The Regulatory Landscape Has Changed — But the Commercial Pressure Has Not
In early 2026, the EU Omnibus I Directive (Directive (EU) 2026/470) came into force, significantly raising the threshold for mandatory CSRD sustainability reporting. The new criteria require companies to have more than 1,000 employees and annual net turnover exceeding €450 million before mandatory CSRD reporting applies. Approximately 80% of companies previously in scope have been moved out of the mandatory reporting requirement.
For most winter sports brands — which are typically mid-size businesses well below that threshold — this means mandatory CSRD disclosure is no longer a legal requirement for most of your operations.
What has not changed: large retailers, sporting goods chains, and the major brand-owners who remain in scope (those with 1,000+ employees and €450M+ turnover) still collect supply chain sustainability data from their vendors and suppliers. The mechanism has shifted from "legal mandate" to "commercial relationship requirement," but the practical ask from your supply chain is largely the same.
The EU's VSME (Voluntary Sustainability Management for Small and Medium-sized Enterprises) framework provides a simplified, voluntary standard for SMEs to respond to these data requests from their larger partners. Whether via VSME, a retailer's own supplier code, or a brand partner's questionnaire, the underlying data they are requesting from your OEM manufacturer is consistent.
This guide explains what those requests typically look like — and what a credible OEM manufacturer should be able to provide.
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What Retailers and Large Brand Partners Typically Request
If your brand sells through a major sporting goods retailer (Decathlon, REI, Sport Chalet, Intersport, etc.), or if you source from or license to a large brand, you will likely receive a supplier sustainability questionnaire. These vary in format but consistently ask for the following:
1. Environmental Management System Certification
What they ask for: ISO 14001:2015 certification from an accredited third-party auditor.
This confirms your supplier has a documented system for managing and reducing their environmental impact — covering energy, waste, water, and emissions. It is renewed through external audit, not self-declaration.
What a credible OEM manufacturer provides: Certificate number, issuing body, and current validity dates.
2. Social and Health & Safety Certification
What they ask for: ISO 45001:2018 certification (or equivalent).
Retailer supplier codes and large-brand procurement standards now routinely require documented occupational health and safety management. ISO 45001 covers worker safety procedures, incident reporting, and continuous improvement.
What a credible OEM manufacturer provides: Current certificate, issuing body, and scope.
3. Material Sustainability Documentation
Retailers and large brands increasingly ask suppliers to identify which materials in their products have sustainability credentials. For winter sports equipment, the relevant materials include:
Bio-based resin content. What percentage of the resin formulation is bio-derived? What is the feedstock? Request a material data sheet confirming percentage bio-content.
Recycled material content. Is any alloy laminate (Titanal or equivalent) from recycled-content sources? Are textile linings recycled-content? What percentage? Confirm with supplier certificates.
Restricted substances compliance. REACH compliance documentation confirming the product does not contain substances of very high concern above legal thresholds.
What a credible OEM manufacturer provides: Material data sheets for each relevant component, supplier certificates for certified materials, percentage compositions, and REACH compliance declarations.
4. Energy and Carbon Data (If Requested)
Some larger retailers now request energy consumption and carbon intensity data from their tier-1 suppliers. This is not universal, but is becoming more common in high-profile sustainability programs.
The minimum a serious OEM partner should be able to provide: annual energy consumption by source (grid, on-site renewables), total production output for the same period, and waste generation and disposal data. This allows the requesting party to calculate an approximate carbon intensity per unit if required.
What a credible OEM manufacturer provides: Annual energy data, source breakdown, and waste figures on request. A commitment to improving the granularity of this data over time.
5. Export Compliance Documentation
Not strictly sustainability, but often bundled into the same compliance package: your OEM manufacturer's customs compliance status. AEO (Authorized Economic Operator) certification confirms the supplier operates within an audited, compliant framework for international trade — which supports supply chain traceability claims.
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The VSME Framework: A Practical Reference
The EU's VSME standard was developed precisely for situations like this: a mid-size brand receiving data requests from larger partners, needing a structured way to collect and pass on sustainability information from their supply chain.
VSME has two modules:
Basic module: Core sustainability data including energy consumption, waste, workforce conditions, and high-level governance. This is what most retailer questionnaires align to.
Narrative module: Contextual information on sustainability strategy, targets, and progress. Relevant for brands that want to proactively communicate rather than just respond to requests.
If you receive a VSME-aligned questionnaire from a retail partner or large brand, the majority of the data you need to complete it should be available from your OEM manufacturer — provided they operate to ISO 14001, ISO 45001, and ISO 9001 standards.
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The Five Questions to Ask Your OEM Manufacturer
Before placing an order with any winter sports OEM manufacturer, these five questions will tell you whether they can support your sustainability data needs:
1. Do you hold current ISO 14001 and ISO 45001 certificates from an accredited third-party auditor?
2. Which materials in my product line have certified sustainable content, and what documentation supports those claims?
3. Can you provide annual energy consumption and waste generation data for your facility?
4. Are you able to complete a retailer or brand-partner sustainability questionnaire on request?
5. What is your process for responding to supply chain data requests from downstream customers?
A manufacturer who responds with certificates, data sheets, and a clear process is ready to support your downstream relationships. A manufacturer who responds with brochure language is not.
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A Note on Where This Is Heading
Mandatory sustainability reporting thresholds have gone up in 2026. But the direction of travel — more transparency, more supply chain data, more documented accountability — has not reversed. The major retailers and brands who remain in mandatory scope will continue passing data requests down through their supply chains. And voluntary frameworks like VSME exist precisely to make this practical for smaller brands.
The brands best positioned for the next decade are those who have already established clear supply chain documentation with their OEM partners — so that responding to the next questionnaire takes hours, not weeks.
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SNOWORKSX holds ISO 14001:2015, ISO 45001:2018, ISO 9001:2015, and AEO certification. We provide material sustainability documentation and can respond to retailer or brand-partner supplier questionnaires. Contact us at snoworksx.com to discuss your documentation requirements.