EU importers of CBAM goods, and indirect customs representatives acting on their behalf.
This guide is written from a auditor's perspective: it explains not just what to do, but what must be true for your CBAM data to withstand regulatory scrutiny. Note that your declarations won't themselves be verified however, the EU's Fraud Office may review your declarations and so it is critical you are audit-ready.
What CBAM requires (today vs. 2026)
Transitional phase (1 October 2023 – 31 December 2025)
You are required to report embedded emissions for all covered CBAM imports.
As an importer, you are responsible for ensuring that:
reported quantities reconcile to customs records,
emissions values are attributable to a specific installation and production route, and
any use of estimates or defaults is explicitly identified and justified.
This phase is already functioning as a data qualification and enforcement dry-run. Data gaps identified now will materially affect your exposure from 2026 onward.
Definitive regime (from 1 January 2026)
CBAM becomes a financial compliance regime:
Only authorised CBAM declarants may import covered goods.
Embedded emissions become financially liable, via CBAM certificates linked to EU ETS pricing.
Poor data quality directly translates into higher cost exposure, especially where defaults apply.
From a verifier’s standpoint, 2026 readiness is determined by the quality and traceability of data you build during the transitional phase.
The importer’s objective
By 2026, a compliant importer should be able to demonstrate that:
every reported import line item is traceable to a product, CN code, origin, supplier, and installation,
embedded emissions values are route-specific, period-specific, and documented, and
assumptions, estimates, and gaps are transparent, consistent, and defensible.
You will need to have this in place to obtain the Authorised Declarant Status.
Your 7-step importer path
1. Confirm you import CBAM-covered goods
What you must prove
That each imported product has been correctly classified under CBAM scope.
How to do this
Review your customs import declarations to confirm CBAM scope alignment
Retain evidence of how classification decisions were made (product specs, customs advice).
2. Confirm your in-scope reporting entities
What you must prove
Who is legally responsible for CBAM reporting obligations and (from 2027) certificate surrender.
How to do this
Check whether reporting is done by:
the importer of record, or
an indirect customs representative acting on your behalf.
You are responsible for EU CBAM obligations if you are the importer of record and you are established in the EU; otherwise your indirect representative is responsible.
If you purchase goods on a DDP basis into the EU then your supplier is responsible for CBAM.
3. Create a supplier data plan
What you must do
That you have established procedures in order to obtain and manage data received from suppliers in order to include this data in your EU CBAM declarations.
How to do this
Identify all suppliers, products, production routes, and countries of origin.
Prioritise suppliers by:
import volume, and
emissions intensity risk.
Issue formal data requests using a consistent template.
Manage, retain and review data received by suppliers.
Ensure that suppliers are readily aware of verification obligations and the impact of non-compliance with verification; particularly regarding use of default values.
4. Collect supplier emissions data
What you must prove
That emissions values relate to a specific installation, route, and reporting period; and ultimately have been verified by a third-party accredited verifier.
How to do this
Collect:
installation identity and location,
production route,
embedded emissions intensity,
methodological notes and evidence references.
Explicitly tag data as:
actual,
partial actual, or
estimated/default.
5. Upload and validate data in CarbonChain
What you must prove
That reported data is internally consistent and technically valid.
How to do this
Upload data via CBAM Supplier Catalogue.
Resolve validation issues:
unit mismatches,
missing route identifiers,
inconsistent quantities.
Confirm that uploaded emissions align with product and CN mappings.
6. Calculate exposure and plan for 2026
What you must prove
That you understand your cost exposure and its sensitivity to data quality.
How to do this
Use the CarbonChain Calculator and Exposure Module to model:
actual vs default emissions,
supplier-level exposure,
country-level exposure,
Identify suppliers where data improvement materially reduces cost risk.
Accrue your costs throughout 2026 in order to preare for the cashflow implications in 2027 when you must purchase certificates.
7. Prepare for authorisation and definitive reporting
What you must prove
That your organisation is operationally ready for definitive CBAM obligations.
How to do this
Track:
supplier data completeness,
evidence availability,
internal review and sign-off processes.
Align CBAM reporting with finance, procurement, and customs teams.
What “good” looks like
A well-prepared importer can:
produce a defensible emissions figure per import line item,
clearly distinguish between actual, estimated, and default data,
be confident that the whole organisation is aware of CBAM cost implications,
explain variances between suppliers and routes,
forecast CBAM cost exposure with confidence, and
demonstrate continuous improvement toward verified actual data.
Next articles
How to check if your imports are CBAM-covered
How to request CBAM emissions data from suppliers
How CarbonChain calculates embedded emissions for CBAM
What changes in CBAM from 2026