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What EU Importers and Non-EU Manufacturers Need to Understand About CBAM Verification

by Gerard van der Ven | Posted:
What EU Importers and Non-EU Manufacturers Need to Understand About CBAM Verification

Key Takeaways: Forest Product Traceability in 2026

  • CBAM's definitive period began 1 January 2026. Financial liability is accruing now, not starting in 2027.
  • The first annual declaration and certificate surrender deadline is 30 September 2027, covering emissions embedded in goods imported during 2026.
  • Default values carry a markup that rises every year: 10% in 2026, 20% in 2027, 30% in 2028.
  • A single 50-tonne threshold now determines CBAM obligations, replacing the old EUR 150 consignment-value rule.
  • Verification happens at the non-EU manufacturer's site. The EU importer (ACD) holds the legal reporting obligation, but the emissions data itself originates abroad.
  • More than half of importers were still submitting default values as of Q3 2024, despite actual-value reporting becoming mandatory that summer. 

The European Union’s Carbon Border Adjustment Mechanism (CBAM) has been live since January 2026, but most EU importers still do not have verified, actual emissions values across all their facilities and CBAM commodities. With every quarter that passes under the legislation, financial liability accumulates.  

Meanwhile, default values now carry a 10-30% markup, making it increasingly costly to avoid using and reporting actual values. Third-party verification is what unlocks those lower, actual-value numbers, and the 30 September 2027 declaration is the natural point to have it in place.

To support organizations looking to make the most of this vital timeline, our CBAM verification team has crafted a high-level overview of how voluntary pre-verification and mandatory third-party verification function under CBAM in 2026. 

What changed in the definitive CBAM period? 

From 1 January 2026, CBAM became a financial compliance mechanism for covered imports into the European Union. The definitive period is built around annual declarations, CBAM certificates, and verified emissions data where actual values are used.

  • Authorization requirement: Importers, or indirect customs representatives where applicable, must hold Authorized CBAM Declarant status before importing CBAM goods above the applicable threshold. 
  • 50-tonne threshold: The Omnibus simplification (Regulation (EU) 2025/2083) replaced the former per-shipment value test with a single mass-based threshold of 50 tonnes per importer, per year.  
    • Old rule: Under the original CBAM Regulation, individual shipments of CBAM goods worth less than EUR 150 were exempt from CBAM obligations entirely, assessed consignment by consignment.
    • New rule: Importers whose cumulative net mass of covered goods stays below 50 tonnes in a calendar year are generally exempt from CBAM obligations, subject to the detailed legal conditions and anti-circumvention rules.
    • Coverage: Applies to iron and steel, aluminium, cement, and fertilizers (more on fertilizers below). Does not apply to electricity or hydrogen.
    • Why it changed: The old rule was assessed per consignment. The new one is cumulative, per importer, per year, which removes the incentive to split shipments to stay under the cap. 
  • Annual declaration: The first annual CBAM declaration and certificate surrender deadline is 30 September 2027 for embedded emissions in goods imported during 2026.
  • Actual or default values: Importers may use Commission default values or actual values. Where actual values are used, the underlying embedded emissions data must be verified by an accredited verifier.
  • CBAM certificate price: CBAM certificate prices are linked to the EU Emissions Trading System (ETS) allowance prices.

Roles and Responsibilities 

EU Importers and Non-EU Manufacturers 

Under the CBAM Regulation, the Authorized CBAM Declarant (ACD), typically the EU importer or an indirect customs representative, is legally responsible for compliance within the European Union. The ACD must obtain the necessary authorization, submit annual CBAM declarations, purchase and surrender CBAM certificates, and maintain evidence supporting the reported embedded emissions.

The embedded emissions themselves, however, originate from the non-EU manufacturing installation that produced imported goods. As a result, the non-EU operator plays a critical role in the CBAM process.  

The manufacturer is responsible for:

  • Establishing and maintaining a monitoring system
  • Collecting activity data, calculating embedded emissions
  • Allocating emissions to specific CBAM goods and eight-digit combined nomenclature (CN) codes  
  • Maintaining the records needed to demonstrate compliance with the CBAM methodology. 

