Cable Recycling in ESG Reporting: How to Report Metals from Construction Sites

Cables from construction sites can contain valuable metals, mainly copper and aluminium. Their actual material yield, however, depends on the cable type, insulation, contamination and the processing technology used. For this reason, the entire weight of the cables should not automatically be reported as recycling in an ESG report. What matters is separating the waste streams, documenting their weight and demonstrating the actual treatment method.

This article explains how cable and metal recycling from construction sites can be classified, measured and described in the context of ESRS E5 and the Slovak rules for construction and demolition waste. Specific obligations depend on the company's scope, the outcome of its double materiality assessment, the type of project and the applicable version of the legislation.

Where cables belong in ESG reporting: CSRD and ESRS E5 in 2026

Waste and the circular economy fall under the topical standard ESRS E5 if they are a material topic for the company according to its double materiality assessment. The revised ESRS E5-5 covers waste from own operations and mainly requires information on:

• a description of the main waste streams,
• the total weight of waste generated,
• the share of waste diverted from disposal, broken down into preparation for reuse, recycling and other recovery,
• the share of waste directed to disposal, broken down into incineration, landfill and other disposal methods,
• the share of waste whose final destination is unknown.

What changed in 2026

• Omnibus I: Directive (EU) 2026/470 entered into force on 18 March 2026. For financial years beginning on or after 1 January 2027, the CSRD scope in the relevant part focuses on companies exceeding EUR 450 million in net turnover and an average of more than 1,000 employees, or on the relevant parent companies of groups. Member States must transpose the provisions of the directive by 19 March 2027.
• Revised ESRS: The European Commission adopted them on 3 July 2026. The Commission states a reduction of mandatory datapoints by more than 60% and of total datapoints by more than 70%. The delegated regulation is to enter into force on 10 November 2026 and applies to financial years beginning on or after 1 January 2027.
• For financial year 2026: The delegated regulation contains transitional rules under which companies within the scope of the ESRS may, under certain conditions, apply either the original or the revised version. They must clearly state in their report which option they used.
• Unknown final destination: The revised E5-5 contains a separate datapoint for waste whose final destination is unknown. A missing document may therefore cause problems in allocating waste between recycling, other recovery and disposal, but this is not an automatic rule specific to cables.

A company outside the mandatory scope of the CSRD is not automatically required to report data under the ESRS. However, it may need such data for contractual requirements of customers, financing, public procurement or voluntary reporting. This must be assessed according to the specific contract or financing programme.

Not sure whether the new rules apply to you? After Omnibus and the ESRS revision, it is not easy to determine what your company must report for 2026 and what from 2027 onwards. Get in touch and we will review your situation together.

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Slovak framework: 70% for selected construction and demolition waste

The Slovak Waste Act sets a target of preparing for reuse, recycling or material recovery of at least 70% by weight of selected construction and demolition waste. The target applies to waste in group 17 of the Waste Catalogue, excluding hazardous waste and waste under catalogue number 17 05 04, to the extent laid down by Slovak legislation.

This target is not identical to the ESRS E5-5 indicator or to the DNSH criteria under the EU Taxonomy. These are separate frameworks with different scope, purpose and calculation rules. When assessing DNSH, the specific economic activity and all relevant technical screening criteria must be verified. Separating metals from cables alone does not demonstrate compliance with all DNSH conditions.

Energy recovery is not considered recycling or material recovery. When calculating the Slovak 70% target, preparation for reuse, recycling and other material recovery must therefore be distinguished from energy recovery and disposal.

How to classify cable waste: catalogue numbers

The correct catalogue number is the foundation of waste records. The code is determined by the actual composition and hazardous properties of the waste, not merely by the fact that it was generated on a construction site.

In practice:

• Common installation and power cables without the properties listed under code 17 04 10 are generally classified under 17 04 11.
• Code 17 04 10 is used when cables contain oil, coal tar or another hazardous substance. Paper insulation by itself does not mean that the cable is hazardous waste.
• If cables are stripped on site, separate streams of metal and insulation may arise. The metal can be classified, for example, under 17 04 01 or 17 04 02 if its nature corresponds. The insulation is assessed and classified separately according to its composition.
• Where there are doubts about hazardous properties, use the available technical documentation, product information, expert assessment or analysis.

Not sure which code your cables fall under? Misclassifying waste as hazardous or non-hazardous affects both your waste records and your ESG report. We will help you set up sorting that holds up from the site all the way to the report.

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How to report metals from cables: a six-step process

The goal is to create a traceable path from the generation of waste through weighing to final treatment.

1. Separate cables at source. Use a dedicated container or big bag. A separate stream makes correct classification easier and reduces the risk that cables are reported only as mixed construction waste.
2. Weigh every collection. Preferably use weighbridge tickets and documents from an authorised facility. A volume-based estimate may only be used if the estimation methodology is properly described and documented.
3. Request yield data. Ask the processor for the weight of the individual output fractions, such as copper, aluminium, plastic and residues, or a justified yield for the specific batch.
4. Assign the treatment method according to the actual operation. The metal fraction may, if the conditions are met, constitute metal recycling, i.e. R4. The plastic or other organic fraction may be recycling if the actual process corresponds to it, or another form of recovery or disposal.
5. Distinguish own streams from subcontractor streams. If a subcontractor removes the cables, contractually require documents on the quantity, catalogue number and final treatment method. If the final destination cannot be reliably determined, assess whether the stream should be reported as waste with an unknown final destination.
6. Link the data to inputs under E5-4. If the company purchases materials with a declared share of recycled content, it may be relevant to report this in the section on resource inflows. However, recycled content in inputs and recycling of own waste are two different datapoints.

