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Importer vs Producer: what data is required

A quick run-through of data requirements and why "actual" data matters

Updated over 2 months ago

What importers need (for reporting/declarations)

  • Product CN code, quantity, and country of origin.

  • Specific embedded emissions (direct + indirect where applicable) per tonne.

  • Carbon price already paid in origin country (for deduction).

  • Verified supporting documentation and full audit trail.

What producers provide (and need to prepare)

  • Installation-specific production routes and activity data.

  • Verified emissions calculations (aligned with EU methodology from 2026).

  • Precursor emissions (if relevant).

  • Methodology evidence and third-party verification (mandatory from definitive phase).

Why “actual” verified data matters

From 2026, actual verified emissions minimise CBAM costs. Where actual data is unavailable/unverified, country-specific default values apply – these include progressive mark-ups (e.g., +10% in 2026, +20% in 2027, +30% from 2028) to incentivise accurate reporting. Defaults are conservative and increase liability exposure.

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