Where actual emissions are reported instead of default values, the non-EU manufacturer must be able to demonstrate how the embedded emissions were determined. This includes:  

  • Maintaining a documented monitoring plan
  • Supporting records for fuel and electricity consumption, production data, precursor information
  • Allocation calculations, quality-control procedures
  • Other evidence required under the CBAM monitoring methodology

An accredited verifier operates independently from both parties. The verifier does not prepare emissions calculations or provide consultancy.  

Instead, the verifier assesses whether the embedded emissions have been calculated and allocated in accordance with the applicable CBAM requirements and whether the reported data is free from material misstatement. The outcome of this process is a verification report and verifier statement, not a certificate.

The relationship can be summarized as follows:

  • The EU importer (ACD) is responsible for CBAM compliance within the European Union.
  • The non-EU manufacturer is responsible for generating the emissions data that supports the CBAM declaration.
  • The accredited verifier independently assesses the emissions data before it is used as verified actual data.
  • The competent authorities and CBAM Registry oversee authorization, reporting, certificate management, and enforcement activities within the EU framework.

This distinction is important because CBAM verification is focused on the manufacturing installation and its embedded emissions data, even though the legal reporting obligation rests with the EU importer. 

What do default values cost your CBAM declaration? 

Default values are fixed, country-specific amounts of GHG emissions based on the type of product, set out by the European Commission under (EU) 2025/2621. Default values are also listed and provided by the EU to producers and importers.  

The cost of relying on default values in the definitive phase comes with real financial and economic consequences, ranging from 10-30% markup. This markup is incremental and takes place over time: 10% markup in 2026, 20% in 2027, and 30% in 2028.

Actual values refer to the real input and output of GHG emissions from a specific production facility. These emissions must be measured and verified using EU methodology. Actual values must also be verified by an accredited body, whether based in the EU or not, provided it holds accreditation from an EU accreditation body.

In addition, it must be part of a larger monitoring, reporting, and verification system, backed by a documented monitoring plan.

What does third-party verification involve? 

CBAM doesn't leave third-party verification optional once you choose to report actual values. An accredited verifier has to confirm that data before it counts toward your declaration. Before outlining the steps in CBAM third-party verification, we’ll distinguish the two central actors.  

The EU operator receives CBAM-covered goods at the EU border, registers with the EU, reports imported volumes and buys CBAM certificates. Verification, however, takes place outside the EU with the non-EU manufacturers that produce those goods.

Because EU jurisdiction begins when goods enter the EU, manufacturers must allocate embedded emissions (direct and indirect emissions) to specific products, categorized by the six-digit harmonized system (HS) codes.  

For example, if 10 tonnes of a steel product are exported to the EU, the manufacturer must show the emissions attributable to that HS code plus volume. Third-party verification confirms whether those allocated figures are accurate.

CBAM third-party verification encourages the use of actual emissions reporting under CBAM’s definitive phase. Third-party verification follows the same core structure across all covered goods.  

Whether the product is iron and steel, aluminium, cement, fertilisers, electricity, or hydrogen, the process generally moves through the same sequence: pre-engagement review, strategic analysis, risk assessment, remote document review, sample-based data analysis, verification of calculations, and an on-site visit.

What can deviate within this process though, is how the verification framework is applied at the activity-scope level. Each CBAM commodity sector has its own annexes within the CBAM Implementing Regulation, which define the default values, calculation factors, and process-specific emission types that must be considered. By way of a few, more concrete examples, consider how:

Steel production may involve process emissions tied to the chemistry of steelmaking.

Cement production involves combustion chemistry and clinker-specific emissions.

Aluminum smelting has its own distinct process-emission profile.  

The verification pathway remains consistent while the technical evidence required will vary by commodity and production process. Importers and manufacturers should therefore prepare for a common verification structure while paying close attention to the sector-specific requirements that apply to their goods.

Third-Party Verification: The Stepwise Process

Structure-wise, verification is divided into two phases. Roughly two-thirds remote document review and one-third on-site assessment. The remote phase is where most analytical work happens. The site visit is primarily a confirmation and cross-check exercise.  

