CBAM verification and compliance
Prepare your organization for CBAM requirements
The Carbon Border Adjustment Mechanism (CBAM) imposes requirements on the import of certain carbon-intensive goods into the European Union. Importers must provide information on the CO2 emissions generated during the production of these goods. Does your organization use actual emissions data instead of default values? If so, this data must be verified by an accredited CBAM verifier. DEKRA offers independent assessments of emissions data and monitoring processes within the framework of CBAM.
What is CBAM?
CBAM stands for Carbon Border Adjustment Mechanism. It is a European mechanism that links a CO2 price to certain carbon-intensive goods imported from outside the European Union.
The goal of CBAM is to reduce the risk of carbon leakage. This occurs, for example, when production shifts to countries with less stringent climate regulations. Meanwhile, European producers do pay for their CO2 emissions under the EU ETS.
CBAM therefore forms part of the broader European focus on sustainability and reducing greenhouse gas emissions.
As of January 1, 2026, the CBAM transition period has ended, and the final requirements for importers are now in effect.
Who is subject to the CBAM?
CBAM is particularly relevant for organizations that import CBAM-covered goods from countries outside the EU. Manufacturers outside the EU will also be affected by it when they are required to provide emissions data to their European customers.
Many importers are required to obtain the status of an authorized CBAM declarant if they import more than 50 metric tons of certain CBAM goods annually. Different conditions apply to electricity and hydrogen.
Among other things, importers must be able to demonstrate how many embedded emissions are attributable to the goods they import. For manufacturers outside the EU, this means they must ensure that their emissions data at the facility level is transparent, traceable, and verifiable.
Which goods are subject to CBAM?
CBAM currently applies to certain goods in the following sectors:
- Cement;
- Iron and steel;
- Aluminum;
- Fertilizers;
- Electricity;
- Hydrogen.
Whether a product is subject to the CBAM depends on its CN code. This is a European commodity code used to classify products for import and export. For example, unprocessed aluminum has CN code 7601.
Which emissions must be reported under CBAM?
Under the CBAM, the embedded emissions of imported goods are determined. These are the greenhouse gas emissions generated during the production of the goods.
- direct emissions from the production process;
- emissions associated with used recursors;
- where applicable, indirect emissions from electricity consumption.
For the calculation, either default values or actual emission values may be used in accordance with the applicable CBAM rules. If an importer uses actual emission values, these must be verified. This verification is performed by an accredited CBAM verifier.
The final phase of the CBAM began on January 1, 2026. Importers must comply with the new requirements for their imports starting in 2026.
The first annual CBAM return, covering imports from 2026, must be filed no later than September 30, 2027.
Would you like to use actual emission values? If so, you will need verified emission data from the relevant production facility.
That is why thorough preparation is important. Manufacturers and importers must have a clear understanding of their monitoring methods, data sources, calculations, internal controls, and supporting documentation well in advance.
How does a CBAM verification work?
A CBAM verification assesses whether the emissions report and the underlying data comply with the applicable CBAM requirements. The approach depends on factors such as the facility, production processes, goods involved, and available emissions data.
The verifier assesses the facility and relevant production processes. This includes examining production routes, CN codes, precursors, measurement data, data sources, and internal controls.
Based on this, the scope, complexity, and key risks of the verification are determined.
Next, an assessment is made of how the emissions data were collected and calculated. This includes a review of the monitoring plan, the calculation methods used, data flows, and internal control measures.
Checks are also performed to ensure that data can be sufficiently traced back to the original source.
The reported emissions data are assessed for, among other things, completeness, consistency, and accuracy.
In this process, factors such as production data, emission sources, electricity consumption, precursors, emission factors, and the assumptions used can be verified.
Upon completion of the verification activities, an independent assessment is conducted. If the applicable requirements are met, the verification results are documented in a verification report in accordance with the applicable CBAM and accreditation requirements.
Preparing for CBAM Verification
A reliable CBAM filing starts with reliable data. Organizations must therefore prepare well in advance of the formal verification process.
Consider, for example, drafting and evaluating:
- monitoring plans and monitoring methods;
- data flows and internal controls;
- emissions calculations and underlying source data;
- direct emissions at the facility and process levels;
- information on precursors;
- production volumes and relevant CN codes;
- the calculation of specific embedded emissions.
By identifying potential shortcomings early on, there is more time to address missing data, inconsistencies, or unclear processes.
DEKRA and CBAM verification
DEKRA has extensive experience conducting independent audits and verifications in the areas of emissions and sustainability. Our experts combine knowledge of laws and regulations with experience in industry, energy, and international value chains.
DEKRA is preparing to conduct formal CBAM verifications. DEKRA will be able to offer formal CBAM verification as soon as the required accreditation and scope of application are in place.
Would you like to know what CBAM means for your organization, what emissions data you need, or how you can prepare for verification? Please contact our expert using the contact information at the bottom of the page.
