For chemical suppliers selling to Europe, sustainability is becoming more than a corporate slogan.Europe Is Asking for More Than a COA. Are Chemical Suppliers Ready?

Increasingly, European customers are asking suppliers for something more specific: product carbon footprint and environmental data.

But what exactly is changing in Europe?

A few different developments are driving this trend.

1. CBAM is now in its definitive regime

Since January 2026, the EU Carbon Border Adjustment Mechanism (CBAM) has entered its definitive phase, covering sectors including cement, iron and steel, aluminium, fertilisers, electricity and hydrogen.

Not every chemical product is covered by CBAM, but for products that are, emissions data from non-EU producers can become part of the import process.

2. European companies need better visibility into their value chains

Under the EU's sustainability reporting framework, companies may need information about environmental impacts beyond their own operations.

For suppliers, this can translate into increasingly detailed customer questionnaires covering topics such as:

• Scope 1 and Scope 2 emissions

• Energy consumption

• Renewable energy use

• Raw material sources

• Waste and water

• Product carbon footprint

• LCA or environmental footprint data 

The reporting obligation may sit with the European company, but much of the underlying data sits with its suppliers.

3. Carbon footprint is only one part of the picture

The EU's Product Environmental Footprint (PEF) methodology looks at environmental impacts across a product's life cycle, rather than only CO₂ emissions.

For a chemical supplier, this means the conversation may gradually move from:

“Can you provide the product?”

to:

“Can you provide reliable environmental data about the product?”

So, what should chemical suppliers prepare?

You don't necessarily need to start with a complicated sustainability project.

A practical starting point is to understand your own production data:

1. Measure energy consumption

Electricity, natural gas, steam and other major energy inputs.

2. Understand Scope 1 and Scope 2 emissions

Know where your direct and purchased-energy emissions come from.

3. Start calculating product-level carbon footprint

For example, kg CO₂e per kg of product, with a clearly defined methodology and system boundary.

4. Keep the data traceable

Emission factors, production volumes, energy data and calculation assumptions should be documented and reproducible.

5. Build a basic product sustainability data sheet

So when a customer asks for environmental information, you don't have to start from scratch.

For chemical manufacturers and exporters, carbon data may gradually become another part of the product documentation package, alongside COA, SDS, REACH and other compliance information.

The transition will not happen overnight, and not every product will face the same requirements.

But one thing is becoming clear:

European customers are looking beyond the product itself and increasingly asking about the environmental data behind it.

For suppliers targeting the European market, preparing that data early may make future customer discussions much easier.