In short
- The OEM asks for a product carbon footprint per part, not a company footprint.
- Purchased materials, especially metals, dominate. Plant energy is the smaller half of the story.
- CBAM binds the importer of covered goods, above 50 tonnes a year. If your supplier imports the metal, it reaches you as price, not paperwork.
Two different requests land on an automotive supplier's desk and they need different artefacts. Vehicle manufacturers require product carbon footprints from their supply chain, meaning a figure per part, per kilogram, per unit shipped. A company-wide inventory will not produce that figure. Customer scope 3 questionnaires are the other request, and they ask for company-level numbers. Your emissions sit in purchased materials, especially metals, so the bill of materials is the dataset and plant energy is the smaller half of the story.
Which request actually lands on your desk, and when?
Two, from different directions, with different formats.
OEM data requests. Vehicle manufacturers require product carbon footprints from their supply chain. The trigger is a nomination, a programme award or a supplier portal deadline, so the timing is commercial rather than regulatory and the notice is often short. The request is per part, and it arrives with the OEM's own template and its own rules about which factors are acceptable.
Customer scope 3 questionnaires. The OEM, or a tier 1 above you, also has its own corporate reporting to do, and that asks for company-level numbers. Same sender, different artefact, and the two requests often arrive within weeks of each other.
The useful observation is that these overlap in their input. Both are answered by knowing what you buy, from whom, in what quantity, with what embedded emissions. Collect that once and it serves both, which is the argument for treating supplier data collection as one programme rather than two projects.
Does CBAM actually reach you?
Probably not directly, and this is worth getting right before you start a supplier programme you may not need.
CBAM is a charge on the emissions embedded in goods imported into the EU, and the obligation sits with the importer. Its definitive regime began on 1 January 2026, and it covers six sectors: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Buying steel is not the trigger. Importing it is.
So run three tests in order.
Are you the importer of record? If your metal comes from an EU mill, or from an EU distributor who did the importing, the answer is no and CBAM is not your filing. It is your supplier's cost, and it reaches you through the price you are quoted rather than through your paperwork. For most tier 1 and tier 2 suppliers buying on the European market, this is where the question stops.
If you do import, how much? There is a de minimis threshold of 50 tonnes cumulative net mass of CBAM goods per calendar year, per importer, covering iron and steel, aluminium, fertilisers and cement. Below it you are outside the regime. The Commission's own stated effect is that this exempts roughly 90 percent of importers while keeping roughly 99 percent of embedded emissions in scope. Electricity and hydrogen have no threshold, which is unlikely to matter to a parts maker. Weigh your annual tonnage before you chase a single supplier.
If you are over it, where does the number come from? Two lawful routes, not one. Either the actual emissions of the installation that produced the goods, which must be verified by an accredited verifier, or default values published by the Commission, which carry no verification duty. The default route is often cheaper for a small or occasional import, and it is a route in the regulation rather than a second-best estimate. We cover the mechanics in CBAM, what you need to know.
Where do automotive supplier emissions actually sit?
In what you purchase, not in what you run.
Purchased materials dominate, and metals lead. Steel, aluminium and castings carry emissions intensities that dwarf the energy used to machine them. For most tier 1 and tier 2 suppliers this is the majority of the footprint by a wide margin.
Plant energy is measurable and secondary. It is the part you can meter precisely, which is why teams over-invest in it. Precision on a small share does not fix uncertainty on a large one.
Logistics is real but rarely decisive. Worth including, rarely the thing that moves a per-part figure.
The consequence for a supplier is uncomfortable and worth stating early: your ability to answer an OEM well depends on your own suppliers answering you well. You are in the middle of the chain, passing a request upstream and an answer downstream, and the quality of what you can send is capped by what you can collect.
Why does a company footprint not answer an OEM request?
Because they measure different things and cannot be converted into one another.
