The Role of CDP Disclosure in Solving the Plastics Pollution Problem

The Role of CDP Disclosure in Solving the Plastics Pollution Problem

The Role of CDP Disclosure in Solving the Plastics Pollution Problem

by: Leticia Socal & Preeti Shanker | September 13, 2023


The plastics pollution crisis has long been one of the most visible sustainability issues of our times, and yet the efforts to address it, while numerous, have remained mostly siloed. Governments, institutions, consumers, NGOs, scientists, corporations, investors, and organizations like ClimeCo are working to solve different aspects of this multi-fold, complex issue. Still, the call for cohesive and collaborative action is finally getting louder, and efforts to unite various stakeholders, become aligned, and work towards a common goal.

The latest shot in the arm towards this shift is CDP’s (formerly the Carbon Disclosure Project) foray into plastics disclosure.

If growth in single-use plastic production continues at current rates, it will account for 5 – 10% of global emissions by 2050.

CDP’s Growing Influence 

CDP manages a global disclosure system that companies, investors, cities, states, and regions use to engage with environmental issues. Companies and investors use the CDP system rather effectively to share key information on metrics, strategies, risks, and opportunities that are either hard to glean from sustainability reports, hard to distinguish from greenwashing claims, or difficult to compare or act upon meaningfully. 

CDP’s disclosure modules on climate change, water security, and forests standardized how and what data is gathered to be useful for investors and shareholders. The annual disclosure cycle means continuous engagement between CDP, companies, and investors, who can collectively push the needle toward attaining sustainability goals.

CDP has grown into a tour de force. As of 2023, a whopping 18,700 companies [1] have been requested to disclose data to CDP by over 740 investors with more than $136 trillion in assets. Over 340 major buyers, with a purchasing power of $6.4 trillion, have asked their suppliers to disclose through CDP. In short, if you were a company that received a disclosure request from CDP, you get your ducks in a row and buckle up for the ride! 

CDP’s Foray Into Plastics 

In 2023, CDP announced the introduction of its Plastics Module. Recognizing the scale and complexity of the plastics problem and its successful role in shaping the climate change movement, this is CDP’s attempt to bring similar standardization, rigor, and engagement to the plastics crisis.

In its inaugural year, CDP has included the Plastics Module within its existing water security questionnaire, recognizing the threats posed by plastic pollution to water systems. In the future, as disclosures improve, companies’ practices mature, and the engagement around plastics deepens, CDP is likely to carve off plastics disclosures as its standalone topic with an independent questionnaire.

Around 7,000 companies have been requested to respond to the CDP Plastics module in 2023. According to a recent CDP consultation, 81% of responding capital markets and supply chain members said that the information requested by CDP on plastics would be useful in informing financial or procurement decisions [2].

Companies face $100 billion annual financial risk if governments require them to cover waste management costs at expected volumes and recyclability.

Key Points on CDP Plastic Disclosure 

– Plastics-related questions are included in the water security questionnaire
– The Plastics Module contains 5-9 questions about a company’s plastics-related environmental impacts
– In 2023, responses to the plastics questions are not scored (this will change in the future)
– CDP’s questions build on existing frameworks and best practices, including work carried out by the Ellen MacArthur Foundation and UNEP’s New Plastics Economy Global Commitment, the PEW Charitable Trusts, and the Minderoo Foundation 

What Questions are CDP Asking About Plastics? 

CDP is asking for information from all companies that use, produce, or commercialize plastics, covering the entirety of their value chain, including plastics waste management, reprocessing, and disposal.              