Step 1: Pre-Contractual Review and Verification Readiness  

Before accepting the engagement, the verifier assesses whether the verification can be delivered with the required competence, impartiality, scope clarity, data availability and time allocation.  

This is the correct starting point. It confirms whether the non-EU operator has the minimum documentation, monitoring approach and data trail needed for an independent verification. If the operator is not ready, pre-verification or a readiness assessment may be more appropriate than formal verification.

Step 2: The Monitoring Plan

The monitoring plan is the single biggest practical barrier in the regulation. Without it, everything downstream is blocked. It must be developed and implemented by the operator. Commission Implementing Regulation (EU) 2025/2547 (Annex II, point A5) sets out 22 requirements in total. However, the five that matter most are:

  • Installation and processes: a description of the installation and its production processes
  • Goods produced: a list of all relevant goods produced, by CN code and functional unit
  • Precursors: the precursors used in each production process, and, if produced at another installation, the name and country of origin of the supplier
  • Monitoring methods: the methods for monitoring data for each production process
  • Emissions allocation: how embedded emissions are allocated at product level to individual product types by HS code.

Together, these components make up a complex equation that requires care to solve. For example, a manufacturer may run multiple processes in a single facility. The monitoring plan must show how it's possible to allocate a specific share of total emissions to one tonne of a particular steel product associated with a distinct process, or one tonne of aluminium with a specific HS code in another process.

To add, it must also demonstrate, at a very detailed level, that the plant's processes are aligned with the relevant CBAM regulatory requirements.

Step 3: Strategic Analysis 

Once the verifier has received all relevant documentation (see EU 2025/2551, Annex II, point 2.3), the verifier assesses the nature, scale, and complexity of the production processes, production routes, precursors, meters, source streams, data systems, and organizational interfaces.  

If the manufacturer is not ready, significant gaps may need to be addressed before the verification can proceed efficiently. The strategic analysis determines the overall verification approach and informs the risk assessment.  

Step 4: Risk Assessment  

At this stage, the verifier identifies inherent risks, control risks and detection risks that could lead to a material misstatement in the embedded-emissions data. Examples include manual spreadsheets, missing meter calibration records, incomplete precursor data, inconsistent production quantities, unclear CN code allocation, weak change control, or insufficient segregation of responsibilities.

The verifier qualifies every relevant risk element as low, medium, or high. Control activities are a core part of this picture.  

For example, emissions data managed in Excel spreadsheets is a weaker control, since spreadsheets can be easily modified, lost, or corrupted, so the verifier allocates more time to verify that data thoroughly. A robust integrated data management system, where data integrity and traceability are better controlled, is a stronger control and can be qualified as low risk, reducing the time spent on verification of that element.

Roughly two-thirds of total verification time is spent in this remote phase. Going through documents, assessing the monitoring plan, plant layout, data sets all take place before the verifier travels or sets foot on-site.

Step 5: Verification Plan

The verification plan translates the strategic analysis and risk assessment into specific verification activities. It defines interviews, document and record review, data sampling, recalculation, control testing, cross-checks, site-visit activities, and the timing and responsibilities for the verification team.

Step 6: Verification Activities and Site Visit

Most analytical work is normally performed through remote document and data review. The site visit confirms that the information and data submitted in earlier steps reflect the physical installation and actual operating practices.  

Once on-site, the verifier checks production areas, meters, source streams, storage locations, data systems, quality controls and personnel responsibilities relevant to the reported embedded emissions.

In addition to the site visit, the verifier conducts a walkthrough to confirm the documented layout and installation structure, then interviews personnel to assess whether procedures are understood and implemented in practice.

The site visit typically requires three personnel groups:

  1. Top management: the person responsible for approving and releasing emissions reports.
  2. Quality manager or equivalent: the person responsible for the Quality Assurance (QA) system, internal audits, and operational procedures.
  3. Operational specialists: personnel responsible for data management, meter calibration, maintenance, purchasing, or other areas flagged in the risk assessment.

For data issues flagged during remote review, the verifier meets with person in charge to understand how the data were collected, calculated, concluded, and reported.

