ESRS S4 Consumers and End-users
ESRS S4 is the topical social standard of CSRD reporting that requires disclosures on a company's impacts on consumers and end-users, in particular regarding product safety, consumer rights and access to information.
ESRS S4 “Consumers and End-users” is one of the four social standards within the European Sustainability Reporting Standards framework, complementing the standards on a company's own workforce (S1), workers in the value chain (S2) and affected communities (S3). Its focus is the actual and potential, positive as well as negative, impacts of a company's products and services on the people who ultimately consume or use them. ESRS S4 distinguishes typical impact categories such as information-related impacts (for example data protection, access to understandable information and protection from misleading advertising), personal safety (product safety, health protection, safeguarding particularly vulnerable groups such as children) and social inclusion (non-discriminatory access to products, services and reliable complaint channels).
Like all topical ESRS, S4 is governed by the principle of double materiality: the company must first determine, through its materiality assessment (IRO analysis), whether consumer and end-user topics are material to its business model. Where this is the case, the required disclosures must be made, following the general architecture of the social standards: a description of policies, of actions and action plans, of targets, as well as of the processes for engaging affected people (stakeholder engagement) and for providing remediation and complaint mechanisms. Equally central is the question of how the company identifies, manages and tracks the effectiveness of measures addressing material impacts.
For product safety, consumer rights and access to information, ESRS S4 demands concrete, verifiable disclosures: for instance on product and service safety procedures, the handling of recalls and incidents, transparency and labelling obligations, the accessibility of information, and the mechanisms through which consumers can raise concerns and obtain redress. These disclosures are integrated into the sustainability statement as part of the management report and are subject to external assurance (initially limited assurance). In this way ESRS S4 is closely interlinked with existing EU consumer-protection and product-safety law and makes the responsible treatment of end-users measurable and comparable.
Legal Basis
ESRS S4 (Commission Delegated Regulation (EU) 2023/2772) in conjunction with Art. 19a, 29a, 29b CSRD (Directive (EU) 2022/2464); supplemented by EU product-safety and consumer-protection law (including Regulation (EU) 2023/988 on general product safety)
Practical Example
A mid-sized manufacturer of household electronics concludes in its materiality assessment that product safety and understandable access to safety information are material to its end-users. The compliance officer therefore documents, for ESRS S4, the internal safety testing processes, the recall management of the past reporting period including the number and resolution of incidents, the multilingual and low-barrier user manuals, and a newly introduced online complaint portal through which consumers can report defects and trigger replacement services. For the report she defines measurable targets, such as a 48-hour response time for safety-relevant notifications, and links them to the general disclosures under ESRS 2 to provide auditors with a consistent chain of evidence.