The Omnibus introduced a ceiling on what large companies can formally request from smaller suppliers. Here is exactly what that means, what it does not cover, and how to prepare before the VSME standard lands in mid-2026.
Until the Omnibus I Directive entered into force on 18 March 2026, the CSRD created a cascading data obligation: large companies in scope had to report Scope 3 emissions, which meant requesting sustainability data from their suppliers, who in turn faced pressure to collect it from their own supply chains. For many smaller maritime suppliers, the prospect of receiving detailed ESRS-level data requests from multiple large customers simultaneously was a genuine operational concern.
The Omnibus addresses this with a specific mechanism: the value-chain cap. Under the revised CSRD, large companies that are required to report under ESRS may no longer demand sustainability data from smaller value-chain partners beyond the scope of the forthcoming Voluntary SME Standard (VSME). The European Commission is required to publish the VSME content by July 2026.
In practical terms: if you are a maritime equipment supplier or OEM with fewer than 1,000 employees, your large customers cannot formally require you to provide full ESRS-level sustainability disclosures through their CSRD compliance process.
The value-chain cap is narrower than it might initially appear. It applies specifically to data requests made through the CSRD formal reporting channel. It does not constrain several other routes through which the same data is requested.
A shipowner or operator can require LCA data, product carbon footprints, or EPDs as a contractual condition of procurement. This is a commercial decision, not a CSRD obligation, and is entirely unaffected by the cap. If a customer includes climate data requirements in a tender specification or supplier qualification process, those requirements stand regardless of the value-chain cap.
FuelEU Maritime, which entered into force in January 2025, requires well-to-wake lifecycle GHG calculations for vessel fuels. Suppliers of propulsion components, fuel systems, and energy-efficiency equipment are increasingly asked to provide lifecycle emissions data that feeds into these calculations. This requirement is independent of CSRD entirely.
Companies making environmental claims about their products — “low carbon”, “climate-neutral”, “reduced emissions” — must substantiate those claims under the EU Green Claims Directive. To do so, they need certified LCA or PCF data from their supply chain. Requesting this data from suppliers is a compliance requirement under a separate directive, not a CSRD request.
Many of the largest maritime operators have made voluntary net-zero or Science-Based Target commitments that require detailed Scope 3 data for progress tracking. These commitments drive supplier data requests outside of any regulatory framework. The value-chain cap has no bearing on them.
The practical implication is straightforward: the cap reduces the formal burden, but the underlying commercial and regulatory demand for product climate data continues through multiple other channels.
The VSME has not been published at the time of writing. Based on the EFRAG draft framework and the Commission’s design intent, the standard is expected to cover:
What the VSME is not expected to cover: product-level carbon footprints, full lifecycle assessments, EPD documentation, or activity-based Scope 3 data by spend category. These go beyond the scale and complexity the VSME is designed for.
This distinction matters because it defines the boundary between what customers can formally request under CSRD and what they will continue to request commercially. Product-level data sits firmly on the commercial side.
Given the window before the VSME publication in mid-2026, there are four actions worth taking now.
Before preparing anything, understand what your current and prospective customers are actually asking for. Review your last 12 months of supplier questionnaires, tender specifications, and procurement onboarding documents. Separate requests into two categories: those that reference CSRD compliance explicitly, and those that are driven by procurement policy, ESG targets, or other regulatory requirements. The value-chain cap will affect the first category only.
You do not need to calculate the carbon footprint of your entire product catalogue immediately. Start with the product lines that: (a) appear most frequently in customer data requests, (b) represent the highest share of your revenue, or (c) are most likely to face procurement competition on environmental criteria. For most maritime equipment suppliers, this means engine components, propulsion systems, or electrical equipment where OEM alternatives exist.
There are three levels of product climate data quality, each serving a different purpose:
For most maritime suppliers starting from zero, ISO 14067-compliant PCF calculations are the right first step: sufficient for CSRD Scope 3 reporting by your customers, achievable without extensive internal resources, and upgradeable to full LCA when the commercial case justifies it.
Having the data is half the task. Being able to share it in a format your customers can use directly is equally important. Customers integrating supplier data into their CSRD Scope 3 reports need data in a structured, consistent format — not a PDF with a single number on it. Consider how your PCF data will be delivered: through a platform integration, a standardised data format, or a certified EPD on a recognised programme.
The period between now and the VSME publication in mid-2026 is a narrow window in which the rules are still being defined. Suppliers who build certified product climate data infrastructure before the VSME lands will be ahead of the formal standard from day one, rather than scrambling to meet it after the fact.
More importantly, the suppliers who move first on product-level LCA and PCF data will have a genuine procurement advantage in an industry where this data is becoming a standard qualification criterion. The value-chain cap means your customers cannot formally require it through CSRD. It does not mean they will not prefer suppliers who have it.
It limits what customers can formally request through their CSRD compliance process to the scope of the VSME standard. It does not limit commercial data requests made through procurement contracts, tender specifications, or other regulatory requirements such as FuelEU Maritime. In practice, the most important data requests you receive are likely to come through commercial channels rather than formal CSRD channels.
The European Commission is required to publish the VSME by July 2026. Until then, the precise scope is not finalised. We will publish an update on this site when the VSME content is confirmed.
It depends on whether the request is explicitly tied to their CSRD formal reporting process. If it is a commercial procurement requirement or part of a supplier qualification framework, the cap does not apply. If it is a formal CSRD value-chain data request, the cap limits it to VSME scope — but only once the VSME content is published. Until July 2026, the formal VSME scope has not been defined.
A Product Carbon Footprint (PCF) is a GHG-only calculation following ISO 14067. An Environmental Product Declaration (EPD) is a certified, third-party-verified declaration of a product’s environmental performance based on a full LCA, published through a recognised programme operator. For most CSRD Scope 3 reporting purposes, a PCF is sufficient. For EPDs — which are required for some procurement processes and for substantiating green claims — a full LCA is needed. ReFlow can support both.
ReFlow’s ClimateHub platform enables maritime suppliers and OEMs to run ISO 14067-compliant product carbon footprint calculations and full lifecycle assessments without requiring in-house LCA expertise. The platform generates certified, shareable PCF data that meets ESRS E1 quality requirements. ReFlow’s environmental engineers provide hands-on advisory support for complex product categories and first LCA projects. Contact us to discuss your product portfolio and agree a starting point.