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Key Takeaways
For manufacturers outside the EU, CBAM became considerably more concrete in 2026. European customers are no longer simply asking suppliers for emissions information for transitional reports. If an importer wants to use actual emissions rather than the European Commission’s default values in its definitive CBAM declaration, those actual emissions need to be independently verified. That puts a new responsibility on the installation producing the goods: the emissions number has to be calculated according to the CBAM methodology, supported by appropriate evidence and capable of surviving an independent verification process.
The timing matters. The first CBAM verifiers are expected to receive accreditation around September 2026, verification work can begin with documentation reviews and site visits, and the first verification reports can be issued through the CBAM Registry from January 2027. The first annual CBAM declaration for 2026 imports is then finalised in September 2027. For a non-EU manufacturer, this means the relevant question is no longer whether verification will eventually be required. If European customers intend to use your actual emissions for their 2026 imports, the data being verified is already being generated today.
Verification is relevant when actual emissions are being used. Under the definitive regime, CBAM declarations can be based either on actual verified emissions data or on applicable default emissions values. If the importer relies on default values, there is no installation-level actual-emissions dataset to verify. If actual emissions are used, an independent verifier accredited by an EU national accreditation body must verify them.
This distinction is important because not every non-EU manufacturer exporting a CBAM-covered product to Europe automatically needs to commission verification. The commercial question comes first: are your European customers going to use your actual emissions, and is there a reason for them to do so? A producer whose actual carbon intensity is significantly below the applicable default may have a strong incentive to provide verified actual data. A producer whose customers are comfortable using defaults may have less immediate reason to take on the additional work.
Manufacturers should therefore speak with their European customers before treating verification as an isolated compliance project. Understanding which customers want actual values, which products are affected, which installations manufacture them and what reporting periods are relevant will determine the scope of the exercise.
One of the easiest mistakes is to think about CBAM verification as verification of an individual product carbon footprint. The Commission’s framework is organised around the installation where the CBAM goods are produced. The installation operator monitors and calculates embedded emissions according to CBAM methodology, and the accredited verifier reviews the monitoring approach, calculations and supporting evidence. The Commission describes the process as producing one verification report per installation.
This matters for manufacturers with several factories. If the same product is produced at two different installations, the underlying production routes, energy sources, emissions and verification evidence may differ. Conversely, one installation may produce several CBAM goods using shared processes or precursor materials. The company therefore needs a data structure that reflects how production actually happens rather than treating every customer-product combination as an independent carbon calculation.
The installation boundary becomes the foundation for much of the work that follows. Before preparing spreadsheets for a verifier, a manufacturer should be clear about which processes sit within the installation, which CBAM goods are produced there, which production routes apply and how emissions are attributed between the relevant production processes and goods.
A common instinct with audits is to begin by asking what documents the auditor will want. For CBAM, it is more useful to begin one step earlier and make sure the monitoring methodology itself is defensible. The verifier is not simply checking whether a collection of documents exists. The verifier is assessing whether the operator has monitored and calculated embedded emissions in accordance with the applicable CBAM methodology.
The Commission published general calculation guidance and six sector-specific guides in August 2026 covering cement, hydrogen, fertilisers, iron and steel, aluminium and electricity. A manufacturer should therefore identify the guidance applicable to its production route and map the methodology to the information available at the installation. That includes understanding which production processes are relevant, how direct and applicable indirect emissions are calculated, how production quantities are established and how precursor emissions are incorporated where required.
This exercise often exposes data gaps early. A calculation may depend on fuel consumption that is currently measured for an entire site rather than a specific production process. Production data may exist in one system while energy data sits somewhere else. A precursor may come with insufficient emissions information from an upstream supplier. Discovering those gaps while designing the monitoring approach gives the manufacturer time to address them. Discovering them when the verifier arrives is considerably less convenient.
The exact evidence depends on the sector and production process, but the verifier needs enough information to assess whether the embedded-emissions calculation is materially correct. The Commission’s verification framework includes the installation’s monitoring plan, the production processes and routes carried out at the installation, the methods used to calculate attributed direct and indirect emissions and the evidence supporting the underlying data.
