Does coal or gas I use as a raw material count as energy in the European Union (EU) voluntary standard for small companies (VSME)?
No. The standard says to leave out feedstocks and fuels that are not burnt for energy when you fill the energy table. You can report that use separately. Only fuel burnt for heat, power or steam goes in. VSME is the European Financial Reporting Advisory Group's Voluntary standard for non-listed micro-, small- and medium-sized undertakings.
The rule
The standard says that when you prepare the energy figure, you shall exclude feedstocks and fuels that are not combusted for energy purposes. A company that uses fuel as a feedstock can disclose that use separately from the required figures.
In plain words
Flour in a bakery is an ingredient. Gas under the oven is energy. Both are bought, but only the gas goes in an energy table. Our reading: a fuel that ends up in the product, or is used up in a chemical reaction, is the flour.
How to split your invoices: our suggestion
- List each fuel you buy with its tonnes or litres for the year.
- For each fuel, write how much was burnt for heat, steam or power and how much went into the product or reaction. Plant logs, batch sheets or the engineer's estimate can support the split.
- Convert only the burnt part to megawatt hours (MWh). Report the rest separately if you wish.
What this page does not settle
This is only the energy table. How to count the emissions from material that is chemically changed is a separate question for the Greenhouse Gas (GHG) Protocol, and the text we read does not answer it for B3. Ask your buyer, and write down the split and the basis you used. Whether coal used to reduce ore counts as burnt for energy is not settled in the text we read; ask your buyer.
Example: a coal purchase split two ways
- Bought in the year: 500 tonnes of coal
- Burnt in the boiler: 380 tonnes. Used as an ingredient: 120 tonnes
- Conversion: the standard's own example is 11.9 terajoules (TJ) per gigagram, which is 3.31 MWh a tonne
- Energy table: 380 x 3.31 = 1,257.8 MWh. The 120 tonnes are reported separately, if at all.
The 3.31 MWh a tonne is the standard's example conversion, not a value for Indian coal. Use your supplier's calorific value.
What Senseible does here
Senseible reads fuel invoices and electricity bills into records, so the fuel and units you bought are on file for this disclosure. Tank dips, plant logs and meter readings stay with you, or can be connected as a custom meter integration on request.
Last reviewed 2026-11-07. Facts are from the standard's own text, with the paragraph numbers named in the source line. The European Commission adopted its own standard for voluntary use in a Delegated Regulation of 3 July 2026, which is not in force until it is published in the Official Journal and may differ from this text, so ask your buyer which one it means. Our own readings are marked as such.