Sedex and CSRD: what Vietnamese garment suppliers actually need to know

This article is for informational purposes only and does not constitute legal advice. Consult a qualified legal professional for advice specific to your situation.

Two requests arriving at once

Vietnamese garment manufacturers supplying EU brands and retailers are increasingly receiving two distinct types of compliance requests in the same period, sometimes in the same email chain.

The first is a request to join Sedex, complete a self-assessment questionnaire, or commission a SMETA audit. The second is a request for sustainability data to support the EU buyer's CSRD reporting: emissions figures, workforce data, wages, and health and safety records. Both requests come from the same procurement or sustainability teams. Both are described as requirements for continued supply. They are not, however, the same requirement, and satisfying one does not satisfy the other.

This article is written for manufacturers who want to understand what each obligation actually involves, how far a SMETA audit goes toward meeting a CSRD data request, and what needs to be built separately to cover the gap.

What Sedex and SMETA are

Sedex is a non-profit membership platform founded in 2004 by a group of UK retailers. Suppliers join the platform, complete a self-assessment questionnaire covering labour, health and safety, environment, and business ethics, and share that data with linked buyers. The same information is then accessible to all buyers the supplier has linked to, which is the efficiency case for the platform: you complete the process once and multiple buyers can access it.

SMETA is an audit methodology developed by Sedex. It is an on-site assessment conducted at your facility by a qualified third-party auditor from Sedex's approved list. You select and pay the auditor directly. The auditor reviews documentation, interviews workers, and inspects your facilities. The resulting report is structured and standardised, with findings categorised as critical, major, or minor non-conformances. The report is uploaded to the Sedex platform and becomes visible to all buyers you have linked to.

SMETA comes in two variants. The two-pillar version covers labour standards and health and safety. The four-pillar version adds environment and business ethics. Your EU buyer will specify which they require. These are not interchangeable: a two-pillar audit does not satisfy a buyer who has specified four-pillar.

A detailed explanation of how both work and what a SMETA audit can and cannot prove is available here: What is Sedex and what does a SMETA audit actually prove?

What CSRD is and why it reaches your factory

CSRD is the EU Corporate Sustainability Reporting Directive (Directive 2022/2464/EU). It requires large EU companies to report on sustainability impacts, risks, and opportunities across their operations and value chains, using the European Sustainability Reporting Standards (ESRS). Following the Omnibus I simplification package, the in-scope threshold is companies with at least 1,000 employees and at least EUR 450 million in net turnover. Listed companies above the relevant thresholds began filing in 2025. Larger unlisted companies are now in their first or second reporting cycle.

Your factory is part of your EU buyer's value chain. Your emissions contribute to their Scope 3 figures. The working conditions in your factory are part of what they must disclose under ESRS S2. The water your wet processes use and the chemicals your finishing operations involve are within scope of their ESRS E2 and E3 reporting obligations.

Your buyer cannot report numbers they do not have. They cannot disclose your factory's conditions if they do not know them. So the questionnaire, the platform login, or the data request you received is the mechanism through which your buyer collects information they are legally required to report. This is not an optional corporate social responsibility initiative. It is a regulatory reporting obligation backed by mandatory independent assurance, and the quality requirements on that data will tighten over time.

One important development: in July 2026, the European Commission adopted revised ESRS as part of the Omnibus I simplification package. The revised standards reduce mandatory datapoints by over 60 percent and total datapoints by over 70 percent compared to the original 2023 standards. This means the specific data requests your EU buyer sends you will reflect these revised, lighter requirements. The analysis in this article reflects what buyers will realistically ask for under the revised standards, not the original full disclosure framework.

A worked example of exactly which CSRD data requests a Vietnamese garment manufacturer is likely to receive, and why, is available here: What CSRD means for a Vietnamese textile manufacturer supplying EU brands. This article focuses on the specific question of how Sedex and SMETA relate to those CSRD data requests.

Where a SMETA audit helps with CSRD

A SMETA audit is genuinely relevant to one ESRS standard in particular: ESRS S2, which requires your EU buyer to disclose material impacts, risks, and opportunities relating to workers in their upstream value chain.

