Certain BRSR disclosures consistently generate confusion, data gaps, and revision rounds across manufacturing clients. These are not necessarily the most complex disclosures, they are the ones where the data is scattered, the format is ambiguous, or the underlying concept is misunderstood. Here are the five that come up most often.

1. P6-E1: GHG emissions, Scope confusion

The most common mistake is reporting Scope 1 (diesel, LPG) but omitting Scope 2 (grid electricity). Both are required under P6-E1. A second common mistake is reporting in kg CO2e rather than tCO2e — divide by 1,000. Third: using a stale CEA factor. Use version 21.0 (0.710 kg CO2e/kWh) for FY 2025-26.

2. P3-E1: Total workforce, contractor headcount

P3-E1 asks for total workforce including contractual workers, part-time workers, and workers from staffing agencies. Most HR systems track only permanent and direct-hire contract employees. The contractors from third-party staffing agencies (security, housekeeping, logistics) are almost always missed. Ask for the third-party contractor headcount from the facilities or admin team, not just HR.

What to collect

For each worker category (permanent employees, other-than-permanent employees, permanent workers, other-than-permanent workers), collect: total count, male/female split, and whether they are differently-abled. Separately collect the part-time and on-call headcount.

3. P2-E3 & P2-E4: Extended Producer Responsibility

EPR covers plastic packaging (Plastic Waste Management Rules 2022), e-waste (E-Waste Management Rules 2022), and battery waste (Battery Waste Management Rules 2022). Manufacturing companies that use plastic packaging or sell electronics/batteries need an EPR registration with CPCB. The disclosure asks for the EPR obligations and how much was collected/recycled.

Many companies either do not have EPR registration (where required), or have it but cannot produce the CPCB portal data. This is a compliance risk beyond just the BRSR filing.

4. P6-E7: Energy intensity, wrong denominator

P6-E7 asks for energy intensity. The format allows turnover (₹ crore) or physical output (units/tonnes) as the denominator. Most manufacturers use turnover, which is fine, but common mistakes include: using gross revenue before returns/discounts, or using the previous year's turnover for the current year's intensity figure. Use net revenue for the same financial year.

5. P5-E4 & P5-E5: Wages paid to women and minimum wage

P5-E4 asks whether the company pays wages above the minimum wage, and separately asks for the wages paid to women as a percentage of total wages. The minimum wage comparison is often done at company level rather than by state (minimum wage is state-specific in India), which can give a misleading picture. The gender wage ratio is frequently unavailable because payroll is not broken out by gender.

Pull payroll data segmented by gender from the HR system.
Compare against the applicable state minimum wage for each location, not a national average.
If the company operates in multiple states, use a weighted average minimum wage.

Saaksh flags these exact fields

When you generate a BRSR readiness report for a manufacturing client in Saaksh, all five of these fields are flagged as high-attention items, with practical guidance on what data to collect and from which team.

Frequently asked questions

Why do manufacturers struggle more with BRSR than service companies?

Manufacturing companies have more complex data requirements: physical energy and water inputs, waste streams, process emissions, worker safety incidents across sites, and supplier dependencies. Service companies have fewer mandatory disclosures and can mark several manufacturing-specific fields as not applicable.

Which team is usually responsible for P6-E1 GHG data in a manufacturing company?

P6-E1 is typically owned by the EHS (Environment, Health and Safety) team or the Plant Engineering team. Fuel consumption records usually sit with the procurement or engineering department, while electricity data comes from the utilities or accounts team.

How detailed does the waste data need to be for P6-E3?

BRSR P6-E3 requires total waste generated (in metric tonnes), broken down by hazardous and non-hazardous, with disposal method (recycled, incinerated, landfilled, co-processed). For PCB-consented or Schedule H waste, the quantity figures should match the CPCB/State PCB records.

What is the minimum wage comparison for P3?

BRSR asks whether the company pays all workers at least the applicable state minimum wage. The comparison must be against the state minimum wage notified by the state government for the relevant category and location, not a national average. Multi-state manufacturers need this data for each location.

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