Step 7: Methodology Implementation and Allocation Checks 

During this step, checks are made to verify whether the monitoring methodology described in the monitoring plan has been correctly implemented and whether the calculation follows CBAM requirements. Important checks include:  

  • Completeness of source streams and emissions sources  
  • Correct treatment of direct and indirect emissions  
  • Correct treatment of precursors  
  • Valid calculation factors
  • Correct production quantities and functional units
  • Correct allocation of embedded emissions to goods and CN / HS categories

Step 8: Misstatements, Non-Conformities and Corrective Action  

Where the verifier identifies material misstatements or non-conformities, the operator must be notified without delay and given the opportunity to correct the data or close the finding. If findings remain unresolved, the verification conclusion may need to reflect the outstanding issue.

Step 9: Independent Review and Verification Report

Before issuance, the verification file and conclusion are subject to independent review within the verifier’s organization. The final output is a CBAM verification report and verifier statement issued with a reasonable assurance conclusion where applicable. It’s not a certificate.  

The verification deliverable is the formal written output of an SCS Global Services assessment of CBAM-related emissions data. It confirms whether allocated emissions for a specific CBAM-covered product, HS code, and reporting volume have been assessed against CBAM requirements and verified with a reasonable assurance conclusion. The report is diagnostic; SCS Global Services identifies gaps but does not recommend or implement solutions.

Why are most CBAM importers still using default values?

As of Q3 2024, more than 50% of importers were still using default values, despite the expectation to report actual values beginning in August 2024. With 2026 data due for declaration in 2027, the choice between verified and default values now carries real financial weight.

Within this definitive phase of CBAM, manufacturers face a clear choice. Either provide verified actual emissions data or rely on CBAM default values, which come with a hefty markup ranging from 10-30%.  

Defaults are set conservatively, higher than a facility's real emissions, so verified data almost always comes back lower. Lower numbers mean the EU operator needs fewer CBAM certificates to cover the same import volume, and fewer certificates mean lower cost. 

There's a real opportunity here that's easy to miss. Manufacturers don't have to wait for 2027 to start. Reviewing documentation and testing your data collection process can begin as early as Q4 2026.

This matters because of how free allocation works. Right now, part of every importer's volume doesn't need a CBAM certificate at all, which softens the cost of staying on defaults. But that free portion shrinks every year. And this is where pre-verification comes into play.

What is CBAM pre-verification?

Pre-verification is a readiness assessment or gap assessment that helps identify whether the operator’s monitoring plan, data trail, controls and allocation methodology appear ready for formal verification. It is diagnostic and not consultancy that designs, implements or manages the operator’s CBAM system where this would compromise impartiality.

For non-EU operators  

The primary beneficiary of CBAM pre-verification is the non-EU installation operator that wants to provide verified actual emissions data to EU customers. A readiness assessment can test whether the operator can demonstrate installation boundaries, production processes, source streams, precursor treatment, electricity use, calculation methods, production quantities, product allocation, and internal controls.  

For EU operators, the CBAM pre-verification engagement has three stages.

Stage 1: Supply chain mapping

This is always the first step wherein SCS Global Services teams ask: “Do you fully understand your supply chain, and if so, how can you backup your understanding with verifiable information?”  Given that many EU declarants buy through traders without visibility of the actual manufacturer, this is often where the most fundamental gaps emerge.  

Until the operator can identify which manufacturers are responsible for their CBAM-covered goods, no subsequent preparation is meaningful.  

Stage 2: Registration and compliance check  

The operator must be registered as an Authorized CBAM Declarant (ACD) and must be submitting quarterly reports. Because CBAM’s definitive stage is active now, obligations for operators are ongoing, and non-compliance risk is real. 

Additional costs may be exacted, and, perhaps most frustratingly, goods can be stopped at the harbor without the proper documentation.  

Stage 3: Systems readiness  

Can the operator identify suppliers, manage CBAM data internally, and report quarterly to the EU? Our teams identify gaps in data and methodology against regulation requirements, walking through an existing pre-verification checklist for operators, which is a structured document covering every aspect of operational readiness.  

