CSRD for Industrial Suppliers: Sustainability Reporting in Manufacturing Supply Chains
Whether you’re a small business, supplier or subsidiary in a European manufacturing chain, CSRD can feel like something designed for much larger organisations. Some facilities will report under CSRD directly, while many others use the VSME Standard voluntarily to support customer requests. Either way, structured sustainability reporting helps your organisation share credible data, avoid repeated questionnaires and position your plant as a trusted supplier.
Large manufacturers increasingly depend on accurate sustainability data from their supply chain. This is built into the CSRD framework, where the Directive highlights how business partners rely on sustainability information “to understand and, where necessary, report on their sustainability risks and impacts throughout their own value chains” . For industrial suppliers all across Europe, this means better data processes are not only a compliance step — they are becoming a commercial expectation.
This guide explains what manufacturers need from their suppliers, the formats you’re likely to receive, and how your facility can provide data confidently without enterprise software or consultants. For a deeper starting point, see the CSRD compliance topic hub, which outlines foundational concepts used throughout this article.
What CSRD Means for Manufacturing Supply Chains
Although many suppliers are not legally in scope for CSRD, the Directive creates new responsibilities for the large companies you sell to. Those companies must report detailed environmental, social and governance information under ESRS. They must also include value-chain impacts, meaning they need reliable data about your energy use, workforce conditions, waste and — where relevant — upstream Scope 3 emissions.
Under the VSME Standard, suppliers can report proportionate information that directly meets customer needs. The standard’s goal is explicit: helping SMEs “satisfy the data needs of large undertakings requesting sustainability information from their suppliers” . This is why many European manufacturers now ask suppliers to provide structured data annually.
Good supplier reporting reduces back-and-forth communication, shortens onboarding cycles and removes bottlenecks in customer audits. To understand timelines, the article CSRD deadlines by country (2025–2028) shows when your customers begin reporting, which is usually the point at which supplier requests increase.
What Large Manufacturers Need From Their Suppliers
Industrial buyers typically request three clusters of information:
1. Environmental data
Energy use, emissions and waste are central to ESRS and mirrored in the VSME Basic Module. Key datapoints include:
- Total energy consumption in MWh, broken down by renewable/non-renewable sources (VSME B3)
- Scope 1 and Scope 2 GHG emissions in tCO2e (VSME B3)
- Waste volumes and recycling ratios (VSME B7)
- Water withdrawal, and consumption if processes significantly use water (VSME B6)
Manufacturers increasingly request this data quarterly or mid-year when they have internal targets. Many questionnaires mirror ESRS E1, but the VSME version is tailored to small operations and much simpler to prepare. The guide on VSME Basic Module requirements walks through each datapoint with examples.
2. Social and value-chain workforce data
ESRS S1 (own workforce) and S2 (value-chain workers) require companies to show how people in their supply chain are treated. Suppliers are usually asked for:
- Workforce size, contract type and gender split (VSME B8)
- Health and safety metrics such as injury rates (VSME B9)
- Human-rights policies or incidents (VSME Comprehensive C6/C7 where relevant)
For small factories, this is often straightforward: payroll data, training logs and accident registers usually cover most requirements.
3. Governance and policies
Buyers want to see basic governance practices, such as anti-corruption policies, equality commitments or details of sustainability initiatives. The VSME Standard treats these as short narrative disclosures (B1–B2) rather than complex frameworks.
Some suppliers also provide environmental or quality certifications (ISO 9001, ISO 14001), as these strengthen a customer’s confidence in your internal controls.
The Most Common Supplier Questionnaire Formats
Most industrial questionnaires fall into four familiar styles:
1. VSME-aligned requests
More manufacturers are adopting VSME as a standardised request form. When this happens, your annual VSME report can be attached directly to tenders, removing the need to re-enter data into multiple customer portals.
2. ESRS-extracted templates
Large manufacturers sometimes send spreadsheets containing ESRS datapoints. These can feel technical, but the overlaps with VSME are strong. If you already collect VSME data, you can usually map most fields with minimal rework.
3. Platform questionnaires
Some sectors use shared supplier platforms (e.g., automotive or electronics networks). These ask standardised questions on emissions, materials, labour practices and product compliance. VSME data helps pre-fill many sections.
4. Bespoke customer-specific questionnaires
Often built around that company’s sustainability strategy — for example:
- “Share Scope 1 and Scope 2 emissions for the past two years”
- “Provide evidence of safety training for machine operators”
- “Describe initiatives to reduce scrap material in production”
Where a question looks unfamiliar, your VSME report provides a reference point: nearly all environmental and workforce topics in ESRS appear in the Basic Module or its guidance.