ESRS S2 requires the buyer to report on working conditions and human rights practices among their suppliers' workers. For a garment brand, the primary upstream workers are the people in their supplier factories. That means your workers.

A current SMETA audit addresses a significant portion of the ESRS S2 information requirement. An auditor who has visited your facility will have reviewed documentation and interviewed workers on the following: working hours and overtime practices, including whether overtime is voluntary and how it is compensated; wages and whether they meet applicable legal minimums; freedom of association and what worker representation mechanisms exist; health and safety conditions covering building safety, fire safety, machinery, chemical handling, and sanitation; and grievance mechanisms.

Your buyer's ESRS S2 disclosures will draw on this kind of information. A SMETA report from an accredited auditor, conducted within the past twelve to eighteen months, provides auditor-verified documentation rather than self-reported figures. That is meaningfully better evidence for assurance purposes than a questionnaire response alone.

The four-pillar SMETA variant also covers environment and business ethics, which contributes some evidence relevant to ESRS E disclosures and ESRS G1.

Where a SMETA audit does not reach

Despite the genuine relevance above, a SMETA audit does not cover the most demanding CSRD data requirement your EU buyer faces.

The most significant gap is greenhouse gas emissions data. ESRS E1 requires your EU buyer to report Scope 1, 2, and 3 greenhouse gas emissions. Scope 3 Category 1, which covers emissions from purchased goods and services, is typically the largest component of a garment brand's total emissions footprint. Calculating it accurately requires emissions data from suppliers.

A SMETA audit does not collect this data. A two-pillar audit does not address it at all. A four-pillar audit asks about environmental management and legal compliance with environmental regulations, but it does not collect your electricity consumption in kilowatt-hours or your fuel use in litres, and it does not calculate your Scope 1 and Scope 2 emissions in tonnes of CO2 equivalent. Those are the figures your EU buyer needs for their ESRS E1 reporting. Your SMETA report, however favourable, does not provide them.

Your buyer will therefore send a separate data request for emissions information, either now or in the next one to two reporting cycles as their reporting matures. Under the revised ESRS, the specific datapoints required are fewer than under the original standards, but the fundamental need for actual consumption and emissions figures from suppliers has not been removed. The most likely request will ask for your total electricity consumption, your fuel use by type, your production volume over the same period, and potentially your own Scope 1 and Scope 2 figures if you calculate them.

The second gap involves quantitative workforce metrics. ESRS S2 requires specific numerical disclosures alongside the qualitative information a SMETA audit provides. Your buyer's ESRS S2 report will need your total headcount broken down by gender and employment type, your average wages by worker grade, your working hours data, and your lost-time injury rate. A SMETA auditor reviews records that contain some of this information, but the audit report is a findings document, not a data submission in the format your buyer's CSRD report requires. The underlying figures need to come from you directly.

A third gap, relevant for manufacturers with dyeing, finishing, or washing operations, is water and chemicals data. ESRS E3 covers water consumption and withdrawal by source. ESRS E2 addresses chemically intensive operations. A two-pillar SMETA audit does not cover either. A four-pillar audit addresses environmental management systems but does not collect the consumption figures some buyers will request. If your operation is cut-and-sew only without wet processes, this gap is less significant. If you operate dyeing or finishing, it is one of the most commonly identified data gaps in CSRD-related supplier requests.

What Sedex's self-assessment questionnaire covers and does not

If your buyer's request is specifically for Sedex membership and completion of the self-assessment questionnaire without requiring an on-site audit, the scope of what you have provided is narrower still.

The SAQ is a self-reported questionnaire. No auditor visits your facility. No one independently verifies that what you have described reflects actual conditions. You are answering questions about your policies and practices, and those answers are stored on the platform for your linked buyers to review.

For buyers using the SAQ as a first-pass risk screening tool, this is useful. For buyers trying to satisfy CSRD assurance requirements, it is a thin evidential basis. An assurance auditor reviewing your buyer's CSRD sustainability report will apply an independence standard to the evidence behind value chain disclosures. Self-reported questionnaire data, however carefully completed, carries less weight than independently verified audit findings.

