The EU Corporate Sustainability Reporting Directive (CSRD) is forcing the companies that buy from you to account for the carbon emissions embedded in everything they purchase. Whether you provide verified data or not, your products will be counted.
The biggest question is whether your buyers use your numbers, or make up their own.
A meeting that is already happening without you
Right now, across the yachting sector, buyers are building Scope 3 inventories. They are going through their supplier lists, and assigning carbon emission factors to every significant purchase they make from you.
If you have provided verified environmental data, a product carbon footprint, an Environmental Product Declaration, a third-party verified LCA, they use your numbers. If you have not, they use industry averages, which are almost always higher than a supplier’s actual performance, because they are designed to be conservative.
In practice, Scope 3 reporting happens with or without supplier participation. The only question is whether the numbers used represent the product itself or a generic estimate.
What Scope 3 emissions are, and why they reach your workshop
The GHG Protocol divides emissions into three scopes. Scope 1 covers direct emissions, Scope 2 covers purchased electricity, and Scope 3 includes emissions generated throughout a company’s value chain.
For a shipyard building or refitting a yacht, Scope 3 is typically the largest category, often accounting for 70 to 90 per cent of their total carbon footprint. The biggest driver is purchased goods and services: the steel, GRP, timber, coatings, systems, and equipment that go into the vessel.
That means your products. Every tonne of material or component supplied carries an embedded carbon footprint that the buyer is now required under law, for the largest companies to account for.
The three numbers that matter
For any given purchase, a Scope 3 Category 1 (purchased goods and services) calculation requires three things:
- The quantity purchased (weight, volume, or units)
- The emission factor for that product category (kg CO₂e per unit, from a database or supplier-provided data)
- The data quality (whether the emission factor is verified supplier-specific data, or a generic estimate)
Most buyers are currently working with the third option, generic estimates from databases like ecoinvent, the GHG Protocol sector guidance, or industry association averages. These numbers are often accurate at a sector level but poorly representative of any individual supplier’s actual manufacturing process, material sourcing, or energy mix.
A supplier who has run an LCA and can provide a verified product carbon footprint replaces that generic estimate with a real number, reflecting the accurate commercial standing of your product.
Where the legal pressure comes from: CSRD explained in three paragraphs
The EU Corporate Sustainability Reporting Directive (CSRD) requires large companies to publish sustainability reports aligned with the European Sustainability Reporting Standards (ESRS).
ESRS E1, the climate standard, requires companies to disclose their full greenhouse gas emissions including Scope 3 Category 1 (purchased goods and services). This is not a voluntary disclosure. It is audited, published, and increasingly used by investors, lenders, and procurement teams as a basis for decisions.
What this means in practice: for the yachting sector, the companies most affected by CSRD are the larger shipyards, refit facilities, yacht management companies and charter operators. Much of their Scope 3 footprint sits within their supply chains, making compliance, in part, a data collection challenge. A shipyard in scope is required to report emissions from purchased goods and services as part of its CSRD submission and therefore depends on material and equipment suppliers to provide verified product-level environmental data. Where that information is unavailable, buyers must fill the gap using estimates, and those estimates become the figures reported publicly.
The IMO runs a parallel track
While CSRD creates Scope 3 pressure from the EU corporate reporting side, the International Maritime Organisation (IMO) is creating parallel pressure from the vessel operational side.
Through measures such as the Data Collection System (DCS) and Carbon Intensity Indicator (CII) require operators of vessels above 5,000 GT to report and improve fuel efficiency. The IMO’s 2023 revised GHG Strategy targets net-zero emissions from international shipping by or around 2050, with interim milestones in 2030 and 2040.
As a result, owners and operators are paying close attention to the weight, energy consumption, and carbon intensity of the equipment and materials on their vessels. A hull coating that reduces drag and improves fuel efficiency is a carbon reduction tool. A lightweight composite component is contributing to a vessel’s GHG profile.
Suppliers who can quantify this contribution in verified terms: ‘our product reduces vessel fuel consumption by X per cent over a ten-year service period, representing Y tonnes of CO₂ avoided’, have a commercial argument that maps directly onto an operator’s IMO compliance challenge. That argument requires an LCA.
What actually happens to suppliers without verified data
The consequences of not having verified environmental data are not immediate but they compound over time.
In the short term: you get estimated, not measured: Buyers assign generic emission factors from databases and industry averages, which may not reflect your specific manufacturing processes, material inputs or energy sourcing. For suppliers who have invested in efficiency may therefore appear to have a higher footprint than they actually do.
