US–EU Value-Chain Compliance
US companies exporting to EU and UK markets face value-chain sustainability requirements from their customers — even though they are not directly subject to EU law.
Customer-driven compliance
The EU Carbon Border Adjustment Mechanism (CBAM) requires EU importers to report embedded emissions in certain imported goods — creating data demands that flow upstream to US exporters. The EU Corporate Sustainability Reporting Directive (CSRD) requires EU companies to report on their value chain, generating sustainability questionnaires for US suppliers.
These are not direct US regulatory obligations. But for US companies exporting cement, steel, aluminium, fertiliser, electricity, or hydrogen to EU markets — or supplying any product to EU multinationals — the practical effect is the same: without the right data, you risk losing the customer.
Who this is for
- US exporters of CBAM-covered goods (cement, iron/steel, aluminium, fertiliser, electricity, hydrogen)
- US suppliers to European multinationals receiving CSRD value-chain questionnaires
- US companies responding to EU customer sustainability due-diligence requests
- Companies seeking to understand their EU regulatory exposure before it becomes urgent
What RSustain provides
- CBAM exposure screeningProduct-level assessment of which exports fall within CBAM scope and what embedded-emissions data is required.
- Supplier and product data preparationCollection and formatting of production data, energy consumption, and process emissions for CBAM reporting.
- Product-carbon data readinessDeveloping product-level carbon intensity data aligned with EU methodology requirements.
- EU customer questionnaire supportTechnical support for completing CSRD value-chain information requests from European customers.
- CSRD value-chain information supportPreparing the data points that EU reporters need from their US value-chain partners.
- Sustainability due-diligence readinessAssessment of your organization’s readiness to respond to EU supply-chain due-diligence requirements.
- International reporting-framework alignmentMapping your existing data to GRI, ISSB, and other frameworks used by European customers.
- Exporter compliance roadmapPrioritized action plan for building the data infrastructure your EU customers will require.
Frequently asked questions
Is my US company directly subject to CBAM?
No. CBAM obligations fall on EU importers. However, EU importers need embedded-emissions data from their suppliers — and if you cannot provide it, they will use default values that may be unfavorable, or source from suppliers who can.
What is CSRD and why does it affect US suppliers?
The Corporate Sustainability Reporting Directive requires large EU companies to report on their full value chain. This means EU customers will send sustainability data questionnaires to their US suppliers. Companies that cannot respond risk being deprioritized or replaced.
Does RSustain have European experience?
Yes. The RSustain group operates across 14 jurisdictions including the UK, EU member states, and the Gulf. This cross-border experience is central to our value-chain compliance advisory.