This does not mean completing the SAQ is pointless. It contributes to your buyer's supplier risk database and may satisfy their platform membership requirement. But it should not be confused with having provided the substantive CSRD supply chain data your buyer needs for their report.

What you need to build for CSRD data requests

The data your EU buyer needs for CSRD reporting that a SMETA audit does not provide falls into three practical categories.

The first is emissions and energy data. Monthly electricity consumption figures from your utility bills, fuel purchase records by type, and production volume over the same period are the inputs. Converting those figures into Scope 1 and Scope 2 emissions in tonnes of CO2 equivalent requires applying standard emissions factors, which are publicly available. The Vietnamese national grid emissions factor is published by the Ministry of Industry and Trade and updated periodically. The calculation is not technically complex. What most factories lack is the discipline of recording utility consumption consistently by month in a format usable for annual reporting. Setting up a simple tracker that captures this going forward closes the gap within one reporting cycle.

The second is structured workforce data. Wage data by worker grade, headcount by gender and employment type, working hours records, and health and safety incident rates are held somewhere in your payroll, HR, or safety management systems. 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 annually in a standardised format reduces the friction when buyer requests arrive.

The third, relevant for wet process facilities, is water and chemicals documentation. Total water consumption by source, wastewater discharge volumes and treatment method, and a maintained chemical register aligned with the ZDHC Manufacturing Restricted Substances List or an equivalent standard. If your operation is cut-and-sew only, the water and chemicals questions will be less intensive. If you operate wet processes, this documentation gap is one of the most commonly identified in CSRD-related supplier data requests.

How to respond when requests arrive together

When a Sedex or SMETA request and a CSRD data request arrive from the same buyer in the same period, the two processes are best handled in parallel rather than sequentially.

For the Sedex and SMETA track, the first step is clarifying exactly what your buyer requires before spending money on either process. Which SMETA pillar variant do they need? Do they require the audit report to be uploaded to Sedex or will they accept it directly? How recently must the audit have been conducted? These questions take one exchange with your buyer contact but prevent costly mistakes like commissioning a two-pillar audit when four-pillar was required.

For the CSRD data track, the first step is identifying which figures your buyer has explicitly requested and which you currently have available. Working from what is already in your systems, even imperfect figures, is more useful than waiting until you have a complete data infrastructure in place. Most buyers in the early phases of CSRD reporting understand that supplier data collection capacity is developing and will work with reasonable estimates clearly labelled as such.

The two processes use some of the same underlying information. Your SMETA audit will have reviewed your wage records, working hours data, and health and safety incident reports. The figures your buyer needs for their CSRD data submission may already exist in the documentation you gathered for the audit. Using the audit preparation process as an opportunity to organise that data for external reporting reduces duplication.

The compliance picture neither covers

A SMETA audit and a completed Sedex SAQ tell your EU buyer how conditions at your facility compared to the SMETA criteria on the day of the audit, and how your self-described practices compare to the questionnaire categories. Together they contribute evidence toward part of what CSRD requires. They do not constitute the complete CSRD supply chain data picture, and they do not address the question of what EU sustainability law more broadly requires from your operations.

CSDDD, the EU Corporate Sustainability Due Diligence Directive (Directive 2024/1760 as amended), applies from 26 July 2029. For EU companies, the threshold is at least 5,000 employees and EUR 1.5 billion net worldwide turnover. For non-EU companies supplying into the EU market, the threshold is at least EUR 1.5 billion net turnover in the EU, with no employee count requirement. When it applies to your EU buyers, it will require them to conduct more systematic documented due diligence on their supply chains than most are doing today, with documented preventive and corrective action, functional complaints mechanisms accessible to your workers, and ongoing monitoring. A SMETA audit contributes some evidence toward that due diligence programme. It does not constitute the full programme.

For Vietnamese garment manufacturers, the practical priority is building the data collection infrastructure now, while your EU buyers are still in the early phases of CSRD reporting and the expectations around data quality are still developing. By the time CSDDD obligations arrive and assurance requirements tighten further, the factories with functioning data systems will be in a materially better position than those who are still assembling utility records in response to urgent buyer requests.

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.