent scoring items. In Sustainalytics' (a Morningstar company) ESG risk rating, packaging-related controversy events have a significant impact on a company's overall risk score. Domestic ratings such as Wind ESG and China Securities ESG also treat "Packaging & Recyclability" as an independent indicator.

For packaging-intensive industries such as consumer goods, food and beverage, pharmaceuticals, and electronics, the quality of the packaging section directly affects ESG rating results, which in turn influences institutional investment decisions. This is why listed companies are increasingly willing to invest in getting this section done thoroughly.

5 Mandatory Disclosure Items

Combining the cross-cutting requirements of the three mainstream frameworks—GRI (Global Reporting Initiative), SASB (Sustainability Accounting Standards Board), and ISSB (International Sustainability Standards Board)—along with domestic stock exchange disclosure guidelines, the packaging chapter must cover the following 5 items.

Item One: Packaging Material Structure and Weight Data.Disclose the total annual packaging material usage (tons), broken down by material type (paper/plastic/metal/glass/composite materials), as well as the average packaging weight per single product. This is the foundation; without it, all subsequent disclosures lack a solid basis.

Item Two: Proportion of Recyclable / Compostable / Renewable Materials.Simply stating "we use eco-friendly materials" is insufficient; the proportions of three categories must be clearly specified—recyclable material proportion, compostable material proportion, and renewable material proportion (e.g., bio-based plastics). These three ratios must be disclosed separately and cannot be combined.

Item Three: Total Packaging Carbon Footprint and Intensity.Total annual packaging-related carbon emissions (tCO2e), as well as carbon emission intensity per unit revenue or per unit product. The source of the carbon emission factors (Ecoinvent, CLCD, DEFRA) must be clearly indicated.

Item Four: Packaging Waste Generation and Disposal.The amount of packaging waste generated during the production stage and the consumption stage respectively, and the proportions of disposal methods (recycling/landfilling/incineration/composting). This is an item specifically emphasized by the new EU CSRD (Corporate Sustainability Reporting Directive).

Item Five: Compliance and Certification Status.Whether packaging design complies with local regulatory requirements (Plastic Restriction Order, EU PPWR, California Prop 65), and which certifications have been obtained (FSC, PEFC, Cradle to Cradle, etc.).

3 Real Samples (Anonymized)

Sample 1: A-share food listed company, packaging section of the 2023 ESG report.

"In the current year, the company's total packaging material consumption reached 12,800 tons, of which paper-based materials accounted for 9,200 tons (71.9%), plastic materials 2,800 tons (21.9%), metal materials 600 tons (4.7%), and other materials 200 tons (1.5%). Within paper-based materials, 38% were FSC-certified, compared with 27% in 2022. The average PCR (post-consumer recycled) content in plastic materials reached 22%, with a target of 30% by 2025. The average packaging weight per unit product decreased by 4.2% compared with 2022 (see Annex Table 3 for the detailed category breakdown)."

This disclosure has reached MSCI's "industry leader" level: breakdown by material type, breakdown by certification status, baseline comparison provided, and improvement targets provided.

Sample 2: Hong Kong-listed consumer goods company, packaging section of the 2024 ESG report (excerpt).

"The Group commissioned a third-party organization to conduct a carbon footprint accounting of the core product line packaging in accordance with ISO 14067, covering 12 product categories. The accounting results show that the packaging carbon footprint per product ranges from 0.12 to 0.38 kgCO2e, of which carton packaging ranges from 0.12 to 0.18 and composite film packaging ranges from 0.25 to 0.38. The Group has set a target to reduce the packaging carbon footprint per product by 10% by 2025, with pathways including: 1) increasing PCR content; 2) optimizing packaging structure to reduce weight; 3) localizing suppliers to lower transportation carbon emissions."

The key point of this excerpt is "commissioned third-party" — ISO 14067 is an internationally recognized standard, and data verified by third-party organizations is 5 to 10 times more credible than self-reported corporate data.

Sample 3: A-share pharmaceutical company, packaging waste disclosure from the 2023 ESG report.

"In the current year, the company's production processes generated 850 tons of packaging waste, of which 720 tons (84.7%) were recycled and reused through professional recycling enterprises, 100 tons (11.8%) were landfilled after harmless treatment, and 30 tons (3.5%) were sent to incineration for power generation due to high material composite complexity, making recycling infeasible. Packaging waste generated at the consumption stage (i.e., after end-user use) is estimated at approximately 2,800 tons, with disposal primarily relying on local recycling systems."p>

The most commendable aspect of this excerpt is the acknowledgment that "3.5% cannot be recycled" — real data is rarely 100% perfect, and acknowledging gaps is more professional than concealing them.

