How does OTP support the ESG strategy of FMCG manufacturers?
Obsolete Trading Platform (OTP) provides outsourcing and comprehensive inventory management services. We work with FMCG manufacturers and distributors.
How does OTP support FMCG producers in implementing their ESG strategies?
Surplus inventory doesn't automatically have to become waste. If a product is safe, compliant, and can still be legally placed on the market, early management can extend the life of the product already produced.
The Obsolete Trading Platform helps manufacturers qualify and manage FMCG obsoletes , end-of-line items, repackaged batches, products withdrawn from regular channels, and goods with shorter shelf lives.
The OTP organizes sales to a dispersed B2B customer base, consolidates orders, and handles payments and logistics. The manufacturer receives a single, structured process and an agreed-upon set of data needed to evaluate its results.
We will analyze the type of stock, operational constraints, and data that may be needed by the Supply Chain, ESG, Finance, and Sales teams.
From Surplus Management to Measurable ESG Performance
ESG goals require not only declarations but also concrete actions, accountability, data, and the ability to demonstrate results. Collaborating with an OTP can support a manufacturer in four areas.
1. Waste prevention
OTP helps find commercial applications for products that remain full-value goods but cannot be effectively utilized in the manufacturer's regular channels.
The process should begin before the product is no longer safe and legally negotiable. The sooner a batch is qualified, the more possible scenarios remain for its disposal.
2. Extending the use of manufactured products
Selling a full-value product allows you to use the materials, packaging, energy and labor that have already gone into its production.
This is not recycling. The product continues to serve its original purpose and remains in circulation as a commodity.
3. Orderly operational process
OTP can take over:
-
acquiring B2B customers,
-
order consolidation,
-
payment processing,
-
coordination of pickups and deliveries,
-
implementation of agreed requirements regarding markets, channels, target groups, logistics and brand presentation,
-
preparation of a report on the implementation of the process.
The manufacturer collaborates with a single partner, instead of handling many scattered orders independently.
4. Data supporting ESG reporting
The agreed OTP report can provide input into internal circular economy, inventory management and waste prevention metrics.
The OTP does not replace an ESG report, dual-materiality assessment, waste documentation, or independent assurance. It provides operational data that the manufacturer can verify and use in accordance with its own reporting methodology.
What regulations and standards might be relevant?
Waste Framework Directive 2008/98/EC
Directive 2008/98/EC establishes the European waste hierarchy. Waste prevention takes priority, followed by preparing for reuse, recycling, other forms of recovery and disposal.
If a safe and compliant product is put to use before it becomes waste, this may support the first level of the hierarchy: waste prevention. Articles 17 and 18 of the Polish Waste Act of 14 December 2012 establish a similar order of priorities.
Impact of working with OTP: the process helps producers identify goods at risk of disposal at an earlier stage and create an alternative commercial route for them.
Important: OTP handles products that may be legally sold. Goods classified as waste, hazardous products or products that may not legally be placed on the market require the appropriate legal procedures and should not be offered for sale.
Directive 2008/98/EC – EUR-Lex
Polish Waste Act of 14 December 2012 – ELI
Directive (EU) 2025/1892 on food waste
Directive (EU) 2025/1892 amended the Waste Framework Directive and introduced food waste reduction targets to be achieved by 31 December 2030.
At Member State level, these include:
-
a 10% reduction in food waste from processing and manufacturing compared with the 2021–2023 average;
-
a 30% per capita reduction in food waste from retail, other forms of distribution, restaurants and food services, and households.
Impact of working with OTP: finding a commercial route for safe products before they can no longer be sold may be one of the operational measures supporting efforts to reduce the risk of food waste.
Directive (EU) 2025/1892 – EUR-Lex
CSRD and ESRS E5 “Resource use and circular economy”
The CSRD, Directive 2022/2464, as amended, among others, by Directive (EU) 2026/470, establishes the framework for sustainability reporting by companies within its scope.
ESRS E5 covers resource use and the circular economy. It addresses, among other matters:
-
policies relating to resource use and the circular economy;
-
actions taken and resources allocated to them;
-
targets and how progress towards them is assessed;
-
resource inflows and outflows;
-
waste;
-
actions taken across the value chain.
