CBAM supplier emissions data: what to gather and when to start
CBAM obligations turn on the greenhouse-gas emissions embedded in imported goods, and most of that data originates with suppliers. Authorised CBAM declarants report embedded emissions in their annual CBAM declaration and surrender certificates against them (Regulation (EU) 2023/956), so gathering supplier data is worth starting early rather than close to a deadline. This guide is about organising that data collection at a practical level — it does not set out emissions methodology, and CBAM Pulse does not collect or verify supplier data on your behalf.
Last updated: 4 July 2026Sources: Regulation (EU) 2023/956Regulation (EU) 2025/2083European Commission — CBAM
Why supplier emissions data matters
CBAM prices the emissions embedded in covered goods, not the goods themselves. Because those emissions are generated during production — at the supplier — the importer usually cannot derive them without information from the supply chain (Regulation (EU) 2023/956).
That makes supplier engagement one of the more time-consuming parts of preparing for CBAM: the data has to be requested, chased, and understood, which rarely happens quickly.
Embedded emissions drive the annual declaration
In the definitive period, authorised CBAM declarants report the embedded emissions of the goods they imported over the year and surrender CBAM certificates against them. The quality of that reporting depends directly on the quality of the underlying supplier data.
The rules distinguish, at a high level, between using actual emissions data and using default values where actual data is not available. The detailed methodology sits in the CBAM legislation and the European Commission's guidance — check those sources, and verify your approach with a qualified adviser or your national competent authority rather than relying on a summary.
Start collection early
Supplier data tends to arrive slowly, in inconsistent formats, and sometimes not at all on the first request. Starting early leaves room to follow up, fill gaps, and understand what you have received before it feeds a declaration.
A generic way to organise it
Whatever tooling you use, the shape of the task is similar. These steps are organisational, not a methodology:
- Identify which suppliers provide your CBAM goods.
- Map each good to its CN code so you know what is in scope.
- Ask suppliers for embedded-emissions data and the supporting documents behind it.
- Version and date what you receive, so you can tell later which figures came from where.
- Note the open questions to raise with your adviser or national competent authority.
Where CBAM Pulse fits
CBAM Pulse helps you organise the surrounding work — confirming which goods are in scope, seeing which sectors are affected, and working through preparation steps. It does not collect, store, or verify supplier emissions data for you.