In the medium term: you become harder to include in verified reporting: As CSRD reporting matures and auditors scrutinise data quality, buyers will face pressure to improve the accuracy of their Scope 3 inventories. The first step is replacing generic factors with supplier-specific verified data. Suppliers who cannot provide this may be replaced on preferred supplier lists, or will face specific requests.
In the longer term: procurement criteria evolve: Several major European shipyards and superyacht builders have already introduced sustainability criteria into their supplier qualification processes. These criteria are currently soft; questionnaires, self-declarations, policy statements. Within two to three years, as CSRD reporting increases and buyers face audit scrutiny on Scope 3 data quality, those criteria will harden. Verified product carbon footprint data and a third-party verified data will be the baseline for inclusion.
The window: Suppliers who act in 2026 and 2027 have an opportunity to build this capability before it becomes a hard requirement, giving them flexibility and the strongest position when buyers come asking.
What verified data looks like and what it does not require
The term ‘verified environmental data’ can sound like a large, expensive undertaking. In practice, what buyers needs for Scope 3 reporting is more specific and more achievable than most suppliers assume.
At minimum, buyers need a product carbon footprint expressed in kg CO₂ equivalent per functional unit for example, per kilogram of product, per litre, per square metre of applied coating, or per unit shipped. This number should be derived from a recognised methodology (ISO 14067 for product carbon footprints, or EN 15804 for EPDs) and verified by an independent third party.
That does not require a full cradle-to-grave LCA for every product in your range on day one. A credible starting point is typically a gate-to-gate or cradle-to-gate calculation covering the production stage, where most of a manufactured product’s carbon footprint sits and where you have the most direct data access.
The process involves three core inputs: your bill of materials (what goes into the product), your energy consumption in production, and your transport data. Most suppliers have this information in some form already. The challenge is usually not the lack of data, but data organisation and methodology application.
What the numbers tell you beyond the buyer’s report
A product carbon footprint calculation tells you more than how compliant you are. It highlights where your emissions are concentrated within the manufacturing process, which materials, energy use, and transport legs. For most manufacturers, this reveals a small number of high-impact inputs that, could meaningfully improve the overall footprint. Such operational insights may provide cost related advantages beyond environmental ones.
Suppliers who run this process consistently report that the data often surprises them — both in terms of where emissions are actually coming from, and in terms of how competitive their products are relative to the industry averages buyers are currently using.
Where to start and what the first step actually looks like
The most common reason suppliers delay is not cost or complexity, it is uncertainty about where to begin. The data required is unfamiliar, the methodology terminology is unfamiliar, and the fear of discovering something unflattering about your own products is real, though rarely justified.
The practical first step is a data readiness assessment: a structured review of what information you already hold; bill of materials, energy invoices, waste and logistics records, existing supplier data sheets against what a product carbon footprint calculation requires. It usually takes a few days with specialist support and results in a clear picture of what you have, what is missing, and how long the process will take.
From that point, the path to a verified product carbon footprint becomes a defined project, not an open-ended commitment. For most single-component manufactured products, the timeline from data collection to third-party verified output is three to six months. For more complex multi-component systems, it may be longer, but the process scales, and it can start with the product that represents the most significant volume in your sales to the buyers who are already asking.
The Hub of Verified Solutions is structured to support exactly this process. It connects suppliers with accredited methodology guidance, LCA practitioners with marine sector experience, and a platform where the resulting verified data can be communicated directly to the buyers who need it in a format that satisfies the data quality requirements of CSRD reporting.
You do not need to have all your products verified to start or an internal sustainability team. You need a clear picture of your first product, a willingness to collect the data that is almost certainly already sitting in your systems, and a next step.
The bottom line
Your products are already being counted in your buyers’ sustainability reports. The question is whether the number being used reflects your actual performance, or a generic estimate that may be significantly worse.
As regulatory expectations and procurement requirements continue to evolve, verified environmental data is moving from a competitive advantage to a standard business requirement. The suppliers best positioned for this transition will not necessarily be those with the lowest carbon footprint, but those that can demonstrate their performance clearly, credibly and with third-party verification.
Take control of how your products are counted
The Hub of Verified Solutions connects marine and yachting suppliers with the methodology, tools, and platform needed to produce and communicate verified environmental data. If your buyers are already asking or will be asking soon, the Hub is the place to start.
Visit: https://waterrevolutionfoundation.org/programmes/hub-of-verified-solutions/
About this series
The Supplier Knowledge Series is published monthly by Water Revolution Foundation. Each issue covers a specific environmental methodology, regulation, or commercial development relevant to suppliers in the yachting and marine sector. Content is written by environmental specialists and reviewed for technical accuracy.