Within the water security questionnaire, Module W.10 contains 5-9 plastics-related questions covering a range of topics around the reporting company’s practices around plastic use and plastic production. CDP provides a useful mapping of the questions, reproduced below:

How to Approach CDP Plastics Disclosure

Disclosure, while cumbersome and time-consuming, is valuable for any reporting company. Disclosure, done right: 

– Aligns the company’s intentions with its implementation plans
– Shines a light on risks the company may not have considered yet and opportunities the company may have yet to discover, both of which are material to its investors

Whether or not your business is among the 7000 early CDP Plastics respondents, plastics disclosure will likely be on the cards soon for most companies. Plastics is soon to be a material disclosure area for your company, especially if you operate in the following sectors: apparel, biotech/healthcare/pharmaceutical, chemical, food/beverage/agriculture, fossil fuel, hospitality, infrastructure, manufacturing, material, mineral extraction, power generation, retail or transportation services (see CDP’s guidance on how plastic is material to these sectors). 

We recommend taking a proactive approach to plastics disclosure. While it remains an unscored module at CDP, this presents an excellent low-risk opportunity for companies to begin disclosures and establish processes and policies for future-focused improved disclosures. 

Here are some valuable resources to get started:

Overview of CDP Plastics
CDP’s Technical Guidance on Plastics Disclosure

To learn more, contact our Plastics and CDP Reporting experts at

[1]  CDP – What We Do
[2]  CDP – Environmental Disclosure System Opens for Reporting on Plastics

About the Authors 

Leticia Socal is a chemist and seasoned plastic industry professional with over 15 years of experience spanning R&D, intellectual property, market research & strategy. Leticia is a certified TRUE Zero Waste advisor and a Blue Consultant. She holds a Bachelor of Science in Industrial Chemistry, a Master of Science in Materials Engineering, and a Ph.D. in Polymer Science.

Preeti Shanker is a lawyer-turned-sustainability consultant with over 12 years of industry experience. Preeti has worked with clients from a variety of sectors including manufacturing, pharma, technology and financial services to develop the companies’ ESG and climate strategies and hone their ESG reporting, communications and disclosures, including CDP disclosures She holds a Bachelor’s degree in Law and a Master’s degree in Sustainability Management. 

Plastic Footprint Part II: Mitigation Metrics That Matter

Plastic Footprint Part II: Mitigation Metrics That Matter

Plastic Footprint Part II: Mitigation Metrics That Matter

The critical connection between plastic mitigation and corporate leadership

by: Leticia Socal | May 24, 2023


Part I of this blog series showcased the benefits of executing a baseline plastic footprint analysis. Now it is time to understand that the risks at stake are equally valuable.

Part II outlines the key metrics corporate leadership will find interesting when planning and budgeting for their plastic mitigation strategy. Once the scope and execution of a plastic footprint has been mapped, planning internal buy-in to implement mitigation actions is essential. Acting now is vital for corporations due to timely institutional changes and because circular plastic is still in its pioneer stage. Early and effective action will establish participants at the forefront of development and influence acceptance in the circular economy.

Costs of Non-Involvement?

Although variable and obscure, the costs of opting out of a plastic survey is risky and can be detrimental in its ever-changing landscape. According to The Minderoo Foundation, conservative, near-term (2022-2030) estimates of corporate plastic liability (US only) land at around $20 billion. This liability estimates ranges from bodily injury, property damage, and loss of shareholder value. And it’s not limited to the cost of liability from “misleading consumer statements” and greenwashing, expected to be penalized with “significant fines and sanctions.” [1]

Beyond liability, operational costs are considerable as well. A study by Pew Trust foresees companies operating at business-as-usual in the 2040s accruing $100 billion in virgin plastic taxes and/or responsible disposal fees with extended producer responsibilities (EPR) [2].

Comparatively, companies that chose to act today towards reducing their plastic impact and building a solid baseline would incur a fraction (~0.5%) of the costs of greenwashing litigation or an EPR non-compliance fee. Familiarizing leadership with this topic’s go-to advisory policymakers, insurers, investors, and corporate leadership would be wise to add to your to-do list.

