CSRD Omnibus and Maritime Suppliers: What the Value-Chain Cap Actually Changes

The value-chain cap: what it is and why it was introduced

One of the most significant practical changes in the CSRD Omnibus I Directive, which entered into force on 18 March 2026, is the introduction of a value-chain cap on sustainability data requests.

Under the original CSRD, large companies required to report under the European Sustainability Reporting Standards (ESRS) were expected to collect sustainability data from their entire value chain — including suppliers of all sizes. In practice, this meant that a single large shipowner could demand detailed ESRS-level emissions, social, and governance data from dozens or hundreds of suppliers, many of them small and medium-sized enterprises with no reporting infrastructure of their own.

The Omnibus addresses this directly. CSRD-reporting companies may no longer require suppliers with fewer than 1,000 employees to provide sustainability data beyond what is covered by the forthcoming Voluntary SME Standard (VSME). The European Commission is required to publish the VSME content by July 2026.

For maritime suppliers and OEMs, this is a meaningful change. It sets a ceiling on what your largest customers can formally demand from you through their CSRD process.

What the value-chain cap covers — and what it does not

The value-chain cap applies specifically to CSRD-driven data requests. If a CSRD-reporting company asks you to fill in a supplier sustainability questionnaire as part of their formal reporting process, they are limited to the scope of the VSME voluntary standard.

What the cap does not cover:

• Commercial procurement requirements. A shipowner can still require LCA data, product carbon footprints, or EPDs as a condition of doing business — this is a commercial decision, not a CSRD obligation. These requests are not constrained by the value-chain cap.
• FuelEU Maritime and EU ETS requirements. These regulations have their own data requirements, including well-to-wake lifecycle emissions data for fuel, which are independent of CSRD. Suppliers of fuel-related components and systems will still face data requests from these routes.
• EU Green Claims Directive compliance. Companies making environmental claims about their products need substantiation data. Suppliers with certified product carbon footprint data support their customers’ green claims compliance regardless of the CSRD cap.
• Voluntary sustainability commitments. Many shipowners have set their own decarbonisation targets aligned with the IMO 2050 strategy or Science-Based Targets. These drive supplier data requests independently of any regulatory requirement.

In short: the cap limits the formal CSRD pipeline. It does not limit the commercial, regulatory, or strategic motivations that drive the same data requests through other channels.

What the VSME standard will likely cover

The VSME content has not yet been published at the time of writing. Based on the EFRAG draft and the Commission’s stated intent, it is expected to cover a simplified set of climate and governance disclosures proportionate to the size and complexity of smaller businesses. This will include basic GHG emissions information — likely at the company level rather than the product level — and some governance and social indicators.

Critically, product-level carbon footprint data and full lifecycle assessments are unlikely to be within the VSME scope. This means that when a large maritime company requests product-level LCA data from a supplier, that request falls outside the CSRD value-chain cap framework entirely. It is a commercial or regulatory requirement, not a CSRD one.

Maritime suppliers should watch for the VSME publication in mid-2026 to understand the precise scope of what can be formally requested.

Why quality product climate data remains a commercial advantage

The Omnibus simplification reduces formal reporting pressure. It does not change the direction of travel in maritime procurement.

Across the maritime supply chain, buyers are increasingly using product-level emissions data as a procurement criterion — for several converging reasons:

• CSRD Scope 3 reporting. Even under the simplified ESRS, large maritime companies must report Scope 3 emissions where they are material. For most shipping operators, Scope 3 — covering the emissions embedded in the goods and services they procure — represents the largest share of their total footprint. They need data from their supply chain to report it accurately. The cap limits how they can formally request it; it does not remove the need for it.
• FuelEU Maritime well-to-wake requirements. FuelEU Maritime, in force since January 2025, requires lifecycle-based GHG calculations for vessel fuels. Suppliers of energy-related components and systems are increasingly asked to provide lifecycle data that feeds into these calculations.
• Green procurement policies. A growing number of maritime operators have adopted internal carbon pricing or green procurement frameworks that score suppliers on the quality and verifiability of their product climate data. Certified, ISO-compliant LCA data scores better than estimates.
• Customer ESG commitments. Large maritime companies with Science-Based Targets or net-zero commitments need high-quality supply chain data to demonstrate progress. Suppliers who can provide it are easier to work with and harder to replace.

The suppliers who will be best positioned in this environment are those who have invested in certified, product-level climate data — not because they are required to report it under CSRD, but because their customers need it and reward suppliers who can provide it.

What maritime suppliers should do now

The practical steps are straightforward, and the window to build a data advantage before the VSME standard is published is narrow.

Understand your current data position. Do you have product carbon footprint (PCF) calculations for your key product lines? Are they ISO 14067-compliant? Can you share them in a format your customers can use for their own reporting? If the answer to any of these is no, that is the starting point.

Prioritise your highest-volume product lines. You do not need complete LCA coverage of your entire catalogue immediately. Focus on the products that appear most frequently in your customers’ procurement data, and build out from there.

Use activity-based data where possible. Spend-based Scope 3 estimates are the lowest-quality input for your customers’ CSRD reports. Suppliers who can offer verified, activity-based product emissions data — based on actual materials, manufacturing processes, and logistics — provide a meaningfully better input. This matters increasingly as CSRD reports become subject to third-party assurance.

Consider certification. ISO 14040/14044 and ISO 14067 certification of your LCA and PCF calculations adds credibility and reduces the due diligence burden for your customers. It is also required for Environmental Product Declarations (EPDs), which are becoming standard in certain maritime procurement processes.

Monitor the VSME publication. When the Commission publishes the VSME standard in mid-2026, it will clarify exactly what can be formally requested through the CSRD value-chain process. This will help you distinguish between the formal minimum and the commercial expectation.

Frequently asked questions

Our company has 150 employees. Are we completely exempt from CSRD?

You are no longer required to produce a CSRD report. However, the value-chain cap only limits what CSRD-reporting companies can formally demand from you through their compliance process. Your customers may still require sustainability and climate data from you through commercial contracts, procurement policies, or other regulatory requirements such as FuelEU Maritime.

What is the VSME standard and when does it apply?

The Voluntary SME Standard (VSME) is a simplified sustainability reporting framework being developed for companies outside CSRD scope. The European Commission is required to publish it by July 2026. Once published, it defines the ceiling for what CSRD-reporting companies can formally request from smaller suppliers under the value-chain cap.

We already have some product carbon footprint data. Is that enough?

It depends on the quality and certification status of the data. PCF calculations based on spend-based estimation are a starting point but are increasingly insufficient for customers’ CSRD Scope 3 reporting as assurance requirements tighten. ISO 14067-certified activity-based PCF data is the standard that meets both CSRD data quality requirements and commercial procurement expectations.

How does ReFlow help maritime suppliers with this?

ReFlow’s ClimateHub platform enables maritime suppliers and OEMs to run ISO-compliant product carbon footprint calculations and lifecycle assessments without requiring in-house LCA expertise. The platform generates certified, shareable PCF data that meets ESRS E1 data quality standards and supports EPD creation. ReFlow’s environmental engineers provide advisory support for complex product categories and first-time LCA projects.