CBAM Compliance Verification
EU Carbon Border Adjustment Mechanism
Independent verification for the EU CBAM
The EU Carbon Border Adjustment Mechanism (CBAM) is designed to put a fair price on the carbon emissions linked to imported goods. It affects businesses both inside and outside the EU, and it is already changing how companies measure, report and verify emissions.
Control Union has applied for accreditation for CBAM verification activities through its Dutch office and is preparing to offer CBAM verification services once accreditation has been granted. Until accreditation is obtained, Control Union cannot provide accredited CBAM verification services.
What is CBAM?
CBAM is intended to ensure that certain imported goods are subject to the same carbon costs as products made within the EU. It entered its definitive phase on 1 January 2026, shifting from transitional reporting to mandatory financial compliance.
CBAM currently focuses on carbon-intensive sectors such as iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. This means:
- If you import relevant goods into the EU, you must report the carbon emissions linked to their production
- You may need to pay for those emissions by purchasing CBAM certificates
- The more emissions associated with your goods, the higher the cost
Even if your organisation is not directly responsible for reporting under CBAM, you may still be asked to provide verified emissions data to remain a competitive supplier to customers who are located within the EU.
What are the benefits of CBAM verification?
Verification is the process of independently checking that your emissions data is accurate and meets the required standards. Under CBAM, verified data allows you to use actual emissions instead of default values.
Using verified emissions data rather than default values can potentially lower your carbon costs, while also reducing the risk of errors, penalties or non-compliance.
Independently verified emissions data may also help you respond to broader stakeholder or market expectations, such as customer, investor, or commercial partner requirements related to carbon performance.
What is the timeline for complying with CBAM?
Importers begin reporting embedded emissions for covered goods entering the EU.
Importers and producers strengthen emissions monitoring systems, calculation methodologies and reporting processes ahead of mandatory verification.
Importers become financially responsible for embedded emissions through the purchase of CBAM certificates. Verified actual emissions data becomes increasingly important to avoid conservative default values.
Organisations collect and maintain detailed emissions data and supporting documentation for the first full CBAM reporting year.
Producers complete verified emissions reports and importers submit annual CBAM declarations covering the 2026 import year. The current deadline for submission is 30 September 2027.
How does CBAM affect importers?
If you import carbon-intensive goods into the EU, CBAM introduces new reporting and financial obligations linked to the emissions generated during production. Since the start of the definitive phase in 2026, importers have been required to report embedded emissions and purchase CBAM certificates reflecting the carbon intensity of imported goods. Sectors currently covered include iron and steel, aluminium, cement, fertilisers, electricity and hydrogen.
Importers can either use default emissions values or submit verified actual emissions data provided by suppliers. While default values may appear simpler initially, they are generally conservative and can result in higher CBAM-related costs. Increasingly, importers are therefore working closely with suppliers to obtain independently verified emissions data that supports more accurate reporting, improved competitiveness and reduced compliance risk. Robust supply chain engagement and early preparation are becoming essential as CBAM requirements continue to evolve.
How does CBAM affect producers?
Producers located outside the EU may still be directly affected by CBAM if they supply goods into European markets. Importers increasingly require verified emissions data from producers to support their own CBAM declarations and reduce reliance on default values. Organisations unable to provide reliable emissions information may become less competitive compared to suppliers with verified actual emissions data.
For producers, CBAM preparation typically involves establishing robust emissions monitoring systems, collecting traceable production data and preparing for independent verification. This can be particularly important across carbon-intensive sectors such as steel, cement, fertilisers, aluminium, hydrogen and electricity generation. Beyond compliance, verified emissions data can also support wider customer, investor and sustainability expectations around transparency and carbon performance.
With offices around the world, Control Union is well placed to support exporters supplying European markets, with EU CBAM accreditation through our Dutch office.
How does CBAM affect different industry sectors?
Steel and iron are among the sectors most directly affected by CBAM due to the carbon intensity of production processes and the scale of trade into the EU. Reporting requirements typically include direct emissions from production as well as certain indirect emissions linked to energy use. Given the complexity of production routes and supply chains, robust emissions monitoring systems and verified actual emissions data are increasingly important to avoid reliance on conservative default values and potentially higher CBAM costs.
Cement manufacturing is highly emissions-intensive, with significant emissions generated both through fuel combustion and the chemical calcination process itself. CBAM reporting for cement producers therefore requires detailed process-level emissions calculations and reliable production data. Companies that begin preparing emissions monitoring methodologies early are likely to be better positioned for accurate reporting and verification.
For aluminium producers, electricity consumption is a major contributor to overall embedded emissions. This makes data quality and traceability particularly important, especially where production involves multiple facilities or external energy suppliers. Organisations may need detailed information on electricity sourcing, production methods and emissions factors to support compliant reporting and verification.
