Your customer wants energy-per-part and OEE data: answering OEM supplier questionnaires after the 2026 Omnibus

Omnibus I cut the number of companies that report under the CSRD and capped what they can ask smaller suppliers. The questionnaires have not stopped. This page covers what to have ready and how to calculate it.

What changed with Omnibus I

Status as of 22 September 2026. This is a summary for operations and quality managers, not legal advice. Check the national transposition in your country.

Check whether the voluntary-standard delegated act has been published in the Official Journal before relying on its exact content.

For most plants in Czechia, Slovakia, Hungary, Romania and Poland, this means two things. Few will report under the CSRD themselves. Many will still receive requests from Western customers who do, but those requests should be narrower and more standardised than the long questionnaires of 2024.

What a CEE supplier will still be asked

The voluntary SME standard (VSME) basic module includes disclosure B3 on energy and greenhouse gas emissions: total energy consumption in MWh, split by renewable and non-renewable and by electricity and fuels; gross Scope 1 and location-based Scope 2 emissions; and GHG intensity per unit of turnover (EFRAG Knowledge Hub, VSME Annex I). If you are under 1,000 employees, expect a customer's CSRD-driven request to look like this. It is company-level data. It is not per part.

Customers also ask for things that have nothing to do with the CSRD: delivery performance, quality (ppm, complaints), capacity and OEE on lines that run their parts, and sometimes energy or carbon per part for product-level footprints. The cap is written around sustainability information requested for reporting. Whether a purchasing or product-footprint question falls under it is a legal question. Ask the customer which basis the request has, and get advice if the answer matters to you.

Why energy per good part needs machine-state data

Dividing the plant's monthly kWh by parts shipped gives a number. It mixes lighting, compressed air, heating and every product family. It moves when the product mix moves. It cannot tell you whether an improvement came from better machines or from a lucky month.

A useful energy-per-part figure needs three things per machine or line: energy consumed (a meter or a sub-meter), the time spent in each state (producing, idle, stopped, changeover), and good-part counts. With those you can separate energy used making good parts from energy used while the machine is idle, making scrap or waiting. Idle and scrap energy is where suppliers usually find something to fix. It is also the same state and count data that feeds OEE, so one data layer serves both the maintenance objectives in IATF 16949 §8.5.1.5 and the customer's energy question.

Industrial electricity prices in the region

Source: Eurostat nrg_pc_205, band MWH2000-19999, I_TAX, EUR, 2025-S2. Differences are our calculation.

Mid-size plants in all five countries paid more than the EU average in the second half of 2025, and Hungary and Slovakia were close to German levels. For a plant in this band, idle-machine energy is a cost line, not only a reporting item.

The answer kit: numbers to have ready

The first three rows follow the VSME basic module disclosure B3 (Recommendation (EU) 2025/1710). The other rows are common commercial requests, not regulatory requirements.

How to calculate energy per good part

Energy per good part (kWh/part) = energy consumed by the line in the period ÷ good parts produced in the period.

Then split the energy by machine state. Productive energy share = kWh while producing ÷ total kWh. The rest is idle, stopped, changeover or start-up energy. Scrap energy ≈ kWh while producing × (scrap parts ÷ total parts).

Illustrative numbers, not data from any plant: a press line uses 42,000 kWh in a month and makes 150,000 good parts, which is 0.28 kWh per good part. If 30% of the kWh was consumed while the line was idle or stopped, 12,600 kWh bought no parts. At the Polish 2025-S2 band price of €0.214/kWh, that is about €2,700 for the month on one line.

• Use the same period and the same good-count definition as your OEE, so the two figures agree.
• Allocate shared utilities (compressed air, chillers) by a written rule, or report them separately. Do not hide them in one line's figure.
• Report per part family, not per plant, when the customer only buys one family.

What not to over-promise

• Do not send per-part figures you cannot reproduce. If the number came from a plant total divided by shipments, say so. Customers compare year to year.
• Do not promise real-time data feeds to a customer portal unless you have the capture, the definitions and someone to maintain them.
• Do not answer more than was asked. If you are under 1,000 employees and the request is CSRD-driven, the voluntary standard sets the limit of what the customer may request. Answering beyond it is your choice.
• Do not commit to reduction targets before you have twelve months of baseline at the granularity you will be measured on.
• Do not treat OEE shared with a customer as an internal target. Agree the definition in writing first, especially planned downtime and ideal cycle time.

This site is published by TEEPTRAK SAS, which sells production-monitoring and OEE software. The machine-state and count data described here can equally come from an MES, from PLC data collected by an integrator, or from sub-meters logged in a spreadsheet as a first step.

• IATF 16949 §8.5.1.5: OEE, MTBF and MTTR audit evidence
• IATF TPM Evidence Pack, with energy-per-part sheet
• Why the data layer comes before AI

Questions

Does the CSRD apply to my plant after Omnibus I?

Only if your company or group has more than 1,000 employees and more than €450m net turnover, under the thresholds published on 26 February 2026. National transposition is due by 19 March 2027. Most CEE supplier plants will fall below these thresholds, but their customers may not.

Can my customer still ask me for sustainability data if we have fewer than 1,000 employees?

Yes, within limits. The value-chain cap restricts CSRD-reporting companies to the information covered by the voluntary standard derived from the VSME Recommendation. Its basic module includes company energy use and Scope 1 and 2 emissions. Commercial requests may follow other rules; ask the customer which basis applies.

Is energy per part required by the VSME standard?

No. Disclosure B3 of the basic module covers total energy consumption, Scope 1 and location-based Scope 2 emissions and GHG intensity per turnover, all at company level. Per-part figures usually come from customer purchasing or product-footprint requests.

Can I calculate energy per part without sub-meters?

You can allocate the plant's energy by machine hours or rated power, but the result is an estimate and should be labelled as one. For a figure you can defend and improve, meter the main consumers and record machine states and good counts for the same period.

Should we share OEE with our customer?

Many suppliers do, especially for lines dedicated to a customer's parts. Agree the definitions first, including planned downtime and ideal cycle time, and share monthly figures you can reproduce rather than live screens.

Sources

1. Latham & Watkins, EU Sustainability Omnibus published in the Official Journal (27 Feb 2026)
2. Linklaters, Commission adopts revised ESRS and voluntary reporting standard (2026)
3. EFRAG Knowledge Hub, VSME Standard (Annex I to Recommendation (EU) 2025/1710)
4. Eurostat nrg_pc_205, electricity prices for non-household consumers (2025-S2)

Published by TEEPTRAK SAS, which makes production-monitoring and OEE software, with an office in Bucharest (TEEPTRAK SRL). Figures are sourced on each page. Funding rules change: check the official call documents before you budget.