CBAM Desk

CBAM Supplier Emissions Data: A Practical Preparation Checklist

Sources checked

The CBAM definitive regime applies from 1 January 2026. For importers and their suppliers, the practical work is not the certificate purchase — it is assembling installation-level and product-level emissions figures that can actually be traced back to a source document. This checklist sets out what to collect, in order.

First confirm the goods are in scope

CBAM applies to imports of selected goods in six sectors: cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. Check the CN codes and the sector-specific requirements on the Commission's CBAM sectors page before commissioning any data collection from a supplier. Sector-specific requirements and CN-code classification are what determine whether and how a given good falls within scope; the six-sector list alone does not settle it.

Then work out who has the obligation

EU importers — or their indirect customs representatives — who import more than the single mass-based threshold of 50 tonnes of CBAM goods into the EU are required to apply for the status of authorised CBAM declarant. Registry access is requested through the National Competent Authority of the EU country where the importer is established.

Treat that 50-tonne figure carefully. It is the mass-based threshold at which an importer in this context is required to apply for authorised CBAM declarant status; it is not a blanket exemption you can rely on across all sectors or all circumstances, and it does not by itself settle whether a given good falls under CBAM — the product and sector applicability check comes first. As a practical suggestion rather than a requirement set out in the sources, where the volume sits near the line, ask the National Competent Authority rather than assuming.

Ask suppliers for the right things

Non-EU installation operators are the source of the underlying figures, so the request to them needs to be specific. Ask for, per production installation and per covered good:

  1. Installation identification and address, plus the reporting period the data covers.
  2. Direct emissions per tonne of product, with the calculation boundary stated.
  3. Indirect emissions, where they are relevant to the production route.
  4. The activity data behind each figure: fuel quantities, electricity volumes, production output.
  5. The measurement source — meters, weighing records, laboratory analysis — and its calibration reference.
  6. Any carbon price already paid in the country of production, with the evidence.

The European Commission published ten guidance documents for non-EU installation operators on 14 August 2026. Guidance No. 3 covers methods for calculating embedded emissions; Guidance No. 2 is a quick guide for non-EU operators on CBAM implementation. Sector-specific documents (5a–5f) cover cement, hydrogen, fertilisers, iron and steel, aluminium, and electricity. Use Guidance No. 3 and the relevant sector document as the reference points against which you check a supplier request.

Separate actual data from default values

Default values exist, and they are not a shortcut that removes the data obligation everywhere. The Commission published the corrected default values in Commission Implementing Regulation (EU) 2026/1740; a consolidated version of Commission Implementing Regulation (EU) 2025/2621 — which holds the binding default values — will be available soon. The Excel file is provided for information purposes only; the regulation holds the binding values. Benchmarks are set out in Commission Implementing Regulation (EU) 2025/2620.

So when a supplier sends you a figure, ask which of these it is: a measured installation value, or a default value used as a substitute. Keep them labelled separately in your files.

Collect the carbon price evidence early

If importers can prove that a carbon price has already been paid during the production of the imported goods, the corresponding amount can be deducted. "Prove" is the operative word. As a practical suggestion of our own rather than a requirement set out in the sources, it helps to ask suppliers for the underlying instrument — the rate, the schedule, the covered tonnes, and proof of actual payment — rather than a sentence asserting that a price exists.

Then check the accreditation question

Accreditation and verification sit in Commission Delegated Regulation (EU) 2025/2551. Commission guidance on CBAM verification and accreditation for verifiers and National Accreditation Bodies was published on 24 August 2026; it is addressed to verifiers and National Accreditation Bodies rather than to importers. If you plan third-party verification of supplier data, start from that regulation and that guidance and supplement them as needed with your own assurance checklist.

What this means for your file structure

A workable supplier data pack, in order of assembly:

  • Scope confirmation by CN code and sector.
  • Importer threshold and declarant status check.
  • Per-installation, per-product emissions with stated boundaries.
  • Activity data and measurement sources behind each number.
  • Default values flagged as defaults, held separately.
  • Carbon price paid evidence, where a deduction is claimed.
  • Verification and accreditation route identified early.

One thing to keep in view on timing: authorised CBAM declarants buy certificates from the National Competent Authority in their country of establishment, and the certificate price follows EU ETS auction prices expressed in €/tonne of CO2 — quarterly average in 2026, weekly average from 2027 onwards. Since importers declare embedded emissions and surrender the corresponding certificates each year, the point for data collection is timing: figures need to be traceable when the annual declaration and surrender come round.

This checklist is editorial guidance for organising your own data work. It is not legal, tax, or certified assurance advice, and it does not confirm compliance for any specific operator or consignment.

Official sources

Checked 2026-10-14