Who is responsible for ESG compliance inside a food company?

In most food companies, ESG compliance is owned at the senior leadership level, typically by a Chief Sustainability Officer (CSO) or an equivalent executive who holds cross-functional authority. Where no dedicated role exists, responsibility often sits with the CEO or CFO by default, though this arrangement tends to produce fragmented results as regulatory requirements grow more demanding.

The question of who manages ESG in a food company has become far more pressing since sustainability reporting moved from voluntary best practice to a legal obligation for larger organizations. The sections below address the most important questions food industry professionals are asking in 2026.

Who typically owns ESG compliance in a food company?

ESG compliance in a food company is typically owned by a Chief Sustainability Officer (CSO) or a designated ESG Compliance Lead reporting directly to the C-suite. This person is responsible for developing the sustainability strategy, coordinating reporting across departments, and ensuring that environmental, social, and governance commitments translate into measurable operational outcomes.

The CSO role has grown rapidly. A 2026 industry analysis found that roughly 80% of large publicly listed companies now have some form of Chief Sustainability Officer, and that more CSOs were appointed in 2020 and 2021 alone than in the preceding eight years combined. That acceleration reflects how quickly ESG has moved from a reputational concern to a core strategic and legal priority.

In food and beverage specifically, the CEO plays an equally critical role. Because sustainability touches global supply chains, from raw material sourcing to packaging and distribution, it requires active commitment from the top, not just a delegated compliance function. The CSO coordinates execution, but the CEO sets the strategic direction that makes ESG integration possible across a complex organization.

What departments are involved in ESG reporting for food companies?

ESG reporting in a food company is a cross-functional effort that draws on procurement, operations, finance, legal, HR, and supply chain teams. No single department can manage it alone. Each function contributes distinct data, emissions figures, supplier assessments, labor practices, governance disclosures, that together form a complete sustainability report.

In practice, building effective ESG governance starts by forming a dedicated cross-functional working group. Finance teams assess ESG-related financial risks and translate sustainability targets into capital allocation decisions. Legal teams monitor regulatory developments such as the EU’s Packaging and Packaging Waste Regulation (PPWR), which began applying from August 2026, and ensure disclosures meet audit standards. Procurement teams manage supplier due diligence and Scope 3 data collection, which is particularly significant in food manufacturing where upstream agricultural supply chains drive the vast majority of total emissions.

Operations and waste management functions contribute data on resource use, circular material flows, and packaging performance, areas directly relevant to ESRS E5, the European Sustainability Reporting Standard covering resource use and circular economy. Marketing teams face their own ESG obligations: the EU’s Empowering Consumers for the Green Transition Directive prohibits vague environmental claims, meaning every sustainability statement on packaging or in communications must be substantiated with specific, verifiable data.

What has changed in recent years is the formalization of these contributions. Previously, ESG responsibilities were scattered informally across corporate social responsibility, environmental management, and investor relations. Today, food companies are creating structured ESG roles, sustainability managers, ESG analysts, and reporting coordinators, to bring those threads together under a coherent governance framework.

How does ESG compliance affect food packaging decisions?

ESG compliance directly shapes food packaging decisions by creating measurable, reportable obligations around recyclability, plastic reduction, and material sourcing. For food companies subject to sustainability reporting frameworks, packaging is no longer a purely commercial or technical choice, it is a documented ESG input that affects compliance scores, supply chain ratings, and regulatory standing.

The PPWR, applying across all 27 EU Member States from August 2026, sets the clearest regulatory baseline. All packaging placed on the EU market must be designed for recyclability, with a grading system being established by 2028 and a 75% recycling target for paper and cardboard packaging by 2030. The regulation also introduces mandatory recycled content targets for plastic packaging from 2030 onward, and bans food-contact packaging containing PFAS compounds above specified concentration limits, a requirement with immediate effect from August 2026.

For sustainability teams preparing CSRD disclosures, switching to recyclable, low-plastic packaging provides concrete, reportable progress on environmental targets. Fiber-based food trays, for example, enter well-established cardboard recycling streams that already operate at scale in most European markets, meaning recyclability translates into actual recycling, not just theoretical potential. Our Jospak fiber-based tray uses at least 85% recycled fiber and contains up to 90% less plastic compared to a same-sized rigid plastic tray, which gives procurement and sustainability teams a specific, auditable data point rather than a generic claim.

Major retailers are reinforcing this regulatory pressure commercially: supplier sustainability credentials are increasingly treated as a listing condition, turning packaging investment into a direct competitive factor rather than a compliance cost.

What ESG metrics matter most in the food industry?

