REGULATIONSCBAM

Carbon Border Adjustment Mechanism

You are the authorised CBAM declarant, or your indirect customs representative is. The duty to declare embedded emissions is yours; the data that satisfies it sits with your supplier.

FALLS ONSUPPLIERBUYER

This one falls on you directly. Only an authorised CBAM declarant may import CBAM goods at all.

THE OFFICIAL ARTIFACT

What the supplier must actually produce.

Not a carbon report. A per-installation emissions record the declarant can carry into a legal filing without restating it.

WHO SIGNS IT OFF
An accredited third-party verifier signs the emissions report. You file the CBAM declaration by 30 September, using the verified figures the operator discloses to you through the registry.
REQUIRED ARTIFACT · CBAM6 ELEMENTS
Verified installation emissions data
REG. (EU) 2023/956 · ANNEX IV · MRR METHODOLOGY
Installation identity and operatorName, address and UN/LOCODE of the plant that produced the goods.
CN code and production routePer good, matched to the aggregated goods category and the route actually used.
Direct embedded emissionsActual, monitored, per tonne of output — MRR methodology, not a life-cycle figure.
Indirect emissions and electricity factorConsumption and the emission factor applied, with its source.
Carbon price paid in origin countryWhere one applies, with evidence it was not refunded.
Verification statementFrom an accredited verifier, covering the reporting period.
THE CHARACTERISTIC FAILURE

An EPD arrives, and it looks like proof.

The document arrives, it is real, and it does not carry what you have to file. You find out in September.

WHAT USUALLY ARRIVESINSUFFICIENT
Environmental Product Declaration
PROGRAMME OPERATOR · ISO 14025 / EN 15804 · CRADLE-TO-GATE
GWP per tonne, life-cycle basis, third-party verified
Averaged across a product family and multiple sites
No installation identity, no MRR monitoring plan
NOT SUFFICIENT
A valid document answering a different question. CBAM asks what this installation emitted, not what the life cycle averages to.
WHAT THE REGULATION NAMESSUFFICIENT
Verified installation emissions data
ACCREDITED VERIFIER · MRR METHODOLOGY · ONE INSTALLATION
Direct and indirect emissions per tonne, monitored, per production route
Named installation, UN/LOCODE, reporting period stated
Verifier statement the declarant can rely on
SUFFICIENT
Same product, same emissions — recorded on the basis the regulation actually names.
THE DELTA: LIFE-CYCLE AVERAGE VS MONITORED ACTUALS FOR ONE NAMED INSTALLATION
NEXT MILESTONE · CBAM
LAST VERIFIED 9 AUG 2026
399DAYS
NOT YETAPPLIES 30 SEP 2027
First CBAM declaration for 2026 goods

The declarant files for calendar year 2026. Actual embedded emissions, MRR methodology, per installation — the supplier data has to exist long before the filing window.

Does CBAM reach your products?

Find out which of your suppliers can give you installation-level actuals — and which will leave you filing on default values.

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