With the Royal Assent of the U.K. Environment Bill on November 9, 2020, attention has turned swiftly to the practicalities of implementation. The bill represents one of the most significant overhauls of environmental governance in the United Kingdom in decades. While much of the public focus has been on biodiversity, air quality, and water management, supply chain waste reporting requirements are quietly but decisively reshaping how companies must account for resource efficiency. For firms embedded in complex supplier networks, the new obligations carry significant operational implications. The expectation is no longer that firms simply report on their own direct waste. Rather, they are being asked—compelled, in fact—to bring supplier practices into the light.
At the centre of this effort lies data. Companies are now encouraged, or in many cases required, to integrate open datasets provided by Defra on licensed waste-disposal facilities with their internal supplier-level packaging and waste reports. This is not a theoretical exercise. The data is there. It is accessible. What is lacking, in many instances, is the technical architecture within firms to make use of it in meaningful ways. Some supply chain managers find themselves grappling with unfamiliar file formats or incomplete supplier records. Others hesitate, unsure how to connect disparate datasets or interpret inconsistencies between internal reports and external data feeds. This is where careful planning—combined with a willingness to experiment—can make the difference between superficial compliance and genuine insight.
A practical starting point is the construction of a “waste by supplier” heat map. This visual tool helps firms identify where waste volumes are concentrated across their supplier base and how those volumes correspond to the proximity and capacity of authorized waste-disposal facilities. The process usually begins by extracting supplier-level packaging data from internal reporting systems. This may come from ERP modules, procurement records, or sustainability tracking tools, depending on the company’s digital maturity. The data then needs to be cleaned—removing duplicates, standardizing supplier names, and filling gaps where possible. It is at this stage that many discover how patchy or uneven their reporting has been to date. That, in itself, is a valuable insight, albeit a somewhat humbling one.
Once internal data is in reasonable shape, the next step involves pulling Defra’s open data on waste-disposal sites. This data is typically available as CSV or XML downloads, and includes information on site types, accepted material categories, permitted volumes, and geolocation coordinates. Cross-referencing supplier locations and packaging volumes with this external data allows firms to begin building the heat map. Geographic information systems (GIS) software or simpler data visualization tools can be employed here. The sophistication of the tool matters less than the clarity of the output. What is important is that managers can see, at a glance, where resource efficiency risks lie and where remedial action—whether through supplier engagement or logistics planning—might have the greatest impact.
While building the heat map may seem technical, it should be seen as an enabler for strategic decision-making. Companies can use the map to prioritise supplier audits, to inform contract renegotiations with high-waste suppliers, or even to rethink sourcing strategies altogether. The map may also reveal opportunities for collaboration between suppliers, for instance by pooling waste streams to improve economies of scale in recycling or recovery. In this sense, the heat map becomes more than a reporting tool; it becomes a driver of supply chain transformation.
All of this feeds directly into the preparation of a mandatory “resource efficiency” annex for inclusion in annual reports. This annex is no longer a nice-to-have, or a public-relations gesture. It is rapidly becoming a compliance requirement, and one that investors, regulators, and civil society actors are scrutinising closely. A typical annex might begin with a high-level overview of total packaging volumes by material type, broken down by supplier or region as appropriate. It would then provide narrative detail on actions taken to improve resource efficiency—perhaps referencing the heat map findings, supplier engagement initiatives, or investments in circular economy partnerships. Where possible, quantitative targets and year-on-year comparisons should be included, though firms should not shy away from acknowledging challenges or areas where progress has been slower than hoped. Such candour is often more persuasive, and ultimately more credible, than overly polished narratives.
Constructing this annex is, inevitably, an iterative process. Data quality will improve over time as firms refine their collection methods and as suppliers themselves adapt to new expectations. The key is to get started—to build the first version, however imperfect, and to use it as a baseline for future improvement. Some firms may choose to align their annex content with broader sustainability frameworks such as the Global Reporting Initiative or the Task Force on Climate-related Financial Disclosures. Others may opt for a more bespoke approach, focusing specifically on the resource efficiency themes most material to their operations. Both paths are valid. What matters most is that the annex reflects genuine effort and serves as a platform for ongoing dialogue with stakeholders.
The reality is that the Environment Bill’s provisions on waste and resource efficiency reporting represent a significant cultural shift. They challenge firms to move beyond siloed thinking—to see supply chains not as black boxes but as systems of shared responsibility. For some, this will be uncomfortable. For others, it will offer a welcome opportunity to demonstrate leadership. Either way, the direction of travel is clear. Resource efficiency is no longer peripheral to corporate strategy. It is, increasingly, at its core.