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Waste Data for ESG Reports: The Complete Guide for Malaysian Enterprises

Most Malaysian companies can't produce the waste data their ESG reports require. Here's exactly what to track, how to document it, and how to make it audit-ready.

16 April 2026Updated 30 October 20269 min read
Waste Data for ESG Reports: The Complete Guide for Malaysian Enterprises
On this page
  1. Every collection must capture six data points
  2. This is what one audit-ready quarter looks like
  3. Audit-ready records meet five standards
  4. The reporting duty binds listed companies and the largest non-listed ones
  5. We can set up these records for your sites

An ESG report covers a company's environmental, social and governance record, and waste sits under environmental. The report, and anyone who checks it, will ask six things about each pickup. They are weight, waste type, date, location, disposal destination and disposal method. If your collector gives you only invoices and bin counts, you have nothing to report from. Here is what to record, and what one real quarter of audit-ready data looks like.

Every collection must capture six data points

#Data pointWhy it mattersWhat a reviewer checks
1Weight (kg or tonnes)Every waste figure is built on it. An estimate from bin volume does not hold up when checkedWeighbridge tickets or calibrated scale readings
2Waste typeNeeded for the diversion rate and for Scope 3 emission factorsThe same categories at every site and in every period
3Date and timeKeeps the record trail wholeRecords in sequence, with no unexplained gaps
4LocationA company with several sites reports each oneEach site named the way your organisation names it
5Disposal destinationShows where the pickup ended upFacility name and type, and its licence or approval number
6Disposal methodSets the diversion rate and the emission factorLandfill, recycling, composting, waste-to-energy or reuse

Diversion means keeping waste out of landfill, by recycling, composting or reusing it. Scope 3 covers emissions you cause but do not control, like landfill gas from your waste. An emission factor turns a tonne of waste into its estimated carbon.

Weight is the one to get right first. You need a weighed figure, by waste type, with a disposal record for every pickup. Bin counts measure volume. Invoices measure cost. Bin size times collection frequency is an estimate. None of them is a weight.

"About 40 tonnes a month" is a guess. "40.02 tonnes to landfill in June" is a record, and it is a real figure from the quarter below.

If you have no weights at all yet, start with a waste audit.

This is what one audit-ready quarter looks like

These figures are real. They come from a retail mall client's report for Q2 2026, April to June, published with the client's permission. Every collection was weighed and photographed.

MonthCollectionsTo landfill (t)Recycled (t)Recycling rate
April4333.502.402.40 ÷ (33.50 + 2.40) = 6.7%
May4437.991.621.62 ÷ (37.99 + 1.62) = 4.1%
June4340.021.311.31 ÷ (40.02 + 1.31) = 3.2%
Q2 2026130111.515.335.33 ÷ (111.51 + 5.33) = 4.6%

The quarter's totals are the three months added up. Each rate has its division written out, so anyone can redo it.

The rate fell every month, from 6.7% to 4.1% to 3.2%. The report shows it as it was.

The same report counts pickups. In June, 41 of 43 scheduled pickups came on the day promised: 95.3% on time. It also states its rule: trips with no scheduled-job reference are left out of the base. That record is published on our total waste management page.

The Scope 3 estimate names its factor set and edition

Waste emissions are Scope 3, Category 5 under the GHG Protocol. The GHG Protocol is a widely used global rulebook for counting a company's carbon emissions. The report works them out from the weighed tonnes: one factor for landfill, one for recycling. The estimate is in tCO2e, tonnes of carbon dioxide equivalent: every greenhouse gas counted as CO2.

MonthThe sumEstimate (tCO2e)
April33.50 × 0.5206 + 2.40 × 0.004717.5
May37.99 × 0.5206 + 1.62 × 0.004719.8
June40.02 × 0.5206 + 1.31 × 0.004720.8
Q2 2026111.51 × 0.5206 + 5.33 × 0.004758.1

The factors are from the UK Government GHG Conversion Factors for Company Reporting (2026 edition). They are 0.5206 tCO2e per tonne of commercial waste landfilled and 0.0047 per tonne recycled. The landfill factor covers collection, transport and the landfill itself. The recycling factor covers only collection and transport to the recycler.

These carbon figures are estimates, worked out from weighed tonnage. Nothing measured CO2e at the bin. If your auditor prefers another factor set, the tonnes stay the same and the sum still checks.

The formulas for the diversion rate and four other measures are in our waste management KPI guide.