In practical terms, that can mean production records, fuel and electricity information, meter readings, invoices, laboratory results, emission factors, calculation files, information about precursor materials and records explaining how data has been allocated between different products or production processes. The verifier also needs to understand the controls around this information. If a value was manually adjusted, for example, there should be a defensible explanation of why it changed and who approved the change.
The important principle is traceability. A final embedded-emissions figure should not appear at the bottom of a spreadsheet with no obvious route back to its source. Someone reviewing the calculation should be able to move backwards from the reported result to the production quantities, emissions sources, factors, precursor information and supporting evidence that created it.
Manufacturing data is rarely organised perfectly around regulatory boundaries. A meter may serve several production lines. One boiler may provide steam to multiple processes. Electricity may be measured at site level while CBAM calculations require information to be attributed to particular production processes. Some facilities will therefore need allocation methodologies rather than direct measurement for every individual input.
That does not automatically make the data unusable. What matters is whether the allocation method is permitted under the applicable methodology, consistently applied and supported by evidence. A reasonable calculation based on a documented methodology is very different from an unexplained number created because no better information was available.
This is an area where preparing early is particularly useful. If the current metering structure makes an important calculation difficult to defend, the manufacturer can decide whether better metering is necessary or whether an acceptable allocation approach can be established. Verification should test the monitoring system, but it can also expose where operational data systems were never designed to answer a carbon-accounting question in the first place.
For some CBAM goods, the embedded-emissions calculation does not stop at the factory gate. Relevant precursor materials used in producing the good can contribute to the embedded emissions of the final product. That means a manufacturer preparing its own CBAM calculation may find itself in the same position as its European customer: asking suppliers further upstream for emissions information.
This can become one of the more difficult parts of the exercise because the manufacturer has less control over upstream data. Suppliers may not understand CBAM, may provide information calculated under a different carbon methodology, or may not have installation-level data available. The manufacturer therefore needs to identify relevant precursors early enough to understand which information must be obtained and what alternatives are available where actual information cannot be sourced.
The practical lesson is that verification readiness should not be assessed only inside the factory. If a significant part of the calculation depends on information from precursor suppliers, supplier-data readiness becomes part of the manufacturer’s own verification readiness.
CBAM verification is not intended to be a simple document-certification exercise. The accredited verifier reviews the operator’s monitoring approach, emissions calculations and supporting evidence and provides reasonable assurance that the calculation of embedded emissions is correct. Verification reports may subsequently be reviewed by the European Commission and national competent authorities.
The verification framework can include documentation review and site visits. The Commission’s 2026 timeline anticipates the start of first verification activities, including documentation review and site visits, from September 2026. The prescribed verification-report structure also requires information about site visits and, where applicable, explanations for virtual visits or for waiving a physical visit.
For manufacturers familiar with environmental, quality or sustainability audits, much of the discipline will feel recognisable. The verifier needs to understand the process, test the information behind the reported values and identify whether material errors or methodological problems exist. The difference is that the object being verified is a very specific regulatory calculation of embedded emissions rather than a generic corporate sustainability claim.
A normal carbon consultant or assurance provider cannot automatically issue a valid CBAM verification report. Verifiers need specific CBAM accreditation from a national accreditation body in an EU Member State, or an EEA country once the CBAM framework is incorporated into the EEA Agreement. Companies established outside the EU can apply for accreditation with an EU national accreditation body that offers the relevant service.
The accreditation process assesses technical competence in the relevant industrial sectors as well as independence, impartiality and the verifier’s ability to apply consistent verification approaches. The first CBAM verifiers are expected to receive accreditation around September 2026, and accredited verifiers must register in the CBAM Registry before carrying out the relevant Registry functions.
For manufacturers selecting a verifier, accreditation therefore needs to be checked rather than assumed. Sector competence matters as well. A verifier assessing an integrated steel installation needs to understand a different production environment from one assessing fertiliser or aluminium production, and the accreditation framework reflects the importance of appropriate technical competence.
Non-EU manufacturers do not necessarily need to send the same verified emissions package separately to every European customer. The Commission’s Operators of Third-Country Installations, or O3CI, module allows operators outside the EU to register their installations and share installation and emissions data with reporting declarants through the CBAM Registry. The system is specifically intended to streamline information sharing while providing confidential treatment for business-sensitive information.