The intangible costs are also notable, as seen in Part I of this series. Refusing to collect sustainability data on your products’ life cycle and overall footprint excludes vital product information from your operation—closing doors on opportunities to expand consumer messaging, innovate product design, diversify market offerings, and differentiate from the competition. Without knowledge, there is little to prepare for – plastic footprinting is a unique approach to understanding potential supply chain vulnerabilities (i.e., deforestation on ingredient plantations) and exposure to public criticism (political opinion on local vs. international labor).

Is the Market Demanding More Sustainable Products?

Making operational changes can be disruptive, laborious, and expensive. If cash flow is suffering, it’s easier to justify implementing product changes that take away time and energy from sales. Business owners typically want low-risk and high ROI. Fortunately, the data highlighting the impacts of performing an analysis or “pedicure” on your products and/or business is positive. A 5-year study by NYU showed that sustainability marketed products grew more than seven times faster than their conventional counterparts, selling at a 39% higher premium [3]. The sustainability market can be considered recession-proof since this study was collected amidst the COVID-19 global pandemic [4]. With all things considered, sustainability marketed products have continued to grow throughout the worst economic downturn since the Great Depression [5]. This raises the question, is now the right time?

Who’s Holding You Accountable?

Failing to act before an official and legislative change is mandated will no doubt decrease the market effectiveness and opportunity to set yourself apart from competitors before it is streamlined and mandated. There is still time to perform a footprint analysis and implement changes before the United Nations (UN) Plastics Treaty is ratified in June and December 2023 [6].

If your company is one of the 18,000 that has disclosed to CDP (formerly Carbon Disclosure Project) for climate change, water quality, or forests in the past or funded by investors with a vested interest in public disclosure, thinking about your plastic impact may come down to bargaining with your financial support. In 2023, the CDP disclosure questionnaire piloted a new set of plastic-related voluntary questions under the Water Quality survey in a growing global response to plastic pollution disclosure and responsibility. These investors are forcing the hand of their companies, thus opening the floodgates of data needed for policymakers to make viable mandated solutions that drive actualized change [7]. This top-down pressure will only increase as the Plastics Treaty makes headway. In the wake before US-mandated disclosure breaches the horizon, familiarizing your business with the conduct of disclosure is both wise and forward-looking.

What’s Next?

The world is at the precipice of significant change—the role of plastic materials is at a tipping point, shifting in its value and applications. The United Nations Environment Programme approaches plastic circularity with three easy steps: eliminate, innovate, and circulate [8]. The role plastic footprints play in larger mitigation measures and Environmental, Social & Governance (ESG) targets is just one step towards a more circular, efficient, and cost-saving operation, whether applied to events, concerts, products, or company offices or operations. Although new and sometimes misinformed, multiple data sources frame plastic mitigation and circular innovation as a sound investment, both operationally and financially. Now that you have the data to assure leadership to buy into plastic initiatives, congratulate yourself for being a thought leader towards corporate change with visible impact.

Understanding your impact is the first step towards change, and there are multiple options available for companies actively planning to meet their ESG targets.

Our global teams are ready to work with you – let’s connect, begin setting targets, assess and mitigate your plastic footprint.

[1]  The Price of Plastic Pollution: Social Costs and Corporate Liabilities

[2]  Breaking the Plastic Wave: Top Finding fo Preventing Plastic Pollution
[3]  2020 Sustainable Market Share Index (
[4]  Risk of Global Recession in 2023 Rises Amid Simultaneous Rate Hikes
[5]  The Great Lockdown: Worst Economic Downturn Since the Great Depression
[6]  Plastic Treaty progress puts spotlight on circular economy
[7]  Businesses encouraged to disclose plastics footprint through CDP for the first time
[8]  Plastic Treaty progress puts spotlight on circular economy

About the Author

Leticia Socal is a chemist and seasoned plastic industry professional with over 15 years of experience spanning R&D, intellectual property, market research & strategy. Leticia is a certified TRUE Zero Waste advisor and a Blue Consultant. She holds a Bachelor of Science in Industrial Chemistry, a Master of Science in Materials Engineering, and a Ph.D. in Polymer Science.