Audit-ready records meet five standards

RequirementWhat it meansCommon failure
CompletenessEvery collection recorded, with no gapsMissing records for some sites or periods
AccuracyWeighed, not estimatedVolume estimates used in place of weights
ConsistencyThe same method at every site and in every periodSites using different categories or measures
TimelinessRecorded at or near the time of collectionEntered later from memory or invoices
TraceabilityA clear trail from collection to final destinationNo disposal receipts or facility confirmations

The evidence trail has four parts

For each collection, keep:

  1. Collection record. Date, site, waste type and weight, from a weighbridge or scale.
  2. Transport record. The collector's name and its licence or approval number.
  3. Disposal confirmation. The receiving facility's name and type, and its confirmation that the pickup arrived.
  4. Reconciliation. Monthly totals that match your billing records, with every gap explained.

The licence depends on the state. Act 672 is Malaysia's solid waste law, and SWCorp enforces it in eight states and territories. In an Act 672 state, the collector needs a SWCorp licence. In Selangor, local councils and KDEB Waste Management, the state's waste company, still run solid waste today. An extension of Act 672 to Selangor in phases was announced on 29 July 2026, with no start date published. There and in the other states, ask the local council or state government which approval a collector needs.

The reporting duty binds listed companies and the largest non-listed ones

Not every business has to publish these figures. The National Sustainability Reporting Framework (NSRF) binds three groups of companies. Waste comes in through carbon, as Scope 3. Bursa's Main Market is for larger companies, and the ACE Market is for smaller, growing ones. The Securities Commission's implementation timeline sets these dates:

  • Main Market companies with a market capitalisation of RM2 billion and above disclose Scope 3 emissions for financial years beginning in 2027.
  • Other Main Market companies follow in 2028.
  • ACE Market companies, and non-listed companies with annual revenue of RM2 billion and above, follow in 2030.
  • The timeline aims for reasonable assurance of Scope 1 and Scope 2 emissions starting in 2027. Its assurance framework is still subject to consultation. Assurance means an independent auditor checks the reported figures. Scope 1 and 2 cover the fuel you burn and the electricity you buy.

Until those years, a company may leave out Scope 3 emissions, except any category its regulator already requires.

If the framework does not bind you, publishing these figures is not a legal duty. The same records still serve a customer, a certifier or a board that asks for waste figures. Start before the year you must report: a pickup that was never weighed cannot be weighed later.


We can set up these records for your sites

Every pickup GarGeon logs carries a photo, a timestamp and the weight. Your report adds them up by site and by month, with the Scope 3 estimate beside the tonnes. If you want one partner for collection, recycling and reporting at every site, see how total waste management works. Or read what our sustainability reporting covers, and book a consultation.

Related reading:

Common Questions

Frequently asked questions

Answers to the questions Malaysian businesses ask about this topic.

Book a Consultation

The framework uses IFRS S1 and IFRS S2, global standards for sustainability reports. It binds listed companies and the largest non-listed ones. IFRS S1 asks for the sustainability risks and opportunities that are material to the company. Material means important enough to change an investor's view. IFRS S2 asks for greenhouse gas emissions, and waste sits in Scope 3, Category 5. So hold three figures: tonnes generated, where they went, and the share kept out of landfill.

You need a weight for every pickup. A weighbridge ticket is the firmest record, and a calibrated scale reading also works. A weight worked out from bin size or bin count is an estimate, so label it as one. If your collector cannot give you weights, ask for weight-based billing or move to one who can.

Yes, if you label them. Say which figures are estimated and how you worked them out. Use the same method each period. Replace them with weighed figures as soon as you can. An estimate has only your method behind it, so write the method down.

Use the average-data method in the GHG Protocol's guidance for Category 5. You need the total weight of your waste and the share sent to each treatment. Multiply the tonnes for each treatment by an average emission factor, then add the results. The guidance says this method is less certain than the waste-type-specific one. Move to that once you have weights by waste type.

Treat it as a red flag. In the states where Act 672 applies, licensed collectors are required to dispose of waste at licensed facilities. In Selangor and the other states, the local council or state government sets the rules. Wherever you operate, a collector who cannot show where your waste went leaves you unable to confirm legal disposal or report a disposal method. Make destination records a condition when you choose or renew a collector.

ESG ReportingWaste DataNSRFAuditSustainabilityScope 3 EmissionsWaste Management MalaysiaDocumentation
Written by
Content Strategist

Content strategist covering practical waste management, sustainability operations, and waste diversion for Malaysian enterprises.

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