When an EU customer requests product-emissions information, data should link back to the producing installation, process, and precursor materials. Confirm goods and trade arrangements first, then organize plant records into traceable calculations and evidence.
When to begin
When a customer spreadsheet arrives, export goods change, or transitional reporting continues into the definitive period, check CN codes, origin, installation, and importer. The CBAM definitive period began on 1 January 2026; transitional quarterly templates should be checked against current definitive-period requirements.
From plant totals to product data
Energy bills support site consumption but do not identify which goods were produced, which precursors were used, or how shared processes should be allocated. Upstream emissions should be tied to the relevant installation, period, and product, not recorded as an unsupported factor.
Scope, roles, and key dates
CBAM covers specified goods in sectors including cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. Confirm product coverage using the relevant CN code and rules. The 50-tonne threshold is assessed against the EU importer’s cumulative annual net mass of covered goods; electricity and hydrogen do not receive this exemption. If the threshold is exceeded, obligations apply to the covered imports for the year, not only the amount above the threshold.
For 2026 imports, the first annual declaration and surrender of certificates are due by 30 September 2027; certificate sales begin in February 2027. Agree data delivery dates between the supplier and the EU authorized CBAM declarant separately.
For actual emissions, confirm that an independent verifier is appropriately accredited for CBAM and that the verification scope covers the data. For default values, verify the applicable version. Embedded emissions and certificate quantities are different; certificate calculation can also involve free-allocation adjustments and eligible carbon prices paid. Commercial cost allocation depends on the transaction agreement.
Suggested data-preparation stages
- Use an export-goods list to confirm product classification, reporting year, production site, and EU contact.
- Collect production, energy, and precursor data along the process; assign an owner to each field.
- Check units, periods, factors, and allocation; track missing upstream data and verification issues separately.
- Prepare customer-format data, calculation version, and evidence index; retain responses and corrections.
Information and possible outputs
Prepare product descriptions and CN codes, origin, transaction volume, process maps, output, energy and precursor records, and customer instructions. Possible work includes boundary mapping, data-gap review, calculation checks, and verification readiness. Formal declarations and certificate handling remain with the qualified and authorized responsible party.
Workload depends on goods, production routes, number of plants, and access to upstream data. Separate advisory support, independent verification, platform work, and certificate costs, and allow time for customer follow-up and verification scheduling.