Who this is for
Producers of CBAM goods exporting to EU customers, directly or via traders.
This guide is written as a verifier would assess your installation data before it is relied upon by EU importers.
The producer’s objective
Your role under CBAM is not to report to the EU directly, but to:
generate installation-level, route-specific emissions data,
document methodologies and assumptions clearly, and
enable downstream customers to report and (from 2026) pay for CBAM accurately.
From a verifier’s perspective, your data must be replicable, traceable, and internally consistent.
Your 7-step producer path
1. Confirm you sell CBAM goods into EU value chains
What you must check
That you you produce EU CBAM goods and that your products are imported into the EU under CBAM-covered CN codes. Otherwise, you may not need to prepare EU CBAM data
How to do this
Check your export commodity code classifications.
Ask customers which products and CN codes they import.
Confirm whether sales are direct or via intermediaries.
2. Define covered CBAM products and production routes
What you must prove
That emissions values correspond to specific products and routes, for your site.
How to do this
List CBAM goods by:
product type,
installation (if multiple production sites),
production route.
Separate routes with materially different emissions profiles.
3. Create a monitoring methodology
What you must prove
That your methodology for preaparing installations emissions and benchmark data is complete, documented, and consistently applied.
How to do this
Define:
system boundaries,
data sources,
allocation rules,
QA/QC checks,
change control procedures.
Align with ETS-grade principles where applicable. CarbonChain can provide extensive further guidance on this requirement.
Verifier red flags
Undocumented assumptions & lack of evidence to justify decisions.
Methodology that changes between periods without explanation.
4. Collect precursor and input emissions data
What you must prove
Where you have in-scope precursor suppliers, that upstream inputs are treated consistently and transparently (and ultimately are verified for 2027).
How to do this
Identify all relevant precursors you consume on site.
Request supplier-specific emissions & benchmarks, where possible.
Document fallback assumptions where data is unavailable; you will need to apply default values here.
5. Track production data continuously
What you must prove
That emissions data reflects actual production over the reporting period.
How to do this
Capture data weekly, monthly or quarterly (depending on requirement):
fuel use,
electricity use,
input materials,
process emissions,
production output.
Maintain a clear audit trail with full documentation.
Verifier red flag
Year-end reconstruction without contemporaneous records.
6. Run pre-verification checks
What you must prove
That data issues are identified and corrected before sharing.
How to do this
Review for:
unit consistency,
missing factors,
boundary misalignment,
unexplained volatility.
Document findings and corrective actions.
Request a third-party to perform pre-verification checks.
7. Share downstream with EU customers
What you must prove
That shared data is complete and prepared in accordance with the EU guidance. Note that from 2027 onwards, you will have to provide both the verified data and a verification statement.
How to do this
Use CarbonChain Downstream Data Sharing to provide:
emissions per product and route,
methodology notes,
evidence references,
verification statement (when available).
What “good” looks like
A well-prepared installation can:
provide route-specific emissions values with a clear audit trail,
explain year-on-year changes in emissions intensity,
demonstrate control over data quality and methodology,
pass verification with minimal remediation, and
support EU customers’ CBAM compliance without repeated clarification.