CBAM supplier emissions data: from source records to verification

Separate the data route before collecting records

Regulation (EU) 2023/956 separates official default values from actual emissions calculated from primary production-process data. A preparation record should name the route used for each figure instead of treating every supplier number as an actual value.

Where an annual declaration is based on actual emissions, Article 8 requires the declared actual emissions to be verified by a verifier accredited under Article 18. A supplier-reported figure is therefore useful input, but it is not a verified actual value merely because it came from the producer.

Tie the figure to the producing installation

Commission Implementing Regulation (EU) 2025/2547 organises actual-emissions calculation around the operator, installation, goods, production process, reporting period, monitoring plan, emissions report, calculation method, and source data. Keep those identifiers and records linked so a later reviewer is looking at one coherent reporting basis.

The operator prepares the monitoring and calculation information. The EU-side declarant uses the resulting emissions information for its declaration. Those roles should stay visible rather than being collapsed into a generic supplier-data status.

Request records, not only a number

Ask for the installation and operator identity, the relevant goods and production process, the reporting period, the method used, the emissions-report version, and references to the underlying source records. Keep the supplier's response date and any later revision rather than overwriting the first response.

Record the status precisely: requested, supplier-reported, based on an official default, calculated as actual emissions, or accompanied by an accredited verification report. Those labels describe evidence state; they do not decide whether a declaration may rely on the figure.

Verification is a separate independent step

Commission Implementing Regulation (EU) 2025/2546 requires a risk-based engagement performed to a reasonable-assurance standard. The accredited verifier reviews the monitoring approach, emissions calculations, controls, and supporting evidence, then issues a verification report with a satisfactory or unsatisfactory opinion.

Accreditation is granted by an EU national accreditation body under Delegated Regulation (EU) 2025/2551. An importer, supplier, adviser, or software provider does not grant that status and cannot substitute its own review for the verifier's opinion.

Where CBAM Pulse fits

CBAM Pulse can help structure supplier requests, evidence references, statuses, and open questions. That is preparation, not verification: it does not calculate or approve an operator's emissions report, accredit a verifier, issue a verification report, decide completeness, or provide an adviser conclusion.