If you are feeling lost, contact us. We will guide you through the entire process: from separate collection on site, through data from the processor, to figures ready for your report.

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Practical example: refurbishment of an office building

The following example is illustrative. The refurbishment included dismantling the electrical installation. The building handed over 4.8 t of cables classified under 17 04 11 and 0.6 t of cables classified under 17 04 10. The processor provided data on the output fractions.

Important: R1 is a recovery operation, not a disposal operation. In ESRS E5-5, energy recovery that meets the R1 conditions is reported as other recovery, not as incineration under disposal. The exact classification must be based on the facility's documentation.

If the first three fractions from stream 17 04 11 are considered recycling, the calculation is:

recycling rate = (2.60 + 0.40 + 0.50) / 4.80 × 100% = 72.9%

This result is the recycling share within the illustrative stream above, assuming all three fractions were actually recycled. It is not automatically identical to the Slovak 70% target or to any single universal ESRS indicator.

R1 energy recovery is not considered recycling. Under the Slovak 70% target, it is also distinguished from material recovery. In ESRS E5-5, however, it may fall under the category other recovery if it meets the relevant conditions.

From the table it can also be calculated that copper and aluminium together amount to 3.25 t. Compared to the total weight of 5.40 t of both cable streams, this is approximately 60.2%. The report should clearly state whether this is the weight of the output metal fraction or the weight of material that has achieved product status after meeting end-of-waste conditions.

Documentation for data assurance

A sustainability statement under the CSRD is subject to assurance to the extent and at the level of assurance resulting from the applicable rules and the relevant period. For cable streams, it is advisable to prepare in particular:

• weighbridge tickets for every collection,
• the date, weight and catalogue number of the waste,
• waste records and the relevant reports under the Slovak Waste Act,
• a contract with the authorised collector or facility,
• proof of the facility's authorisation for the relevant treatment method,
• the processor's confirmation of the output fractions and the relevant operations,
• documents on the final destination of the waste or material,
• a calculation methodology that separates measurement from estimation.

If the company uses estimates, it should state which values were estimated, why direct measurement was not possible and on what basis the estimate was calculated.

Will your data hold up under assurance? We will review your waste records, documents from collectors and your calculation methodology, and show you where an auditor might find gaps.

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Most common mistakes when reporting cables

1. The entire weight of the cables is reported as recycling. Only some output fractions may be recycled. Without yield data, such reporting is often unjustified.
2. Energy recovery is reported as recycling. R1 may be other recovery, but not recycling.
3. R1 is labelled as disposal. If the operation genuinely meets the R1 conditions, it is a recovery operation.
4. Oil-filled cables are confused with paper-insulated cables. Hazardousness must be assessed based on the presence of oil, coal tar or other hazardous substances and on the relevant properties of the waste.
5. Scrap sales are left out of the records. Payment alone does not determine whether the material was waste. If it was, the relevant records and transfer documents must be in place.
6. Subcontractor data is missing. The contract should govern the handover of data on quantity, classification and final treatment method.

Frequently asked questions

Does a construction company still have to report waste under the ESRS after Omnibus?

The obligation depends on the CSRD scope, the relevant financial year and transposition in the Member State. A company outside the CSRD scope may report data voluntarily or provide it at the request of a customer, bank or public contracting authority. Obligations under the Slovak Waste Act must be assessed separately.

Do cables count towards the Slovak 70% target?

Cables under code 17 04 11 and separated metals under codes 17 04 01 and 17 04 02 may be among the waste counted in the calculation if they meet the conditions of the relevant legal framework. Hazardous waste, such as cables correctly classified under 17 04 10, is excluded from this target. The exact calculation must be made in accordance with current Slovak law and project records.

How do I find out how much copper came from the cables?

Most reliably from the processor that sorts or granulates the cables. Where possible, the figure should be tied to a specific batch and should distinguish input weight, output fractions and any residues.

Is the sale of cable scrap reported as waste even if the company was paid for it?

If the material met the definition of waste, income from its sale does not change that fact by itself. It must be assessed whether the material remained waste or met the end-of-waste conditions, and the documentation must be kept accordingly.

When will the revised ESRS start to apply?

Delegated Regulation (EU) 2026/1563 is to enter into force on 10 November 2026 and applies to financial years beginning on or after 1 January 2027. For financial year 2026, it contains transitional options that must be assessed according to the company's scope and the rules applied.

Conclusion

Cables can be a useful and well-traceable waste stream if they are separated on site, weighed and handed over to an authorised facility. However, an ESG report should not label the entire weight of a cable as recycling. Metal fractions, insulation, residues, hazardous and non-hazardous waste must be distinguished, as must recycling, other recovery and disposal.

When reporting in 2026, it is also necessary to distinguish between the ESRS applicable to the specific financial year, the Slovak 70% target for selected construction and demolition waste, and the DNSH criteria under the EU Taxonomy. These are related but not identical requirements.

Want to get cables and construction waste right in your ESG report? We will help you set up data collection, subcontractor contracts and calculations so that they are traceable and ready for assurance.

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Sources

• European Commission – adoption of the revised ESRS on 3 July 2026
• Commission Delegated Regulation (EU) 2026/1563 – revised ESRS
• Directive (EU) 2026/470 – Omnibus I
• EFRAG Knowledge Hub – ESRS E5
• Slov-Lex – Act No. 79/2015 Coll. on Waste (in Slovak)
• Slov-Lex – Waste Catalogue under Decree No. 365/2015 Coll. (in Slovak)
• EUR-Lex – Directive 2008/98/EC on waste, Annexes I and II
• EUR-Lex – EU Taxonomy technical screening criteria