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customer asks whether we purchase circular materials

Circular procurement falls under raw material policy, not under waste

This question concerns the purchasing side: does the company purchase materials that are recycled or suitable for reuse. This is a different subject than how much waste is generated or what proportion of it is separately collected — those questions are in the waste section, not here. A customer asking this question usually wants to know whether the company actively steers its choice of raw materials: recycled material, reusable packaging, refurbished components, or suppliers that offer circular products.

There is no statutory threshold or percentage that determines when the answer is "yes". Evidence is usually straightforward: a purchase invoice stating that the material is recycled, a supplier declaration, or a specification in the contract. Without such documentation, the answer cannot be substantiated with a yes, even if the company has the impression that "most of it is sustainable" — an impression is not a source. If there is no document whatsoever confirming the origin of materials, then "no" or "not known" is the answer that fits the facts. If you are unsure whether a supplier does procure circularly but documentation is lacking, that is a reason to ask the supplier before you confirm the answer, not to set the answer to yes anyway.

This question often appears in the same section as the questions about total energy consumption per year and scope 3 emissions, because the purchase of raw materials counts in the supply chain. Anyone wanting to understand that connection will find the explanation at emissions in the value chain.

Where this appears in the VSME base module

The VSME standard of EFRAG treats raw materials and circularity as a separate area of focus within the basic module for non-listed SMEs, separate from waste indicators. Questionnaires based on VSME usually include circular procurement as a separate question alongside — not as part of — the waste questions. The scope classification of the GHG Protocol is relevant here because purchased materials fall under scope 3: the indirect emissions that occur before the materials enter the company.

What this is based on

The regulation itself is on EUR-Lex. We refer for each claim; you do not have to take our word for it.

What you concretely need to do

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This is not legal advice. This page provides general information on the regulations this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections receive priority.