Can a small supplier refuse a customer's carbon questionnaire?

Partly. Directive (EU) 2026/470 gives protected undertakings, those with up to 1,000 employees, the right to refuse information requests that go beyond the standards specified for voluntary use, and requires the reporting undertaking to inform them of that right. It does not release you from a contractual requirement you have already signed, and it does not apply to schemes like Catena-X that a customer imposes through the supply agreement. Read the request against the voluntary standard before answering all of it.

What is a primary data share and why does it matter commercially?

It is the percentage of a product carbon footprint based on direct measurement rather than industry averages, and Catena-X requires it to be reported. It matters because it is a quality score on your answer that the customer can compare across suppliers. A plant with machine-level metering can declare a high share; a plant working from annual invoices and average factors cannot, whatever its actual emissions are.

Does energy per part have to be per good part?

For an energy performance indicator, yes in practice: scrap moves the denominator, so a scrap-blind figure drifts for reasons unrelated to energy performance. For a product carbon footprint, the declared unit is one piece as described in the part description with a defined weight and part ID, and the energy attributed to it has to include the energy spent making the parts that were scrapped, because that energy was really consumed. Keep scrap as an explicit variable so both views are producible from the same data.

How fine does the sampling interval have to be?

One minute or finer at machine level if energy has to be attributed to a part, a cycle or a batch; anything coarser cannot separate producing from idle. 15 minutes at feeder or area level, which matches the European settlement interval and therefore reconciles with the utility bill. Monthly is enough at the reporting layer. The collection period also has to be documented, because temporal representativeness is one of the graded data quality criteria.

What is the single artefact worth building first?

The reconciliation chain: machine meters to area meters to site incomers to the utility invoice to the figure you report, each link with a stated tolerance. It is the only artefact that answers the certification auditor, the assurance provider and the customer questionnaire with the same evidence, and it is the thing that exposes whether your sub-metering actually covers what you think it covers.

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Compliance · Customer carbon and energy data · status 22 September 2026

Energy per part: what customers actually ask for in 2026

For plant and operations managers at European suppliers who keep receiving carbon questionnaires. What CDP, Catena-X and PACT ask for, what the CSRD changes mean for a smaller supplier, and the measurement chain that turns an estimate into an answer.

In shortThree asks now arrive separately and want the same underlying data. CDP wants organisational energy consumption in MWh with purchased electricity broken down by country. Catena-X wants a cradle-to-gate product carbon footprint per part, with a declared primary-data share and evidence for the electricity claim. PACT wants the same with transparent data reliability metrics. All three are answerable only from metered data you can reconcile to an invoice.

CDP: the questionnaire most suppliers meet first

CDP's supply chain programme is the route by which most European suppliers first get asked. More than 200 organisations request data from their suppliers through it, and over 45,000 suppliers were asked to disclose in the 2025 cycle. A bespoke SME questionnaire exists for smaller suppliers, which matters because the full corporate questionnaire is a heavy lift.

The energy question in the full questionnaire sits at Q7.30 and Q7.30.1: report organisational energy consumption in MWh, excluding feedstocks, with purchased or acquired electricity broken down by country or area.
The SME equivalent is Q20.15 and its sub-questions, focused on purchased and acquired electricity.
The 2026 cycle deadline is stated as the week of 26 October 2026, with the exact date and time to be confirmed.
CDP states alignment with ISSB and ESRS, which means the energy figure you produce for sustainability reporting is the same figure CDP wants. One number, produced once, used three times.

The practical consequence"Excluding feedstocks", "by country" and "in MWh" are all boundary decisions. If your energy figure is assembled from invoices once a year, the boundary is whatever the invoices happened to cover. If it comes from a metering structure you designed, the boundary is a decision you can defend and repeat.

Catena-X: the per-part ask, in detail

The automotive network's product carbon footprint rulebook, version 4.0, released September 2025, is the most specific demand a European supplier currently faces on per-part data. What it requires, per part:

Catena-X PCF Rulebook v4.0: what a supplier has to deliver per part
Requirement	What it means on the shop floor
Declared unit: for countable products, one piece as described in the part description including a defined weight and the part ID	The footprint is tied to a part number, not to a plant or a product family. Your energy data has to be attributable to a part.
System boundary: cradle-to-gate, including raw material sourcing, production of materials and components, packaging, disposal of production waste, logistics and internal transport, quality control and manufacturing IT	Internal transport, quality control and manufacturing IT are inside the boundary. Compressed air, lighting and the measuring room are not out of scope.
Primary data share: report what percentage of the footprint rests on direct measurement rather than industry averages	This is the line that turns machine-level metering into a commercial argument. A supplier with meters reports a high primary-data share; a supplier without them reports averages.
Allocation hierarchy: avoid allocation, then subdivision, then system expansion with substitution, then physical or economic allocation	Subdivision beats allocation. A meter on the shared compressor is worth more than a formula dividing its consumption by part count.
Electricity: market-based approach preferred, with a supplier-specific product where a tracking system exists, otherwise the country-specific residual grid mix; renewable commitments need the committed generator's emission factor with supporting documentation; location-based is the fallback, and v4 includes infrastructure emissions	The electricity claim has to be evidenced with contractual instruments or on-site generation records, not asserted.
Data quality rating covering data age and temporal representativeness, geographic appropriateness, technology and process specificity, and completeness of measurement	Your sampling interval and metering coverage are graded, not just your total.
Reference period: the time period of primary data collection must be documented	A footprint without a stated collection window cannot be rated.