How to Prepare Your Facility for CSRD-Driven Supplier Requests
1. Create a simple annual data cycle
Your customers report annually, so aligning your own internal cycle makes sharing data much easier. Many SMEs begin with a basic spreadsheet covering:
- Monthly electricity and fuel invoices
- Waste invoices and recycling receipts
- Water bills
- Injury logs and training hours
- Headcount and contract types
The article on value-chain data collection for CSRD SMEs provides a practical outline of how to organise this data.
2. Use VSME as your reporting structure
The VSME Standard offers proportionate templates, basic metrics and guidance that are directly relevant to suppliers. It is optional, but its structure matches what customers need, including:
- Clear environmental metrics (energy, GHG, water, waste)
- Workforce safety and equality data
- Disclosures on policies and planned improvements
By reporting annually in VSME format, suppliers avoid duplicate work and build a consistent dataset over time.
3. Focus on the high-impact manufacturing metrics
In most factories, a handful of numbers carry the highest value for customers:
- Energy: the largest driver of Scope 2 emissions
- Fuels: significant Scope 1 emissions in machinery, forklifts and heat processes
- Waste: scrap, offcuts, packaging and hazardous waste
- H&S: incident rates for production workers
- Material flows: relevant for cost reduction and circularity
A helpful companion resource is the guide on emission-factor selection if you need to calculate CO₂ from fuel or refrigerant use.
4. Establish simple governance and policy statements
Buyers want to understand your approach, not receive lengthy documents. Short, plain-language statements covering health and safety, environment, equality, and anti-corruption are ideal — this is exactly how the VSME disclosure B2 is designed .
5. Share your report proactively
A well-prepared VSME report strengthens tender submissions and reduces customer onboarding time. Many industrial suppliers now send their sustainability report alongside financial documents when bidding for work.
How to Position Your Organisation as a Sustainable Industrial Supplier
1. Show consistency
Even small factories can demonstrate reliability by reporting the same set of metrics every year. The VSME requirement to provide comparable information after the first year (paragraph 12) supports this approach .
2. Highlight ongoing improvements
Small steps matter: LED upgrades, machinery insulation, compressed-air leak checks, recycling partnerships, or workforce training programmes. Under VSME B2, organisations can explain future initiatives and targets, which helps customers evaluate your progress.
3. Keep documentation simple and verifiable
The VSME Standard emphasises relevance, comparability and verifiability (paragraphs 8–11) . This means attaching clear evidence — invoices, logs, certificates — rather than complex narrative text.
4. Use supplier portals to your advantage
Many customers allow you to upload annual sustainability information once, then reuse it for multiple products or contracts. A structured VSME report fits neatly into this requirement.
Frequently Asked Questions
Do industrial suppliers need to comply with CSRD directly?
Most suppliers do not report under CSRD unless they meet size thresholds, but many still need to provide data to customers who are in scope. CSRD requires large companies to report value-chain data, which is why suppliers are increasingly involved. If you’re unsure how this applies, the guide on CSRD for SMEs provides a clear overview.
What sustainability metrics matter most for manufacturing suppliers?
Energy, emissions, waste and workforce safety are the top priorities for most industrial customers. These topics align directly with ESRS requirements and the VSME Basic Module, making them simple to collect and share. You can explore these metrics in detail in the article on VSME Basic Module requirements.
How often should suppliers update sustainability data for their customers?
Annual updates are usually enough because CSRD reports are annual. Some manufacturers request quarterly energy or waste figures to improve their forecasting. Establishing an annual VSME reporting cycle helps you respond to requests efficiently.
Can small factories handle CSRD-related requests without consultants?
Yes. Most SMEs use invoices and existing logs to complete the VSME Basic Module. Software can reduce manual work, but it is not required. The step-by-step guide on value-chain data collection for CSRD SMEs shows how small teams can manage this confidently.
Key Terms
- CSRD: EU directive requiring large and listed companies to publish detailed sustainability information.
- ESRS: European Sustainability Reporting Standards used by in-scope companies.
- VSME: Voluntary sustainability reporting standard for non-listed micro, small and medium organisations.
- Scope 1 / Scope 2 emissions: Direct fuel emissions and emissions from purchased energy.
- Value-chain workers: People employed in supplier organisations whose working conditions affect CSRD disclosures.
Conclusion
Manufacturing supply chains across Europe are entering a new phase of transparency. Even when suppliers are not directly in scope for CSRD, their data is essential for customers who must meet strict reporting requirements. The VSME Standard gives SMEs a clear, proportionate way to structure this information and present it professionally.
With a clear structure and consistent effort, CSRD becomes an advantage — not an obstacle.