For a metal processor or manufacturing company with one thousand employees or fewer, a reporting-obligated customer may no longer request more sustainability information than what is laid down in the VSME standard since March 2026. This affects two topics in this sector that often appear on questionnaires: the energy consumption of energy-intensive processes such as smelting, casting, welding and surface treatment, and the origin of raw materials such as steel, aluminium or other metals. On both points there is a difference between what the VSME asks and what some questionnaires ask in practice.
The VSME asks for your own energy consumption and associated emissions in scope 1 and 2: the fuel you burn yourself and the electricity you purchase yourself, expressed using an established emission factor. What the VSME does not ask for is process-based substantiation per production step, an audit of your energy systems, or a traceable certificate of origin for every tonne of steel or aluminium that passes through your factory. A customer who does ask for this is asking for more than the standard requires — and you are entitled to decline, with a proper wording instead of a blunt refusal.
Energy-intensive processes: what falls within the VSME
Smelting, casting and welding are energy-intensive, and that makes the topic sensitive: a customer who is themselves subject to full reporting obligations often wants to know how much their own supply chain weighs on the climate. That is an understandable interest, but the VSME limits what may be requested from a small or medium-sized company. Within the standard falls the total energy consumption of your site, broken down by fuel type and electricity, and the emissions that result from this using the established emission factors per reference date. Outside the standard falls a question about energy consumption per production line, per order or per customer — that is a level of detail that the standard does not require of an SME supplier.
The distinction is for most installation and manufacturing companies traceable from documents already on hand: the energy bill for the site, if necessary supplemented with fuel receipts for own transport or forklifts. Those who already keep these figures for compliance with the energy savings obligation already have a large part of the scope 1 and 2 picture in place. worked out per situation what applies to your sector provides an overview of this.
Origin of raw materials: where the line is drawn
Questions about the origin of steel, aluminium or other metals often stem from the customer's desire to map their own scope 3 emissions and value chain. For a large, reporting-obligated company, this may be a genuine information need. For a supplier with fewer than one thousand employees, this is precisely the type of question for which the scope 3 supply chain requirement draws a line: the VSME does not ask for a traceable chain of origin back to the mine or the smelter, nor does it ask for certification of your own suppliers on that point.
This does not mean that the question may never be asked — some customers ask for this from a different legal framework than sustainability reporting, for example concerning conflict minerals. Whether a specific question falls under that other regulation is something for which the text of that regulation or a lawyer is the appropriate source. What the VSME limit means is that a question that relies solely on sustainability reporting may not go beyond what that standard requires.
How you respond to your client
Refusing a question that falls outside the VSME does not need to escalate your conversation with your customer. Most procurement departments send questionnaires without having checked them against the supply chain obligation themselves; a brief, factual response with a reference to the standard often works better than a principled discussion. On esgia.eu, the cap check reviews every question from your list and, for a question that falls outside the VSME, formulates a response that you can use directly, without having to consult the standard yourself.
The questions that do fall within the VSME go further in the file: energy bills, fuel receipts and a printout from payroll administration together provide the majority of the figures that remain. If you are unsure whether your company falls under the supply chain obligation, or if you first want to see roughly where you stand, then provides a first indication in a few questions a starting point without needing an account right away. If you want to know exactly where the figures in the file come from and how they are recorded, you can read that in the working method behind the file.
This article describes how the supply chain obligation and the VSME standard relate to each other for energy-intensive processes and raw material sourcing in the metals and manufacturing industry; it is not legal advice on your specific questionnaire. If you have doubts about an individual question or the scope of another regulation, a lawyer or the competent supervisory authority is the appropriate place for a judgment on your situation.
Do you want to run a questionnaire along the VSME boundary yourself, or first read which topics apply to your sector? Take the free quick-scan or view the answers to questions that other entrepreneurs already asked.