CSRD: Climate Data from Asian Suppliers

Asian suppliers do not become subject to the Corporate Sustainability Reporting Directive simply because they sell to Europe. They do, however, sit inside the value chains that an in-scope European group must understand. The practical task for a buyer is therefore not to send every factory the full European Sustainability Reporting Standards questionnaire. It is to collect enough reliable information to assess material climate impacts, calculate relevant Scope 3 emissions and support procurement decisions, while respecting the new limits on supplier requests.

The 2026 reforms make that distinction more important. They reduce the population of companies directly in scope and simplify the standards, yet preserve the need for material value-chain information. A good data programme should now be narrower, more explicit about purpose and better connected to decisions.

What changed in 2026 — and what did not

On 3 July 2026, the European Commission adopted revised ESRS and a voluntary standard for smaller companies. The Commission said mandatory datapoints were reduced by more than 60%, with the revised standards intended to apply from financial year 2027 and available as an option for 2026 reporting 1. Reporting teams should document which ESRS version they use for 2026 rather than mixing requirements silently.

The underlying Omnibus I reform also narrowed CSRD scope. The Council’s final approval described the main threshold as more than 1,000 employees and more than €450 million net annual turnover, with separate thresholds for third-country groups 2. A company should confirm its own legal position with its reporting and legal advisers; a supplier questionnaire is not a substitute for a scope assessment.

What remains is the need to report material sustainability impacts, risks and opportunities, including material value-chain information. Climate reporting can still depend on data about purchased materials, contract manufacturing, logistics, product use and end of life. Fewer datapoints do not make those emissions disappear.

The value-chain cap changes how buyers should ask

The 2026 value-chain cap protects partners with 1,000 employees or fewer from being required to provide more information for CSRD reporting than the voluntary standard permits. An in-scope company may request additional data, but it must identify what exceeds the cap and tell the partner that it has a statutory right to decline. The Commission also says buyers should request only the information they actually need, not the maximum theoretically permitted 3.

This calls for three changes to supplier engagement:

• label every field by purpose: required for CSRD reporting, requested for a commercial or product need, or optional for collaboration;
• route suppliers by employee band and request type before issuing a questionnaire;
• explain how the data will be used, retained and checked, with a named contact for questions.

The cap does not prohibit proportionate commercial requests, such as product-footprint evidence for a tender. It does prevent buyers from presenting every desirable datapoint as a mandatory CSRD requirement. Clear labelling reduces legal risk and often improves response quality because suppliers can focus on the evidence that matters.

Build a tiered climate-data request

A single form is rarely appropriate for a trading company, a component maker and an energy-intensive factory. Use a common core, then add modules according to materiality and the procurement decision.

Tier 1: core organisational and energy data

Ask all selected suppliers for:

• legal entity, parent group, reporting period, sites serving the buyer and headcount band;
• electricity, heat, steam, cooling and fuel consumption by relevant site;
• gross Scope 1 and location-based Scope 2 emissions, with market-based Scope 2 where available;
• organisational boundary, consolidation approach, emission-factor source and calculation year;
• renewable-electricity instruments, on-site generation and supporting contracts or certificates;
• reduction targets, base year, target boundary and major actions completed or planned.

The Commission’s voluntary reporting recommendation for SMEs uses energy, Scope 1, location-based Scope 2 and emissions intensity as a proportionate core 7. This is a useful starting architecture, although reporting teams must apply the version of the voluntary standard and value-chain cap that is legally relevant to their request.

Tier 2: category and product data

Add this module only where purchased goods or services are material. Request physical quantities, product or material definitions, cradle-to-gate boundaries, product carbon footprints, allocation rules, primary-data share, factor sources and assurance status. For a contract manufacturer, capture the energy and process emissions associated with the buyer’s production rather than the supplier’s total corporate footprint alone.

The GHG Protocol calculation guidance distinguishes supplier-specific, hybrid, average-data and spend-based methods. It recommends collecting the methodology, data sources, assurance and proportion of primary data when supplier-specific product information is used 6. Those fields make a number traceable and comparable over time.

Tier 3: evidence for priority suppliers

For the highest-emitting or highest-risk suppliers, request source files: utility bills, fuel ledgers, meter exports, production volumes, allocation workbooks, renewable-electricity certificates and verification statements. Ask for this evidence through a controlled channel, not by email chains with unclear access rights.

Priority should depend on estimated emissions, strategic importance, data uncertainty and ability to influence change. It should not reward suppliers merely for producing polished reports.

Handle missing data without hiding uncertainty

Supplier data will be incomplete, especially below tier one. The Commission’s implementation FAQ confirms that estimates may be used in certain value-chain circumstances rather than collecting every figure directly 4. EFRAG’s earlier IG 2 explains value-chain reporting under the 2023 ESRS and remains useful for companies applying that version in 2026, but EFRAG notes that it is non-authoritative and has not been updated for the revised standards 5.

Treat every estimate as a record with:

• the activity data, factor, currency and unit used;
• the reporting period and geography;
• the organisational and product boundary;
• the allocation or extrapolation method;
• a confidence rating and owner;
• the condition that would trigger replacement with primary data.

Use spend-based factors for screening, not for judging supplier performance. Where an emissions hotspot is material, move towards physical activity data, then supplier-specific site or product data. Keep the original estimate so reviewers can understand why the result changed.

Check the evidence in an Asian supply-chain context

Asia is not one data environment. Electricity factors, renewable-energy instruments, fiscal years and evidence practices vary across China, Hong Kong, Taiwan, India, Vietnam and other sourcing markets. A robust review should therefore confirm the exact facility and legal entity rather than relying on a group-level sustainability report.

Check whether electricity consumption covers the production site serving the buyer, whether certificates match the market and period, and whether captive generation or purchased steam is included. For process-heavy categories, reconcile production volumes with fuel, electricity and material inputs. For outsourced steps, identify whether finishing, heat treatment, dyeing, assembly or logistics has been excluded from the supplier’s boundary.

Standardise units and retain the original submission. Record translations and conversions. Ask local procurement or engineering teams to investigate anomalies before assuming that a supplier is uncooperative. A sudden fall in emissions may reflect a boundary change, lower production or a new factor rather than operational decarbonisation.

Turn reporting data into procurement action

The value of supplier data is not the questionnaire completion rate. It is the decisions the evidence supports. CDP’s 2026 supply-chain work emphasises integrating disclosure data into procurement and combining data points to manage material risks 8.

Connect the dataset to four workflows:

1. Inventory: calculate Scope 3 with transparent methods and uncertainty.
2. Sourcing: compare bids only where boundaries and data quality are sufficiently consistent.
3. Engagement: prioritise efficiency, renewable electricity, material substitution and process changes.
4. Assurance: preserve source evidence, approvals, factor versions and change logs.

A practical 90-day launch starts with mapping material categories and supplier populations, then pilots the tiered request with 10–20 suppliers across different markets and sizes. Review response burden as well as data quality. In the final month, approve calculation rules, escalation paths and a data-improvement roadmap.

The process should connect with a wider supplier carbon-data strategy and a consistent supplier assessment checklist. To design a proportionate request that supports both CSRD reporting and procurement in Asia, talk to our team.