Disclaimer: New EUDR developments - December 2025
In November 2025, the European Parliament and Council backed key changes to the EU Deforestation Regulation (EUDR), including a 12‑month enforcement delay and simplified obligations based on company size and supply chain role.
Key changes proposed:
These updates are not yet legally binding. A final text will be confirmed through trilogue negotiations and formal publication in the EU’s Official Journal. Until then, the current EUDR regulation and deadlines remain in force.
We continue to monitor developments and will update all guidance as the final law is adopted.
For mid-market companies, Scope 3 reporting has moved from an optional sustainability activity to a near-mandatory business requirement. Not because of direct regulatory obligation, but because your biggest enterprise customers — the ones who account for a disproportionate share of your revenue — are now required to report their own Scope 3 emissions. And Scope 3 Category 1 (Purchased Goods and Services) means your emissions become their emissions. This article explains the mechanics of why Scope 3 expectations are trickling down to mid-market suppliers, what the implications are, and how to prepare.
The EU’s Corporate Sustainability Reporting Directive (CSRD) requires large companies to disclose their full Scope 1, 2, and 3 greenhouse gas inventory — verified by an external auditor under limited assurance. For Wave 1 companies (already reporting), this is live. For Wave 2 companies (1,000+ employees and >€450M turnover), it’s coming in 2027.
Scope 3 Category 1 — Purchased Goods and Services — covers emissions from everything a company buys. For most businesses, this is the largest single Scope 3 category, often representing more than 50% of total value chain emissions. To report it credibly, CSRD reporters need emissions data from their suppliers. That means you.
Enterprise customers reporting under CSRD will typically ask their suppliers to provide one or more of the following:
Some customers will request this via formal procurement questionnaires or platforms like EcoVadis or CDP. Others will send direct data requests. The expectation is that this data will eventually be verified — either by your customer’s auditor or through your own third-party verification.
Coolset’s carbon accounting methodology is certified by TÜV Rheinland, confirming it meets the GHG Protocol Corporate Standard and Scope 3 Standard. This means companies that calculate their emissions using Coolset can share their results with confidence that the methodology is independently certified — meeting the data quality expectations of CSRD reporters requiring supplier-level emissions data.
The most effective preparation is to build your emissions inventory now, before the requests arrive. Key steps:
Scope 3 expectations are increasingly being embedded into procurement. Some companies are already moving beyond data requests to setting supplier decarbonization requirements: either reduce your emissions or provide evidence that you have a credible plan to do so.
For mid-market companies, this creates both a challenge and an opportunity. Companies that can respond quickly and credibly to sustainability data requests will be more competitive in enterprise sales processes. Companies that can’t will increasingly face friction.
For more on how to navigate this landscape, see our guide to the Omnibus proposal and its implications for supply chain reporting and our guide to CSRD audit readiness.
A practical guide to scoping, sourcing and calculating scope 1-3 data

This free compliance checker scans your packaging documentation and maps it against mandatory PPWR data requirements, giving you a clear view of your compliance status. Get actionable insights on documentation gaps before they become compliance issues.