The ESG metrics that matter most in the food industry are greenhouse gas emissions (particularly Scope 3), packaging recyclability and recycled content rates, food waste volumes by disposal route, water use, and circular material use rates. These are the indicators most directly tied to mandatory reporting standards and most scrutinized by investors, retailers, and regulators.

Scope 3 emissions deserve particular attention. In food and agriculture, upstream and downstream supply chain emissions represent the overwhelming majority of a company’s total carbon footprint, driven by agricultural inputs, livestock, land-use change, and distribution. Despite this, a significant share of packaged food companies still do not disclose full Scope 3 data, creating exposure to ESG rating downgrades and audit findings under CSRD, which requires third-party assurance of sustainability disclosures.

On the packaging side, ESRS E5 requires companies to report circular material use rates, recycled input shares, and waste processing methods when resource use is material to the business. This means sustainability teams need reliable data on what percentage of packaging is recyclable, what share of material input is recycled or renewable, and how packaging waste is processed at end of life. Lifecycle emissions per packaging unit are also increasingly tracked. Jospak has developed a cradle-to-gate carbon footprint calculator for its trays, enabling direct comparisons with conventional plastic packaging for customer reporting purposes.

Food waste reporting under ESRS E5 adds another layer: companies must disclose food waste volumes broken down by disposal route, with estimates permitted in year one but measured, verifiable data expected by year two of reporting. Pairing waste volumes with Scope 3 emissions attribution, as required under the GHG Protocol, ties operational performance directly to carbon disclosure.

When should a food company appoint a dedicated ESG officer?

A food company should appoint a dedicated ESG officer when sustainability has become a core strategic imperative requiring formal reporting, science-based targets, and consistent cross-departmental accountability. For companies in scope for CSRD, currently defined as large undertakings with more than 1,000 employees and net annual turnover exceeding €450 million, a dedicated role is effectively a practical necessity, not just good practice.

The 2026 Omnibus I Directive significantly narrowed CSRD’s scope from earlier thresholds, exempting listed SMEs and smaller companies entirely. However, companies that fall below the new thresholds are not immune to ESG pressure. Larger supply chain partners subject to CSRD will request sustainability data from their suppliers, and while the Omnibus agreement introduced a cap limiting such requests to the scope of the voluntary VSME standard, smaller food companies still benefit from having someone internally who understands what data to collect and how to present it credibly.

For SMEs, a part-time or shared ESG role is a practical starting point. The risk of leaving ESG responsibility entirely dispersed across departments is inconsistency, different teams using different methodologies, producing data that cannot withstand third-party scrutiny. A dedicated owner, even a part-time one, centralizes accountability and reduces greenwashing risk by ensuring that every public claim is backed by traceable evidence.

The clearest signal that a dedicated appointment is overdue is when ESG reporting has become reactive, responding to customer questionnaires, retailer audits, or regulatory inquiries without a structured data collection process behind the answers.

How can food companies verify ESG compliance across their supply chain?

Food companies can verify ESG compliance across their supply chain by combining structured supplier assessments, third-party certifications, digital data collection tools, and internal audit processes. Self-reported supplier data alone is insufficient, auditors and CSRD assurance providers expect timestamped, categorized, and independently verifiable evidence, not manual logs.

The practical challenge is visibility. Most organizations have reasonable oversight of their direct suppliers, but visibility drops sharply beyond the first tier. Supplier sustainability programs typically start with questionnaire-based assessments for all suppliers, followed by third-party ratings, such as EcoVadis, for higher-risk or higher-volume relationships. These provide a more credible alternative to taking suppliers at their word, particularly for SME suppliers that may lack the infrastructure to measure and report ESG data accurately.

Certifications play a structural role in supply chain verification. FSC Chain of Custody certification, for example, creates an active audit obligation at every stage of the fiber supply chain, meaning the recycled fiber content claim on a packaging product is not self-declared but independently verified. Our supply chain at Jospak carries FSC CoC certification alongside BRCGS AA+ packaging certification, which together provide customers with auditable traceability documentation for their own supplier due diligence processes.

Under the PPWR, traceability obligations extend to packaging itself: packaging must identify the manufacturer and importer by name, registered trade name, and postal address, creating a direct regulatory requirement for supply chain transparency at the product level. Extended Producer Responsibility fees under the same regulation are modulated by recyclability performance grade, which gives food companies a financial incentive to verify and document their packaging’s recyclability credentials rather than rely on unsubstantiated claims.

For food companies building their verification infrastructure, the most effective approach combines clear ESG data requirements aligned with CSRD and EU taxonomy, standardized digital data collection, supplier training and engagement, and regular internal audits, treating supply chain ESG verification as an ongoing operational capability rather than an annual compliance exercise.