The Registry also connects the verification process. Accredited verifiers can access the O3CI environment, connect with non-EU installation operators, review emissions data and supporting documentation and issue the corresponding verification report. Declarants can then retrieve the actual verified emissions information for use in their CBAM declarations.
This is particularly useful for manufacturers supplying the same installation’s products to several European customers. Rather than allowing CBAM to become a collection of separate customer spreadsheets, the manufacturer can maintain the installation-level information once and control how verified information is shared. The Commission’s framework therefore gives manufacturers a reason to organise CBAM data around the installation rather than around each individual customer request.
CBAM calculations can require information that manufacturers quite reasonably consider commercially sensitive. Production volumes, energy consumption, process information, precursor inputs and other operating data can reveal far more about a factory than a customer would normally see. This concern becomes more significant when a manufacturer supplies multiple customers, some of whom may also be commercially close to competitors.
The O3CI framework is partly intended to address this problem by allowing operators to provide installation and emissions information through the Registry rather than repeatedly transmitting sensitive underlying information to individual declarants. The Commission states that the O3CI module supports confidential treatment of business-sensitive data while allowing declarants to use the relevant emissions information for reporting.
Manufacturers should nevertheless decide internally who can access the underlying calculation data, what information is shared with customers, what is shared with the verifier and what belongs in the official Registry. A good verification process should create confidence in the emissions result without turning every European customer into an auditor of the manufacturer’s production economics.
CBAM preparation does not end once a verification report has been issued. Commission guidance for non-EU operators states that operators sharing emissions data should retain the verification report and records used to calculate embedded emissions for four years after verification.
That makes document management part of the compliance architecture rather than an administrative afterthought. Production records, calculation versions and supporting evidence need to remain connected to the reporting period they support. If a calculation is subsequently changed, the company should be able to distinguish the revised version from the information that was originally verified.
This is also where spreadsheets begin to become uncomfortable for larger organisations. A spreadsheet can calculate emissions perfectly well. Maintaining several years of installation data, evidence, methodological changes, verification status and customer sharing across many products and facilities is a different problem.
Before engaging a verifier, a non-EU manufacturer should be able to answer a relatively small set of questions with confidence:
The objective is not to have a perfect answer to every question before contacting a verifier. In many cases, early discussions with the verifier will help identify weaknesses in the monitoring approach. The checklist is useful because it distinguishes genuine methodological gaps from the much less interesting problem of documents simply being scattered across different people and systems.
There is a risk that companies respond to CBAM verification by creating another large manual compliance process. Every production site creates its own workbook, sustainability teams chase operations for monthly numbers, evidence is downloaded into folders, somebody consolidates everything at year-end and another employee spends several weeks preparing an audit package.
Some human judgment is unavoidable. Someone needs to understand the production process, determine the appropriate monitoring approach, investigate anomalies and work with the verifier when methodological questions arise. Those are sensible uses of specialist time. Copying meter readings between files, renaming evidence documents and repeatedly asking the same supplier for information are not.
A better operating model is to maintain the data and evidence continuously enough that verification becomes a review of an existing system rather than an annual reconstruction exercise. Production data should flow from its original source where practical, calculation logic should be consistent, supporting evidence should remain attached to the relevant inputs and unusual values should be investigated when they occur rather than six months later.
The aim is not to automate verification itself. Independent verification is deliberately a human and institutional control. The opportunity for software is to make the information being verified substantially easier to produce, trace and defend.
It is easy to view all of this as another cost imposed on exporters by European regulation, and in many cases that is exactly what part of it is. Monitoring systems, verification fees, employee time and data infrastructure all have real costs. A manufacturer should therefore have a reason for choosing actual verified emissions rather than assuming that more sophisticated reporting is inherently desirable.
The reason becomes clearer for producers whose actual emissions are lower than the applicable default. Verified data allows the European importer to use the producer’s real emissions performance in its CBAM calculation. As the financial obligation under CBAM increases, the difference between a high-carbon and low-carbon production route can increasingly affect the economics of sourcing.
For those manufacturers, verification is not only proof that a regulatory calculation was performed correctly. It is the mechanism that allows a lower-carbon production process to become credible information in a commercial transaction. That does not make verification free, but it does change the question from “How do we comply with another European requirement?” to “Is our carbon performance valuable enough that we should be able to prove it?”
For a growing number of non-EU manufacturers, that is likely to be the more useful question.