Source: CX-PCF-Rulebook v4.0, Catena-X Automotive Network, September 2025; standard CX-0029. Paraphrase; the rulebook prevails.

Verification is delegated to a separate Catena-X and TfS verification and programme certification framework, which means a footprint can be checked by someone other than the customer who asked for it.

PACT, and why the two converge

PACT, the WBCSD initiative, is the cross-sector equivalent: methodology version 3 and technical specifications for product carbon footprint data exchange version 3.0.3. It uses the same cradle-to-gate boundary, including storage and shipping within and between life-cycle stages, and requires footprints to be accompanied by transparent data reliability metrics giving data quality and the share of primary data. Third-party verification of the calculation model is expected to build trust rather than strictly mandated. Catena-X's rulebook is listed among PACT's resources; the two are deliberately interoperable.

What this means for planningYou are not building an answer for one customer scheme. Primary-data share and a documented collection period appear in both. If you meter for one, you have met the substantive requirement of the other, and the remaining work is format.

The direction of travel: carbon as a technical feature

Volkswagen Group's 2025 annual report states that only suppliers who manufacture products in accordance with the requirements of the specifications are eligible for contract award, and that the group plans to make CO2 emissions a technical feature for relevant components, with binding CO2 targets whose compliance must be proved on request. Its S-Rating covers direct suppliers with high sustainability risk and corresponding company size; the 2025 interim target of 85% of procurement volume from relevant suppliers with a positive rating was met at 87%, against a 2040 target above 95% by sales revenue. A separate target has 95% of suppliers holding a certified environmental management system.

A technical feature is not a questionnaire. It is a specification value, and specification values are verified on request, held against a tolerance, and treated as nonconformity when missed. That is a different evidentiary standard from an annual sustainability response, and it is the reason to build the measurement chain now rather than when the first specification arrives.

CSRD after Directive (EU) 2026/470: the cap that lets you say no

The Omnibus amending directive, Directive (EU) 2026/470 of 24 February 2026, entered into force on 18 March 2026. For a supplier, one provision matters more than all the rest.

The value-chain capProtected undertakings — those with up to 1,000 employees — may refuse information requests that go beyond the standards specified for voluntary use, and the reporting undertaking has to inform them of that right. If a customer sends a smaller supplier a data request built for a large reporting entity, the supplier can decline the parts that exceed the voluntary standard.

Scope thresholds were raised: the net turnover threshold moves from 150 million to 450 million euro, with an employee criterion of more than 1,000 on average during the financial year. We could not confirm from the text we read whether the two criteria apply cumulatively or as alternatives, so verify that before relying on it.
Wave 2 covers financial years starting on or after 1 January 2027, and only for undertakings above the new thresholds. Wave 1 continues with a transition period ending 31 December 2026.
Assurance stays limited. The move to reasonable assurance was removed; the Commission is to adopt assurance standards by 1 July 2027.
Two delegated acts were adopted on 3 July 2026: revised and simplified reporting standards with mandatory datapoints cut by 61%, applying to financial years beginning on or after 1 January 2027, and a separate set of standards for voluntary use by undertakings protected by the value-chain cap. Both were awaiting Official Journal publication when we checked.

On the energy disclosure itself: the version operative for financial years 2024 to 2026 asks for total energy consumption in MWh, disaggregated into fossil, nuclear and renewable sources with renewables split three ways, an additional fossil breakdown for high climate impact sectors, separate disclosure of energy production where applicable, and an energy intensity ratio of total energy consumption over net revenue for high-climate-impact activities. We read that paragraph-level detail in a secondary reproduction, not in the official annex, and we could not confirm how the energy disclosure is treated in the revised 2026 standards. Given a 61% datapoint cut, assume the numbering has changed and verify before making claims about reporting for 2027. For the wider picture of what OEMs ask after the Omnibus, see OEM supplier data requests after the Omnibus.

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The measurement chain that makes an answer defensible

Four links, in order. Each one is a place where an answer gets challenged.

