What CSRD means for a Vietnamese textile manufacturer supplying EU brands
CSRD does not apply directly to most Vietnamese manufacturers. But if your factory supplies a large EU brand, retailer, or buying house, their CSRD obligations create real data requests and compliance requirements that land on you. This article walks through exactly what those requests look like and what you need to be able to answer.
This article is for informational purposes only and does not constitute legal advice. Consult a qualified legal professional for advice specific to your situation.
The situation this article is for
You run or manage a textile or garment manufacturing operation in Vietnam. You supply finished garments, fabric, or components to one or more EU brands, retailers, or buying houses. You have seen references to CSRD in emails or supplier communications from your EU customers, or you have received a questionnaire you do not fully understand. You want to know what is actually being asked of you, why, and what happens if you cannot answer.
This article is a worked example. It takes a specific type of business, a mid-sized Vietnamese garment manufacturer supplying EU fast fashion and mid-market brands, and walks through exactly which CSRD requirements trigger data requests to that manufacturer, what those requests look like in practice, and what the manufacturer needs to do about them.
The regulation itself is covered in more detail in CSRD and ESRS explained: what the corporate sustainability reporting directive requires. This article assumes you do not need a full regulatory explainer. You need to know what it means for your specific situation.
Why your EU customer is asking you for data
Your EU customer (whether it is a brand, a retailer, or a buying house that sources on behalf of brands) is subject to CSRD if it has more than 1,000 employees and more than €450 million in net turnover. If it is a listed company with more than 500 employees, it has been filing CSRD reports since 2025. Larger unlisted companies are filing now or in the next reporting cycle.
CSRD requires your EU customer to report on sustainability impacts, risks, and opportunities across its entire value chain. The value chain includes you. Your factory’s greenhouse gas emissions contribute to your customer’s Scope 3 figures. The working conditions in your factory are part of what your customer must disclose under ESRS S2. The water your dyeing facility uses, the chemicals your finishing process involves, and the waste your cutting room generates are all potentially within scope of your customer’s reporting obligations.
Your customer cannot produce numbers it does not have. It cannot disclose your factory’s conditions if it does not know what they are. So it asks you. The questionnaire you received, or the platform login you were invited to complete, is the mechanism through which your customer collects the data it is legally required to report.
This is not optional for your customer, and it is not a new corporate social responsibility initiative that might go away. It is a regulatory reporting obligation backed by mandatory independent assurance. As assurance requirements tighten over time, your customer’s auditors will scrutinise the quality and verifiability of the supply chain data in its report. Data gaps or implausible figures from suppliers will become liabilities in the assurance process.
The specific ESRS standards that create requests to your factory
Three ESRS standards are most likely to generate data requests directed at a Vietnamese garment manufacturer.
ESRS S2: workers in the value chain
ESRS S2 requires your EU customer to report on the working conditions and human rights of workers in its upstream supply chain. For a garment brand, the most significant upstream workers are the people in its supplier factories, your workers.
The specific disclosures ESRS S2 requires include: whether the company has identified actual or potential adverse impacts on value chain workers, what policies are in place to address those impacts, what actions have been taken and what outcomes have resulted, and a set of quantitative metrics covering the workforce.
The metrics that will generate direct data requests to your factory include:
Wage data. Your EU customer must disclose whether value chain workers receive wages that meet or exceed applicable living wage benchmarks. For Vietnamese garment workers, the relevant benchmark is typically the Asia Floor Wage or a similar regionally calibrated figure, compared against your actual average wages by production grade. You will need to provide average wage data broken down by worker category, and your customer may ask you to compare those figures against a published living wage estimate for your region.
Working hours. Your customer must disclose whether value chain workers work excessive hours. You will likely be asked to provide data on average working hours per week, the proportion of workers regularly working more than 48 hours, and overtime practices including whether overtime is voluntary and how it is compensated.
Health and safety. Your customer must disclose the rate of work-related injuries and fatalities in its value chain. You will be asked for your lost-time injury rate, your total recordable incident rate, and whether you have had any fatalities or serious injuries in the reporting period.
