CBAM requires EU importers to declare the embedded emissions of their imported CBAM goods. To avoid the use of costly default values, they need to ensure actual emission values from their suppliers. Emissions data must meet the monitoring, reporting, and verification (MRV) standards by the EU.

(Last update on 04/03/2026)

The CBAM case for actual emissions

From 2026 onwards, EU importers need to declare embedded emissions of imported goods falling under the Carbon Border Adjustment Mechanism (CBAM). The first CBAM declaration for 2026 will be due by end of September 2027.

Embedded emissions determine the importer’s CBAM costs. These costs materialize when importers as CBAM declarants purchase and surrender CBAM certificates at the EU’s carbon prices to comply with EU rules.

The required number of certificates is based on the specific embedded emissions as emissions intensity in tons of CO2 equivalent per ton of the imported goods.

Embedded emissions cover the greenhouse gases (GHG) released during the production process of a product (i.e. direct emissions) and the electricity consumed in this process (i.e. indirect emissions).

Following the CBAM simplifications, according to CBAM Regulation 2023/956 and Implementing Regulation (IR) 2025/2547 importers have 2 options to determine these embedded emissions:

1. Actual values that reflect the specific production conditions at the installation for manufacturing the CBAM goods; they need to be monitored based on IR 2025/2547 and verified based on IR 2025/2546 in line with the methods and standards in the EU Emissions Trading System (ETS);
2. Default values as the goods-specific average emissions intensity in the country of origin with a mark-up; these default values are set by the EU Commission in IR 2025/2621.

In the absence of actual data from the manufacturers of CBAM goods, importers can rely on default values. However, where production installations operate more efficiently than the country average, using actual emissions data can significantly reduce carbon cost exposure.

CBAM standards for emissions data

To use actual values, EU importers depend entirely on data from non-EU installation operators. For imports in 2026, the full calendar year of 2026 needs to be covered. These producers must collect data according to a monitoring plan, report this data to accredited verifiers and obtain a compliant verification report.

Monitoring of actual data

The calculation of specific embedded emissions follows a top‑down approach as defined in IR 2025/2547: emissions are monitored at installation level, then attributed to production processes, and then converted to specific embedded emissions for the goods produced.

Starting point is the monitoring of data at the installation-level. CBAM allows 2 methodologies:

1. Calculation-based: Monitors source streams (fuels/materials) using activity data and calculation factors (including standard method or mass balance where relevant);
2. Measurement-based: Monitors emission sources using a Continuous Emission Measurement System (CEMS), where applicable.

For each production process and emissions component, operators can select the methodology that gives the most accurate and reliable result. Where existing monitoring systems do not meet CBAM requirements, they need to be adjusted.

Operators need to design and implement a monitoring plan covering key elements such as installation description, relevant goods, methods for monitoring data per production process, and a control system for data quality.

Reporting of emissions data

Whereas the monitoring plan defines how data is to be collected, the operator’s emissions report compiles these data in a standard format as per IR 2025/2547. Together these 2 documents form the basis for verification.

This operator’s emissions report covers, among others:

1. Operator and installation information;
2. Summary of the monitoring plan;
3. For each good produced: the specific embedded emissions, and free allocation, information on the data quality and methods, and share of default values;
4. Total emissions of the installation broken down into production processes, including calculation factors and emissions sources;
5. Quantity of precursors and their emissions based on actual or default values.

Operationally, the emissions report is transmitted to the verifier either via the CBAM Registry (if the operator is registered) or by other means (if not registered). The report must be submitted in English.

The emissions report is a technical compliance document that allows the verifier to trace what was monitored, how calculations were done, and what data sources were used.

Verification of emissions report

CBAM verification is the compliance gate for using actual values based on the principles set out in IR 2025/2546. Verifications can only be done by accredited CBAM verifiers.

Based on the operator’s emission report, CBAM verifications involve:

1. Site visits: For the first verification, a physical on-site visit is required. In subsequent years a virtual visit or a waiver is possible if there are no significant changes to the installation or its monitoring plan.
2. Risk assessments: To assure that the emissions report can be verified as satisfactory, the verifier assesses whether any misstatement, non-conformity or non-compliance has a material impact on the emissions data or free allocation adjustment. A materiality level of 5% is defined.
3. Submission of the verification report with the results of the assessment and the verifier’s statement that the emissions report is free from material misstatements and material non-conformities.

The verification report can be transmitted to the operator via the CBAM Registry (if the operator is registered) or by other means (if not registered). Verification reports for 2026 can be issued in an electronic EU template from January 2027 via the CBAM Registry.

Securing actual emission values

To reduce financial CBAM exposure through the use of actual emission values, importers need to ensure with the producers of their imported goods, that the CBAM requirements for emissions monitoring, reporting, and verification (MRV) are met.

CBAM creates a new compliance interface between importers and their suppliers. In collaboration they can now:

• Review and design CBAM-compliant monitoring plans to secure that all the required data is collected without any material gaps, misstatements, or non-conformities;
• Set-up structured emissions reporting processes with complete CBAM data – including from producers of relevant precursors – for the relevant CBAM reporting period, which usually is the calendar year of the import;
• Identify suitable CBAM verifiers who are accredited by national accreditation bodies in an EU member state for the relevant CBAM activities and who bring capacities to complete verifications in time.

Verification introduces timing challenges. Producers and all their precursor suppliers must complete monitoring and verification before importers can rely on full data for actual values for their annual CBAM declarations. Forward planning is needed.

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Sources and further information:

• EU: Regulation Establishing CBAM (EU 2023/956)
• EU: Implementing Regulation on Verification Principles (EU 2025/2546)
• EU: Implementing Regulation for Methods for Embedded Emissions (EU 2025/2547)

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