Key takeaway
The plastics theme is the newest in CDP's framework, and the disclosure expectations are still evolving. CDP asks about plastics across the value chain: raw material production, packaging design, end-of-life recovery, and policy engagement. For most companies, plastics exposure concentrates in packaging, with some sectors having additional exposure in product composition. This lesson explains the question structure, the materials taxonomy, and how to disclose without over-engineering for a smaller-scoring module.
Who has plastics exposure
Almost every consumer-facing company has plastics exposure through packaging. The depth of exposure varies:
| Sector | Plastics exposure |
|---|---|
| FMCG / Consumer goods | High; primary packaging is often plastic; product use can involve plastics |
| Beverages | Very high; PET bottles dominate; closures, films, secondary packaging |
| Personal care | High; bottles, tubes, sachets; multi-material packaging is hard to recycle |
| Apparel | Medium-high; synthetic fibres, packaging, hangtags |
| Pharma | Medium; blister packs, bottles, secondary packaging |
| Industrial / B2B | Lower; bulk packaging, pallet wrap |
| Financial services | Minimal direct; financed exposure to consumer goods sectors |
For most respondents, plastics is a smaller-scoring module than climate or water. The CDP 2026 Module 10 question count is around 11 questions, with total available points around 8-12.
What CDP wants
The plastics module typically covers:
- Plastic production and use volume. How much plastic you produce, package with, or sell as final product.
- Material types. The polymer mix (PET, HDPE, LDPE, PP, PS, PVC, multi-layer composites).
- Recycled content. Percentage of recycled material in your plastic use.
- Recyclability of packaging. Percentage of packaging designed for recyclability under common collection systems.
- End-of-life management. What happens to your products' packaging after consumer use; participation in EPR (Extended Producer Responsibility) systems.
- Targets. Specific commitments on recycled content, recyclability, or absolute reduction.
- Engagement. Programmes with packaging suppliers, recyclers, or consumers.
The polymer taxonomy
CDP uses standard polymer classifications:
- PET (Polyethylene terephthalate): bottle resin; widely recycled in many markets
- HDPE (High-density polyethylene): rigid bottles, jugs; widely recycled
- LDPE (Low-density polyethylene): films, bags; less commonly recycled
- PP (Polypropylene): caps, closures, some containers; variable recycling
- PS (Polystyrene): cups, packaging; less commonly recycled
- PVC (Polyvinyl chloride): pipes, some packaging; not commonly recycled
- Multi-layer composites: laminates, sachets; very hard to recycle
CDP rewards detailed reporting by polymer type because different polymers have different end-of-life trajectories.
Analogy
Think of polymer reporting like reporting your investment portfolio by asset class. "I have 5 lakh in investments" is less informative than "2 lakh in equity, 2 lakh in debt, 1 lakh in gold." Each asset has different risk-return profiles. CDP's polymer reporting works the same way: each polymer has different recyclability, different recycling infrastructure, and different end-of-life impact.
EPR and the regulatory landscape
In India, the Plastic Waste Management Rules require many companies to register under EPR and meet recovery targets. Most major FMCG and beverage companies have EPR registrations and reported quantities in the system.
Globally:
- EU: Packaging and Packaging Waste Regulation (PPWR) effective 2024-2026, with progressive recyclability requirements
- UK: Plastic Packaging Tax (effective 2022) on packaging with less than 30 percent recycled content
- US: State-level EPR rules emerging (Maine, Oregon, California, others)
- Other markets: India, Brazil, Indonesia have evolving EPR frameworks
CDP rewards companies that disclose their EPR participation, recovery rates, and progress toward recyclability targets.
Worked example: a beverage manufacturer
Worked example
ColaBev India (continuation, plastics disclosure).