Fertiliser production often involves emissions-intensive chemical processes, particularly in ammonia production and related activities. Accurate calculation methodologies and monitoring systems are essential to support CBAM reporting requirements. Producers exporting into the EU may increasingly require verified emissions data to maintain competitiveness and support customer reporting obligations.
Hydrogen is expected to play an increasingly important role in industrial decarbonisation, but emissions profiles can vary significantly depending on production methods and energy sources. Producers may therefore need robust verification of embedded emissions and production pathways to support CBAM reporting and broader low-carbon market claims. Please note that Control Union will not offer CBAM verification for hydrogen.
Electricity imports are subject to specific CBAM considerations linked to generation sources, cross-border transmission and emissions intensity. Reliable emissions calculations and transparent supporting documentation are critical, particularly where importers seek to demonstrate lower actual emissions values instead of relying on default assumptions. Please note that Control Union will not offer CBAM verification for electricity.
Many manufacturers outside the directly regulated sectors may still be affected indirectly through customer requirements and supply chain expectations. Increasingly, EU importers and multinational buyers are seeking verified emissions data from suppliers to support their own CBAM reporting and wider sustainability commitments. This is driving growing demand for product-level emissions transparency and independent verification across global supply chains.
What are the five most common mistakes companies make in their first CBAM report?
- Relying on default values without understanding the cost impact Organisations sometimes rely on default emissions values because they are easier to use and do not require external verification. But default values are intentionally conservative and can result in significantly higher CBAM costs. Verified actual emissions data not only improves reporting accuracy, it also reduces unnecessary costs.
- Underestimating the complexity of emissions data collection
Many organisations do not yet have the monitoring systems, documentation or calculation methodologies needed to fully support CBAM verification. In practice, many businesses discover gaps in their emissions reporting processes only once formal verification preparation begins. - Waiting too long to prepare for verification
It takes time to gather production data, align methodologies, review calculations and address any gaps before verification takes place. Control Union’s pre-verification approach is designed to help businesses identify weaknesses in emissions monitoring systems early, reducing the risk of delays or non-compliance during formal verification. - Assuming CBAM only affects EU-based companies
CBAM directly affects importers into the EU, but it also has major implications for producers and suppliers located outside Europe. Exporters increasingly need verified emissions data to remain competitive with EU suppliers and support their customers’ reporting obligations, especially in carbon-intensive sectors such as steel, aluminium, cement, fertilisers, electricity and hydrogen. - Treating verification as a paperwork exercise rather than a commercial issue
CBAM reporting is not only about compliance. Verified emissions data can influence import costs, competitiveness and customer relationships. Organisations that approach verification strategically may be better positioned to reduce exposure to conservative default values, strengthen supply chain transparency and respond to growing customer and investor expectations around carbon performance.
FAQ
The Carbon Border Adjustment Mechanism (CBAM) is an EU regulatory framework designed to place a carbon cost on certain imported goods. Its objective is to ensure products imported into the EU face similar carbon costs to goods produced within the EU under the EU Emissions Trading System (EU ETS).
CBAM primarily affects EU importers of affected goods. But producers and suppliers located outside the EU may also be impacted, as importers increasingly require detailed and verified emissions data from their supply chains to support CBAM reporting obligations.
CBAM entered its transitional reporting phase in October 2023. The definitive phase began on 1 January 2026, introducing financial obligations linked to embedded emissions and the purchase of CBAM certificates.
CBAM currently focuses on carbon-intensive sectors, including:
• iron and steel
• aluminium
• cement
• fertilisers
• hydrogen
• electricity
The scope may expand over time as the regulation develops.
During the transitional phase, organisations were required to report emissions data but were not yet required to purchase CBAM certificates. Under the definitive phase, importers become financially responsible for embedded emissions associated with covered goods and must purchase CBAM certificates accordingly.
Verified emissions data is required where organisations wish to report actual emissions values under CBAM. Without independent verification, importers can rely on default values instead. From January 2026 onwards, third-party verification has become increasingly important for organisations seeking accurate reporting and reduced exposure to conservative default emissions values.
Default values are standard emissions values provided under the CBAM framework and are generally easier to use initially. However, they are typically conservative and may result in higher CBAM-related costs. Actual values are based on the producer’s real emissions data and require independent verification, but they can provide more accurate reporting and potentially lower carbon costs.
Although CBAM is an EU regulation, it has significant implications for producers outside Europe that export goods into the EU. Importers increasingly require verified emissions data from suppliers to support their own CBAM declarations. Producers that can provide reliable and verified emissions information may be better positioned to maintain competitiveness within European markets.
Control Union combines technical knowledge with a clear understanding of how CBAM works in practice. Our specialist verification team can help you understand your obligations and take the right steps towards CBAM readiness, with EU accreditation through our Dutch office.
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