Freedom of association. ESRS S2 requires disclosure of whether value chain workers have access to freedom of association and collective bargaining rights. You will be asked whether your workers are represented by a trade union or worker committee, and what mechanisms exist for workers to raise grievances.
Gender data. Your customer is likely to ask for your workforce broken down by gender, the proportion of women in management positions, and whether you have a documented equal pay policy.
If you have existing social compliance audit reports, such as a SMETA 4-pillar audit or an SA8000 certification, much of this data will already be captured somewhere. The challenge is often not that the information does not exist, but that it is not organised in a format your customer’s questionnaire expects, or that the figures in your audit report are more than twelve months old.
ESRS E1: climate change and Scope 3 emissions
ESRS E1 requires your EU customer to report on its greenhouse gas emissions across all three scopes. Scope 1 covers emissions from the customer’s own operations. Scope 2 covers emissions from purchased electricity. Scope 3 covers emissions from its upstream and downstream value chain. For a garment brand, Scope 3 Category 1 (purchased goods and services) is typically the largest single emissions category, often representing 80 percent or more of total lifecycle emissions.
Category 1 Scope 3 emissions include the emissions generated by manufacturing the goods the brand sells. That means your factory’s emissions are a component of your customer’s Scope 3 figure.
In the early years of CSRD reporting, many EU brands are estimating their Scope 3 figures using spend-based or activity-based models rather than actual supplier data, because collecting actual data from hundreds of suppliers simultaneously is impractical. But the assurance requirements and the competitive pressure from more detailed reporting will drive brands toward supplier-specific data over time.
What you will be asked for, either now or in the next one to two reporting cycles:
Scope 1 emissions. Direct emissions from combustion sources in your facility: generators, boilers, company vehicles. Measured in tonnes of CO2 equivalent.
Scope 2 emissions. Emissions from purchased electricity. The figure depends on your electricity consumption and the emissions factor for the Vietnamese national grid or, if you purchase renewable energy directly, the factor for that energy source.
Energy consumption data. Total electricity consumption in kilowatt-hours, broken down by source where relevant. This is the underlying figure from which Scope 2 is calculated, and many customers will ask for it directly.
Production volume. Your customer needs to know how many units or how many kilograms of product you manufactured in the period, so it can calculate an emissions intensity figure (emissions per unit or per kilogram) that allows comparison across suppliers and over time.
If your factory does not currently track its electricity consumption and fuel use systematically, this is the starting point. Monthly utility bills and fuel purchase records provide the raw data. Converting those figures into CO2 equivalent requires applying standard emissions factors, which are publicly available. The calculation is not technically complex, but it requires a data collection discipline that many factories have not previously needed.
ESRS E3 and E2: water and chemicals
Textile and garment manufacturing, particularly operations that include dyeing, finishing, or washing, are water-intensive and chemically intensive. If your facility includes these processes, your EU customers are likely to ask for water and chemicals data as part of their ESRS E2 and E3 reporting.
Water requests typically cover total water consumption in cubic metres per period, water withdrawal by source (municipal supply, groundwater, surface water), and water discharge volumes and treatment method. For facilities in water-stressed areas, the intensity of questioning on water is higher.
Chemicals requests typically cover whether you operate a restricted substances list, whether you have a chemical management system, and the wastewater treatment processes in place before discharge. The ZDHC (Zero Discharge of Hazardous Chemicals) Programme and its Manufacturing Restricted Substances List are widely used benchmarks in the garment sector, and your customer may ask whether you are ZDHC-compliant or working toward it.
If your operation is cut-and-sew only, without dyeing or finishing, the water and chemicals questions are less intensive. But if you operate a wet process facility, this is an area where documentation and management system gaps are commonly identified.
What the requests actually look like
The data described above reaches you through several mechanisms.
The most common is a supplier questionnaire, either sent directly from your EU customer’s sustainability or procurement team, or hosted on a third-party platform such as EcoVadis, Sedex, or a customer-proprietary portal. The questionnaire asks you to report against a defined set of indicators for the most recent calendar or financial year. You upload supporting documentation, such as audit reports, utility bills, and HR records, to substantiate your answers.
