Article · For SME suppliers

Your customer asked for ESG data. Now what?

Published 25 June 2026 · The Circular Bulb

What the Empowering Consumers Directive actually does

The Empowering Consumers for the Green Transition Directive, often shortened to ECGT, is EU law that tightens the rules on how companies talk about sustainability to consumers. It bans vague, generic claims such as "eco-friendly" or "green" when they cannot be backed up, and it restricts the use of sustainability labels that are not based on a recognised certification scheme. Member states are transposing it into national law, with the rules taking effect in 2026.

It is a consumer-protection law, so at first glance it looks like a problem for big consumer brands, not for an industrial or logistics supplier. The catch is in how those brands comply.

Why this lands on suppliers

A large company can only substantiate a claim about its product if it knows what is inside that product and how it was made. That information lives with its suppliers. So the practical effect of the directive is a wave of data requests flowing down the supply chain: carbon footprints for specific materials, recycled-content figures, energy and emissions data, and evidence behind any environmental attribute the customer wants to advertise.

For an SME supplier, this usually shows up as a questionnaire attached to a tender or a contract renewal, or as an EcoVadis assessment request. The customer is not being difficult. They are passing on a legal obligation of their own, and they will favour suppliers who make it easy to comply.

What a supplier can do to be ready

1. Know what you are being asked. Most requests map to a small set of recurring topics: carbon data, materials and recycled content, energy use, and basic governance and social policies. Read past questionnaires and find the pattern.
2. Find the data you already hold. Energy bills, production records, purchasing data and safety systems already contain much of what is asked. The gap is usually in pulling it together, not in collecting something new.
3. Do a materiality check. Identify which Environmental, Social and Governance topics actually matter for your business and your customers, so you spend effort only where it counts rather than chasing every possible metric.
4. Build it once, reuse it. A structured sustainability baseline turns each future request into a quick update rather than a fresh scramble. This is the difference between a cost and an asset.
5. Turn the answer into a selling point. A supplier that can hand over credible data quickly becomes the easy choice at tender, and a preferred supplier as customers tighten their own reporting.

The shift worth seeing

Treated as a one-off chore, a customer ESG request is pure cost. Treated as a prompt to organise your sustainability data properly, it becomes business intelligence: a clearer view of energy use, waste, cost and risk that helps the business beyond the questionnaire. That is the shift The Circular Bulb helps suppliers around the Port of Rotterdam make. A worked example is in the case study.

This article reflects The Circular Bulb's interpretation of the current regulatory landscape and is provided for general information. TCB is not a law firm and does not provide legal advice. Verify obligations that apply to your specific business before acting.