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Regulation and sustainability

When the supplier does not have the data

The commonest situation when new regulation starts, and what to do without blocking everything.

Updated on 13/08/2026

You ask for composition, origin or footprint and the supplier says they do not have it. They are not lying: most likely nobody ever asked them, and they in turn depend on their own supplier. It is the commonest situation at the start and it has to be handled without stopping supply.

What to do, in order

  1. 1

    Record that you asked

    With its date. It is what shows diligence even if the data never arrives, and it is what you will be asked about.

  2. 2

    Ask which part they do have

    It is rarely all or nothing. Often they have origin but not footprint, or the reverse.

  3. 3

    Give a realistic deadline

    If they depend on their supplier, two weeks is not enough. An impossible deadline guarantees no answer.

  4. 4

    Decide whether it changes anything

    Do you keep buying? Look for an alternative? It is a commercial decision worth taking rather than leaving open.

Important

What you must not do is fill the gap with an estimate and treat it as fact. If you pass it to a customer as a firm figure, that number carries your signature and your company answers for it, not the supplier who did not have it.

What you can answer meanwhile

"We do not hold that data as of today; we requested it from our supplier on X and expect it by Y." That is a professional, verifiable answer and far better than an invented number. Most customers accept it; those who do not are asking you to lie.

Watch out

If several customers ask for the same data, do not chase it separately. One case per supplier with the request made once serves to answer all of them, and stops the supplier receiving the same request four times.

Worth knowing

The sooner you start asking, the less it hurts. Suppliers who lack it today will acquire it, and those asking you will do so on ever shorter deadlines.

Can I require it contractually?

On future renewals it is standard; check with your adviser.

What if they never provide it?

That is information for a commercial decision. The case at least proves you asked.

Is an unsupported declaration from them enough?

It depends on the data and who you pass it to; ask before assuming it suffices.

A real case

The situation

A manufacturer receives the same origin request from three customers and lacks it from eight suppliers.

What you do

  1. Launches a single request per supplier with a two-month deadline
  2. Tells all three customers what it has and when the rest will come

What you get

Keeps all three customers without inventing a figure, and two months later holds six of the eight.

The situation

The supplier says they do not have the data and it stops there.

What you do

  1. Records the request and the reply

What you get

The gap is a documented finding rather than silence.

The situation

The whole file is blocked over one missing figure.

What you do

  1. Moves on with the rest and flags that point

What you get

What can be completed is completed.

The situation

The supplier does not understand what is being asked.

What you do

  1. Explains the data point with an example

What you get

The reply arrives on the second request.

The situation

The data sits with your supplier's supplier.

What you do

  1. Asks them to pass it back up the chain

What you get

The chain is walked to where the data is.

The situation

An estimate is invented to fill the gap.

What you do

  1. Declares it as an estimate and on what basis

What you get

What is declared is defensible.

This article answers

  • my supplier cannot give me the composition
  • supplier without sustainability data
  • what to do when origin data is unavailable
  • non-eu supplier not responding with data