An organisational footprint tells you the emissions of a legal entity over a year. A product carbon footprint tells you the emissions attributable to one unit of one part, with a defined functional unit, a defined system boundary and allocation rules for shared processes. Dividing your annual total by units shipped is not a PCF, and an OEM reviewing it will say so.
| The ask | What it needs | Where it comes from |
|---|---|---|
| OEM PCF per part | Functional unit, boundary, allocation, per-part figure | Bill of materials plus supplier data plus process energy |
| CBAM, only if you import covered goods above 50 tonnes a year | Embedded emissions of the consignment | The producer's verified actual emissions, or a Commission default value |
| Customer scope 3 questionnaire | Company-level inventory, sometimes per category | Organisational footprint |
| Your own reduction programme | Company-level inventory with a stable base year | Organisational footprint |
Read down that table and the practical answer appears: you probably need two of these artefacts rather than three, they share a data foundation, and confusing them is what causes a supplier to spend a quarter building the wrong thing.
What does the software actually have to do?
Four things, plus one honest caveat about the fifth.
Hold supplier-specific emissions data, not just averages. An OEM asking for a PCF generally will not accept an industry average for your main input material where a supplier certificate exists. You need somewhere to store the certificate value and use it.
Map the purchase ledger to materials. Your ledger has part numbers and euros. Your footprint needs materials and kilograms. That translation is the work.
Keep the method stable across a model year. Programmes run for years and a figure that moves because a factor library updated needs to be distinguishable from a figure that moved because you changed a supplier.
Show its working. An OEM audit asks you to evidence a number, not just state it.
Produce the per-part figure. This is the caveat. Organisational carbon platforms, ours included, do organisational footprints. A PCF is a modelling exercise, not a report you export.
What does Hedgehog do for automotive suppliers, and what is a service?
The platform covers GHG Protocol setup, data collection planning, inventory building and reporting, guided by an AI assistant with human GHG experts reachable in-app. It carries over 20,000 spend-based and activity-based factors and, importantly for this sector, lets you add organisation-specific and supplier-specific CO2 data, which is where a steel supplier's certificate value belongs. Multi-entity management covers suppliers running several plants or legal entities. The free account requires no sales call. Pro starts at EUR 1,200 a year.
Two limits, both worth knowing before a nomination deadline.
Product footprints are delivered as a service. LCA, EPD, ECI (MKI in Dutch) and PCF work is a project with a specialist, not a platform feature. At Hedgehog that runs through LCA consulting and carbon footprint consulting. Given that the OEM ask is specifically a per-part figure, this is the most important sentence on this page for an automotive reader. The platform builds the organisational inventory and the supplier data foundation that the PCF work draws on. It does not emit the PCF.
Loading the data takes real effort. A Small Business reviewer told G2 in August 2026 that everything works perfectly once the data is in, and that getting it in is the hard part. With a bill of materials running to thousands of lines and supplier certificates arriving as PDFs in three languages, that is the realistic first-year shape. Plan it as a quarter of work, not a week.
What is worth starting this quarter?
Read the request and classify it before you buy anything. If the words are "per part", "per kilogram" or "functional unit", it is product work. If the words are "scope 1, 2 and 3" or "company emissions", it is organisational work. Suppliers routinely spend a month on the wrong one.
Then take your top ten purchased materials by spend and ask those suppliers, in writing, for the embedded emissions of what they sell you and the basis for the figure. That request has a long lead time and it answers the OEM ask directly. If you are also the importer of record on any of those lines, it does double duty.
Meanwhile you can start a free account and build the organisational inventory from plant energy and the purchase ledger. It gives you a base to work from and it tells you quickly how much of your ledger is going to need mapping.
Sources: our platform page and our G2 profile, both read on 27 August 2026. CBAM facts from Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083 and the Commission's CBAM page, verified 16 September 2026: the six covered sectors, the 1 January 2026 definitive regime, the 50 tonne annual de minimis in Article 2a and the actual-or-default routes in Article 7(2). Sector facts from the Hedgehog industry fact base, verified 17 September 2026. CBAM detail moves, so confirm the current position with your customs advisor before you file anything. Verified 17 September 2026.
Facts on this page were last verified on 2026-09-17.