Plastics in packaging FY25:
Total plastic packaging weight: 87,200 tonnes
- PET (bottles): 52,000 tonnes (60 percent of total)
- HDPE (caps, closures, secondary containers): 18,000 tonnes
- LDPE (shrink wrap, films): 9,200 tonnes
- PP (some closures, films): 6,000 tonnes
- Other (composites, labels): 2,000 tonnes
Recycled content: 22 percent across portfolio
- PET bottles: 30 percent rPET (recycled PET)
- HDPE: 15 percent recycled
- LDPE: 5 percent recycled (limited rLDPE infrastructure)
- PP: 10 percent recycled
- Composites: not recycled
Recyclability of packaging: 75 percent of packaging is "designed for recyclability" under standard PET and HDPE recycling streams. The remaining 25 percent (composites, multi-layer films) is technically recyclable but rarely captured in current Indian recycling infrastructure.
EPR participation: Registered under India PWM Rules; FY25 EPR targets met (90 percent volume covered through PRO partnerships with national recyclers); PRO partner: ITC SIVAN Plastics, GreenLine.
Targets:
- 50 percent recycled content in PET by 2028 (from 30 percent now)
- 100 percent recyclable packaging by 2027
- 25 percent absolute reduction in virgin plastic by 2030 (from 2020 baseline)
Engagement:
- Partnership with Banyan Nation for high-quality recycled PET supply
- Member of Indian Plastics Foundation circularity working group
- Consumer education campaign on bottle return programme; 12 cities active
This level of disclosure scores at Management to Leadership tier. The components: tonnage by polymer, recycled content per polymer, recyclability assessment, EPR coverage, named targets, partnership engagement.
To reach full Leadership tier, ColaBev would add: third-party verification of recycled content claims; commitment to a specific date for 100 percent recycled content; absolute volume reduction targets.
How plastics connects to other modules
For most companies, plastics has overlap with:
- Climate. Plastic packaging is part of Scope 3 Category 1 (purchased goods); recyclability affects end-of-life emissions in Category 12.
- Forests. Some packaging is paper-based as a substitute for plastic, with FSC certification overlaps.
- Biodiversity. Plastic pollution affects marine and freshwater biodiversity.
The integrated answer mentions these connections. A response that treats plastics as a stand-alone theme misses points.
Common pitfalls
- Reporting only total plastic. Without polymer breakdown, the disclosure is at Awareness tier only. Polymer-by-polymer is the Management-tier expectation.
- Confusing "recyclable" with "recycled." Recyclable means the packaging can theoretically be recycled. Recycled content means the packaging actually contains recycled material. Both should be disclosed separately.
- Claiming compostable as recycled. Compostable plastics serve a different function and are scored separately.
- No targets. Many companies have made packaging commitments but have not set numerical targets with target years. Without specific targets, the cluster caps at Awareness tier.
The UN's Intergovernmental Negotiating Committee on Plastics is finalising a global treaty (negotiations through 2025-2027) that will likely include extended producer responsibility, design standards, and possibly absolute production caps. CDP's plastics disclosure framework is evolving in anticipation. Companies disclosing now should expect significantly more rigorous expectations in 2027-2028, particularly around upstream commitments (production reduction) and downstream verification (recycled content traceability). Building disclosure infrastructure now is forward-looking; companies that wait until the treaty is final will be behind.
Key Takeaways
- Plastics disclosure expectations are evolving rapidly; the 2026 module is small in points but is forward-looking
- Polymer-level reporting (PET, HDPE, LDPE, PP, etc.) is required for Management tier; aggregate plastic-only disclosure caps at Awareness
- Recycled content and recyclability are separate metrics; both should be disclosed by polymer
- EPR participation in India and other jurisdictions is now standard; CDP rewards disclosure of recovery rates and PRO partnerships
- Targets need numerical detail and target years; vague packaging commitments cap the cluster at Awareness tier
Knowledge Check
Test what you just learned
6 questions ยท check each one as you go
Which sector has the highest plastics exposure?
What does 'recyclable' mean as opposed to 'recycled content'?
True or false: A response that reports total plastic without polymer breakdown can earn Management tier.
Which is the EU regulation effective 2024-2026 on packaging?
Which is a Leadership-tier plastics commitment?
Select all that apply
Match each polymer to a typical use.
Match each item to its pair
PET
HDPE
LDPE
PP
Multi-layer composites