Impact of working with OTP: data on qualifying batches, the number or mass of products successfully redirected, completion times and process outcomes may support the documentation of specific actions relating to ESRS E5. Entering into cooperation with OTP does not, in itself, constitute compliance with CSRD or ESRS requirements. The scope of reporting depends on the company’s circumstances, its materiality assessment, the applicable version of the standards and national legislation.
CSRD – European Commission information
Directive (EU) 2026/470 – EUR-Lex
ESRS, Commission Delegated Regulation (EU) 2023/2772 – EUR-Lex
ESPR — Regulation (EU) 2024/1781 on ecodesign
The ESPR introduces a European framework for preventing the destruction of unsold consumer products. Article 23 states that economic operators should take measures that can reasonably be expected to prevent the need to destroy unsold products.
For companies within its scope, Article 24 requires the disclosure of information including:
-
the number and weight of unsold products discarded as waste;
-
the reasons for discarding them;
-
how they are subsequently handled;
-
measures taken and planned to prevent their destruction.
The details and format of these disclosures are set out in Commission Implementing Regulation (EU) 2026/2.
Impact of working with OTP: OTP may form part of a documented process for preventing product destruction. A report on the cooperation may help demonstrate which batches were redirected for further sale and describe the preventive measure applied.
Important clarification: the current prohibition on destruction under Article 25 of the ESPR applies to the categories listed in Annex VII, primarily apparel and footwear. It should not be interpreted as a general prohibition on destroying all FMCG products. For FMCG products, the prevention principle and the disclosure obligations concerning unsold products are more broadly relevant.
Regulation (EU) 2024/1781 – EUR-Lex
Commission Implementing Regulation (EU) 2026/2 – EUR-Lex
Recovering value without creating a parallel problem
The scope of the report is determined before the collaboration begins. Depending on data availability, it may include:
-
list of products, SKUs and batches,
-
number of pieces, boxes or pallets sold,
-
the mass of the products, if it has been provided or can be reliably calculated,
-
dates of notification, order, pickup and delivery,
-
time needed to develop the batch,
-
share of the utilized volume in the stock qualified for the process,
-
markets and customer segments covered by the implementation,
-
unused part of the stock,
-
reasons for excluding products from the process,
-
information needed for internal summary of ESG performance.
The OTP report should be considered a source of operational data. The classification of this data in the ESG report remains the responsibility of the producer.
Examples of ESG indicators related to surpluses
The manufacturer may consider using the following indicators:
-
the number or weight of products intended for further marketing,
-
share of utilized products in the stock qualified for the process,
-
number of batches and SKUs used,
-
average time from stock qualification to collection,
-
share of products excluded for safety or compliance reasons,
-
change in the volume of liquidated stock compared to the adopted base period,
-
number of preventive actions taken before the product is considered waste.
The "avoided CO₂e emissions" metric requires a separate, credible methodology, baseline data, and a benchmark scenario. The number or weight of products sold should not be automatically converted into avoided emissions.
What does cooperation with OTP not replace?
Cooperation with OTP does not replace:
-
manufacturer's responsibility for product safety and compliance,
-
correct qualification of the product or waste,
-
documentation required by industry regulations,
-
waste recording and reporting,
-
double significance assessment,
-
report compliant with CSRD and ESRS,
-
independent certification of the report,
-
legal analysis of the obligations of a specific company,
-
methodology for calculating climate impact.
OTP does not guarantee the sale of the entire submitted batch or a specific environmental outcome. The outcome depends on, among other factors, product category, shelf life, volume, available time, operational constraints, and demand.
Incorporate surplus management into your ESG strategy
Effective action begins before waste is generated . Early identification of surplus increases the ability to safely manage products and allows for the collection of data needed to evaluate results.
OTP combines expertise in FMCG, supply chain, B2B sales, logistics, and technology. We help manufacturers transform a fragmented warehouse problem into a structured process with a defined owner, schedule, and reporting.
See what comprehensive management of FMCG surpluses and obsoletes looks like.
