A metal processor or manufacturing company receiving a sustainability questionnaire often sees questions that go beyond an energy bill: about the origin of steel or aluminium, the share of recycled material, emissions per production process. The VSME standard (the voluntary EU reporting standard for unlisted SMEs) determines what a customer may reasonably ask of a supplier with one thousand employees or fewer. Energy consumption at company level falls under this, as does fuel consumption of the vehicle fleet. A breakdown per production line, per furnace or per alloy generally does not.
The same applies to raw materials: the standard calls for a broad overview of the main material flows, not a traceable statement of origin per batch of metal or a supplier audit further down the chain. Where a questionnaire does require that, it goes beyond what the standard prescribes for an SME supplier — and that is precisely the distinction the new supply chain provision has targeted since March 2026.
Energy-intensive processes: what the standard does ask for
Smelting, rolling, pressing and heat treatment require substantial energy, and that consumption is usually well documented in the company's energy bill or meter readings. The VSME standard asks for this consumption to be reported at company level, broken down by energy source: electricity, natural gas, possibly other fuels. That is a sum that can be compiled from existing invoices, without requiring a separate measurement per machine or per process.
What the standard does not ask for is a process-specific link between energy consumption and emissions per production step, as sometimes occurs in questionnaires from large industrial customers. Such requests are not necessarily inadmissible — a customer may ask for more than the standard prescribes if that falls outside the scope of the supply chain provision, for example because it concerns a separate procurement requirement rather than sustainability reporting. It is, however, the point at which it makes sense to consider whether the question falls under the supply chain provision or not, and that distinction is precisely what the capcheck on esgia.eu helps with: for each question it is indicated whether it fits within the standard.
Raw materials and origin: what is included, what is not
The VSME standard asks for a concise overview of the main material flows and, where relevant, the share of reused or recycled material. For a manufacturing company this typically means an estimate based on procurement data: how many tonnes of steel, aluminium or plastic were purchased in a year, and what proportion of that is demonstrably recycled.
What falls outside the standard is a complete chain of origin per raw material batch, a statement about the mine or smelter of origin, or an audit of your own suppliers. That kind of information belongs in the reporting of the large enterprise itself, which must look deeper into the chain for its own scope 3 figures — but the supply chain provision limits what it may demand of a smaller supplier for that purpose. Anyone in doubt about whether a specific question on raw material origin falls within that boundary will find the overview of topics per situation a detailed explanation for each type of question.
What the standard deliberately leaves out of consideration
The VSME standard was designed as a lightweight, voluntary standard, specifically to avoid burdening smaller companies with the same reporting requirements as a listed company. This means that topics such as a full life cycle assessment per product, a climate scenario analysis, or an extensive biodiversity section are not appropriate for a metal company of this size. A questionnaire asking for these items goes beyond what the standard requires, and a polite refusal or a request for clarification is warranted.
It is important to understand that this does not result in a mark or certificate — for SME sustainability reporting, there is currently no recognised body, not even for esgia. What the standard does provide is a fixed benchmark against which to measure a questionnaire, and that is exactly what many metal companies need when a customer, bank or insurer comes with an extensive list.
Preparing the conversation with the customer
If it turns out that part of the questionnaire falls outside the VSME standard, the next step is usually a conversation with the buyer or sustainability contact person at the customer. That conversation will go more smoothly with a concrete reference to the standard and an explanation of why a question does not fit there, rather than a general refusal. For companies that want to see how such a review works in practice, an explanation of the methodology and sources used is available, including where to find the standard itself.
The remaining questions — those that do fall within the standard — can usually be answered largely from documents that are already in place for a metal company: the energy bill, fuel receipts for the vehicle fleet, a printout from the payroll system for personnel figures. Frequently asked questions about what is and is not needed in this context are collected on the page with answers to frequently asked questions.
Anyone who wants to see in a few minutes which questions from a received list fall within the VSME standard can check this for free and without an account via the quick scan with a direct indication. This gives a first picture before time is spent working through each individual question.