Market AccessMay 10, 2026

The ESG Passport: What Indian Exporters Now Have to Prove

Tariffs used to be the barrier to the UK and EU. Increasingly it is disclosure — carbon, labour, traceability. What that changes for an Indian business planning to export.

A textile manufacturer in Tiruppur exporting to a London retailer is now effectively selling two things: the fabric, and the data proving how it was made.

The second one is newer, and a lot of businesses are not resourced for it.

The barrier moved

Trade barriers used to be tariffs. The ones that matter now are disclosure requirements: the Carbon Border Adjustment Mechanism, supply chain due diligence rules, and the buyer's own Scope 3 reporting obligations, which get pushed down to suppliers as questionnaires.

None of these are trade barriers in name. In effect, an exporter who cannot answer them does not get shortlisted.

What buyers actually ask for

In our experience the requests cluster: energy source and intensity at the production site, traceability far enough up the chain to identify the raw material origin, labour standards documentation, and an environmental claim that will survive the buyer's own legal review.

That last one catches people out. An Indian supplier's marketing language becomes the buyer's legal exposure the moment it appears on a European pack, so buyers increasingly vet supplier claims as carefully as their own.

See the ESG Media Index

The case for treating it as a moat

Compliance reads like cost. We would argue that for a mid-sized Indian exporter it is closer to a moat, because most of your competitors are not doing it and the ones who are get a shortlist position they do not have to compete for on price alone.

That argument only holds while it is rare. It is getting less rare.

What we do not know

We cannot tell you how quickly enforcement tightens. CBAM's reporting phase has been considerably gentler than its eventual financial phase will be, and the gap between the two is where a lot of planning assumptions currently sit.

We are also unsure how much of the compliance burden ultimately lands on Indian suppliers versus being absorbed by buyers. Right now it is being pushed down the chain. That may not be stable.

Where we have got to

The businesses we see doing this well started before they had to, usually because one large customer asked and they decided to build the answer properly rather than once.

If you are working out what a UK or EU buyer will ask you for next year, that is a conversation we are always glad to have.

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