A second mechanism is a requirement to complete a specific audit. Your EU customer may require you to hold a current SMETA 4-pillar audit, which covers labour, health and safety, environment, and business ethics, or to complete an assessment on a specific platform. The audit or platform score becomes the supplier data your customer uses for its CSRD reporting.
A third mechanism, increasingly common as CSRD reporting matures, is embedding sustainability requirements in the supplier contract itself. New contracts and contract renewals include clauses requiring you to provide defined categories of sustainability data annually, to notify your customer of any material incidents such as a serious injury or a regulatory penalty, and to cooperate with audits or assessments at reasonable notice. Signing a new supply agreement with an EU brand means accepting these obligations contractually.
What happens if you cannot respond
In the short term, gaps in your response to a supplier questionnaire create a data problem for your EU customer. It has to estimate your figures, use sector averages, or disclose in its report that complete data was unavailable from some suppliers. As assurance requirements tighten, both of these options become less acceptable.
In the medium term, customers managing large supplier networks will increasingly distinguish between suppliers who can provide consistent, verifiable sustainability data and those who cannot. Preferred supplier programmes, capacity allocation decisions, and new business awards are all commercial levers that procurement teams can apply. The sustainability data request is becoming part of what it means to be a qualified supplier, not an optional extra.
In the longer term, for EU customers also subject to CSDDD (which applies from 2029 to companies with more than 5,000 employees and more than €1.5 billion in turnover), a supplier that cannot provide adequate information about its labour and environmental practices creates a due diligence risk that the customer is legally required to address. The available responses are improvement plans, increased audit intensity, and ultimately relationship suspension or termination. Suppliers who are not positioned to respond to basic data requests before the question becomes a legal compliance issue for their customer are in a materially weaker position.
What you need to build
The data requirements described above are not exotic. Most of the underlying information exists in your business in some form. What is typically missing is the system to collect it consistently, store it accurately, and report it in the format your customers expect.
Payroll and workforce data. Wage data by worker grade, headcount by gender and employment type, and working hours records are held in your HR or payroll system. The gap is usually not that the data does not exist, but that it has never been extracted and formatted for external reporting. Establishing a process to pull these figures quarterly and store them in a format usable for annual reporting is a straightforward administrative change.
Utility consumption records. Electricity consumption figures are on your monthly bills. Fuel purchase records are in your accounts. Establishing a simple tracker that records monthly consumption by energy type and calculates CO2 equivalent using standard emissions factors gives you the Scope 1 and Scope 2 figures your customers are asking for. This does not require specialist software. A well-maintained spreadsheet is sufficient as a starting point.
Health and safety records. Lost-time injury data, total recordable incidents, and near-miss records should be held in your safety management system. If you do not currently track these systematically, this is the most operationally important gap to close, both for regulatory purposes and for worker welfare. The data is also the most likely to be verified by an on-site auditor.
A current social compliance audit. If you do not currently hold a SMETA 4-pillar audit or equivalent, this is the single investment with the broadest return for CSRD-related supplier data requests. A current audit from an accredited body covers the majority of ESRS S2 indicators and provides auditor-verified documentation rather than self-reported figures. The cost is significant but is increasingly a cost of doing business with major EU buyers.
A restricted substances list and chemical register. If you operate wet processes, maintaining a documented restricted substances list aligned with ZDHC MRSL or an equivalent standard, and a chemical register showing what substances are in use in your facility, is the foundation for responding to ESRS E2 data requests.
None of this needs to be built at once. The practical starting point is identifying which EU customers are subject to CSRD, what they have already asked for, and where the gaps are between what they need and what you can currently provide. That gap assessment determines the priority order for building the data infrastructure.
For a broader understanding of how CSRD supply chain obligations work and why they reach non-EU manufacturers, see How EU sustainability legislation flows down from buyer to supplier.
Verdandi monitors CSRD, ESRS, and CSDDD continuously, so non-EU manufacturers working with EU buyers are working from current data requirements as reporting standards develop and assurance obligations tighten. Start for free.
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