Packaging Chapter 1,500-Word Template Framework

If you are preparing a packaging chapter of around 1,500 words, you can organize the content using the following framework:

Paragraph 1 (approx. 200 words): Packaging Strategy Overview — the positioning of packaging within the company's ESG strategy, scope of coverage (which product categories / which subsidiaries), and management structure (which department is responsible).

Paragraph 2 (approx. 300 words): Disclosure of Five Indicators — the five mandatory items discussed above, with data provided for each and, where necessary, references to attached schedules.

Paragraph 3 (approx. 300 words): Annual Progress and Baseline Comparison — improvements compared to the previous year, presenting 2-3 specific improvement cases (lightweighting cases, mono-material conversion cases, cases of expanded certification scope).

Paragraph 4 (approx. 300 words): Goals and Action Plan — quantitative targets for the next 1-3 years (packaging weight reduction of X%, share of recyclable materials at Y%, certification scope expanded to Z), along with the implementation pathway.

Paragraph 5 (approx. 200 words): Compliance and Certification — a list of currently held certifications and a description of compliance with applicable market regulatory requirements.

Paragraph 6 (approx. 200 words): Closing — management statement, third-party verification statement, and scope of data description (which subsidiaries are excluded from the statistics and the statistical methodology).

4 Practical Challenges in Data Collection

Challenge 1: Inconsistent data standards across subsidiaries. Different subsidiaries under the group use different ERP systems, resulting in significant discrepancies in packaging material data standards. It is recommended to unify a "Packaging Material Statistics Table" template and mandate that subsidiaries report on a monthly basis.

Challenge 2: Selection of carbon emission factor databases. The differences between commonly used domestic CLCD (China Life Cycle Database) and the international Ecoinvent database range from 15-30%. It is recommended to cite both simultaneously and note the sources of discrepancy.

Challenge 3: Difficulty in obtaining consumption-stage data. It is challenging for factories and brand owners to track how packaging waste is handled by consumers. Estimates can be derived by combining three approaches: sample surveys, industry average estimates, and feedback data from partner recycling enterprises.

Challenge 4: Third-party verification costs. Complete third-party verification of ESG reports costs between 100,000 and 300,000 RMB, which places significant pressure on small and medium-sized listed companies. A phased approach can be adopted: first obtain Limited Assurance for the packaging chapter, then expand later.

Disclosure Mistakes That Should Be Avoided

Mistake One: Selective disclosure. "Our gift box packaging is 100% biodegradable" — such absolute statements carry extremely high risk against the backdrop of tightening regulations. It is recommended to use specific statements such as "X% certified to EN 13432".

Mistake Two: Future commitments substituted for current actions. "We plan to make all packaging recyclable by 2030" — this is a commitment, not a disclosure. Regulators focus on what has been done now, not what is intended in the future.

Mistake Three: Concealing negative information. "Our recycling rate is as high as 95%" — if the actual figure is 60%, being verified by a third party will result in more severe negative impact. It is recommended to proactively disclose gaps and improvement directions.

Mistake Four: Lack of data timeliness. Packaging data should be disclosed on an annual basis; quarterly data may be omitted but must be accompanied by an explanation to avoid data being one year out of date.

Conclusion

The packaging chapter of an ESG report is not an "essay"—it is a "ledger." Every paragraph must withstand cross-verification by investors, regulators, the media, and ESG rating agencies. Treat it as an important material for external communication, not a task to get through perfunctorily.

Over the past 3 years, LeXiang has assisted 7 listed companies in writing packaging-related chapters (including overall ESG report consulting for 2 listed companies). If you are preparing this year's ESG report, you can contact us for internal review or outsourced writing of the packaging chapter.

Further Reading

How to Calculate Packaging Carbon Footprint? Practical Calculation for 3 Types of Packaging Under ISO 14067 Standard

Single-Material Packaging Design: Why Brands Are Pursuing One Material

Compliant Use of Packaging Recycling Symbols: Differences Between 3 Types of Symbols + Regulatory Comparison Across 4 Countries

Compostable Packaging Certification: The Hard Threshold for Products to Reach European and American Shelves