Metering granularitySite incomers first, because they reconcile to the invoice. Then every significant energy use individually. Then the machines where energy per part is a decision variable: ovens, furnaces, presses, moulding, compressors, chillers, paint, plating, drying. Shared utilities either get a meter or get a written allocation key, and the Catena-X hierarchy prefers subdivision over allocation, so the meter is worth more. Target: sub-meters explaining at least 90% of the main incomer.
Sampling intervalOne minute or finer at machine level, because anything coarser cannot separate producing from idle and therefore cannot attribute energy to a cycle or a batch. 15 minutes at feeder and area level, matching the European settlement interval so it reconciles with the bill. Monthly at the reporting layer. Keep meter identity, accuracy class and calibration record with the data, and document the collection period — temporal representativeness is graded in the data quality rating.
Allocation to partsEnergy per good part, not per part started. Scrap belongs in the denominator's definition and as a separate variable, so drift is explainable. Attribute by operating state so that idle and changeover energy is visible rather than smeared across the parts that happened to be made. Where one machine makes several part numbers, the allocation key has to be written down and applied consistently, because the declared unit is a part ID with a defined weight.
Reconciliation, machine meter to utility invoiceOne documented chain: machine meters to area meters to site incomers to the utility invoice to the MWh figure reported. Each link with a stated tolerance. This is the single artefact that satisfies the certification auditor, the financial assurance provider under limited assurance, and the customer questionnaire at the same time, and it is the one that is almost never built until someone asks a hard question.

The same data, four destinations
What you measure	ISO 50001	EED audit	CDP / sustainability reporting	Catena-X / PACT
kWh per good part per machine	Indicator for a significant energy use	Representativeness of the audit	Underlying data for the intensity ratio	Primary data share, per part ID
Relevant variables measured (volume, mix, state, ambient)	Normalisation	Load profile analysis	Year-on-year comparability	Allocation by subdivision
Sub-metering to 90% of the incomer	Significant energy uses and the measurement plan	Coverage expectation	MWh split by carrier	Gate-to-gate energy by process
Meter identity and calibration records	Documented information	Auditor evidence	Assurance	Evidence of electricity source
Renewable and self-generated split	Energy review	Consumption includes self-consumed renewables	Renewable disaggregation	Market-based versus residual mix

Most plants can start this with the meters they already have plus a handful of clamp meters on the biggest consumers, and a spreadsheet. That is a reasonable first year and it will tell you where the energy actually goes. The point at which it stops working is the reconciliation step, once the number has to be produced monthly, per part number, and defended. These sites are published by TEEPTRAK SAS, which sells production-monitoring and OEE software, so treat any recommendation of a monitoring system from us as an interested one, and compare it against your building management system, your MES and your utility's own interval data before buying anything.

Questions

Can a small supplier refuse a customer's carbon questionnaire?: Partly. Directive (EU) 2026/470 gives protected undertakings, those with up to 1,000 employees, the right to refuse information requests that go beyond the standards specified for voluntary use, and requires the reporting undertaking to inform them of that right. It does not release you from a contractual requirement you have already signed, and it does not apply to schemes like Catena-X that a customer imposes through the supply agreement. Read the request against the voluntary standard before answering all of it.
What is a primary data share and why does it matter commercially?: It is the percentage of a product carbon footprint based on direct measurement rather than industry averages, and Catena-X requires it to be reported. It matters because it is a quality score on your answer that the customer can compare across suppliers. A plant with machine-level metering can declare a high share; a plant working from annual invoices and average factors cannot, whatever its actual emissions are.
Does energy per part have to be per good part?: For an energy performance indicator, yes in practice: scrap moves the denominator, so a scrap-blind figure drifts for reasons unrelated to energy performance. For a product carbon footprint, the declared unit is one piece as described in the part description with a defined weight and part ID, and the energy attributed to it has to include the energy spent making the parts that were scrapped, because that energy was really consumed. Keep scrap as an explicit variable so both views are producible from the same data.
How fine does the sampling interval have to be?: One minute or finer at machine level if energy has to be attributed to a part, a cycle or a batch; anything coarser cannot separate producing from idle. 15 minutes at feeder or area level, which matches the European settlement interval and therefore reconciles with the utility bill. Monthly is enough at the reporting layer. The collection period also has to be documented, because temporal representativeness is one of the graded data quality criteria.
What is the single artefact worth building first?: The reconciliation chain: machine meters to area meters to site incomers to the utility invoice to the figure you report, each link with a stated tolerance. It is the only artefact that answers the certification auditor, the assurance provider and the customer questionnaire with the same evidence, and it is the thing that exposes whether your sub-metering actually covers what you think it covers.

Sources

Published by TEEPTRAK SAS, which makes production-monitoring and OEE software. Every figure is sourced on the page. Funding rules, standards and reporting duties change: check the official documents before you budget or commit.