Everything needed to identify suppliers, make internal systems ready for CBAM, and report quarterly is assessed. We offer an internal pre-verification checklist for operators that covers all stages. The service is structured around working through this checklist systematically.

For context, SCS Global Services is one of the first organization in Europe to have its CBAM accreditation application accepted by RvA (Raad voor Accreditatie, the Dutch national accreditation body) with full accreditation committed by end of 2026. Find out where your CBAM data stands before the 2027 deadline. Contact us to discuss a pre-verification assessment.

For EU importers and ACDs  

EU importers may need supply-chain mapping and CBAM preparedness support, but they do not themselves undergo verification of an installation’s embedded emissions unless they are also the operator of the producing installation. For ACDs, the focus is normally on supplier identification, data collection from non-EU operators, registry reporting, certificate management and evidence retention.

How is CBAM scope expanding through 2028?

180 additional downstream steel and aluminium products are entering CBAM scope by 2028. For those companies not yet subject to CBAM, the choice to consider verification readiness now is economic, not regulatory.  

In other words, there is no mechanism to require currently out-of-scope companies to have verified actual figures. Under the current rules, operators may continue using default values where permitted, provided they accept the associated costs (see the section above entitled “The Cost of Default Values”).  

By staying on defaults, the EU importer ends up buying more CBAM certificates than they would with verified actual values.  

That gap gets more expensive every year, as free allocation phases out between now and 2034. Whether or not to switch to verified actual emissions is a decision best made jointly, between the EU importer and the non-EU manufacturer supplying the goods."

And while there is no mandatory timeline, companies that delay making this decision face a steeper ramp-up later. For those entering scope in 2028, pre-verification offers a practical path. identify gaps now, address them across 2026 and 2027, and enter the first mandatory verification cycle prepared. Waiting until formal verification begins could leave only weeks to resolve avoidable issues.

Although the CBAM Implementing Regulation is updated annually, the embedded emissions calculation framework is expected to remain stable because it underpins CBAM pricing, declarations, and supply chain calculations.  

Future updates are more likely to affect verification procedures, accreditation audits, site visits, and sample-size requirements. Manufacturers should monitor these changes, but the calculation approach they build now is expected to carry forward.

Need help with CBAM pre-verification or third-party verification?

SCS Global Services runs a full gap analysis against CBAM's data and methodology requirements, then walks you through what the regulation expects from your organization, no matter where you're based. As one of the first bodies in Europe to have its CBAM accreditation application accepted by RVA, we're ready to help you navigate what CBAM requires.

Whether you're deciding between default values and verification, or you're not sure where your data even stands, the smart move is finding out now, while the timeline is still yours to control. Contact our team to scope a pre-verification assessment.

Frequently Asked Questions (FAQs) 

1) What is CBAM verification, and is it mandatory? 

CBAM verification is an independent third-party assessment of a non-EU manufacturer's product-level emissions data. It's not mandatory in the sense that every importer has to get it. What's mandatory is the annual declaration and certificate surrender, whether the underlying data is verified or based on default values.  

Verification only becomes necessary if you want to report actual emissions instead of defaults. Without it, the data can't be used to support the CBAM declaration, and you fall back to defaults and the markup that comes with them. 

2) What does CBAM third-party verification actually check?  

CBAM third-party verification is a structured review of whether a non-EU manufacturer can support its reported product-level emissions with reliable data, documented procedures, and a compliant allocation methodology.

The process includes:

  1. Pre-contractual verification
  2. Monitoring plan and documentation review
  3. Strategic analysis
  4. Risk assessment
  5. Verification plan
  6. Verification activities and site visit
  7. methodology implementation and allocation checks
  8. Misstatements, non-conformities, and corrective action, and
  9. Independent review and verification report. 

3) When is the first CBAM certificate surrender deadline?  

EU importers of CBAM-covered goods must become authorised CBAM declarants; report embedded emissions and meet associated financial obligations. The first CBAM declaration and corresponding certificate surrender are due by 30 September 2027.

4) What is the 50-tonne CBAM threshold, and who does it apply to?  

EU importers, or their indirect customs representatives, must apply for authorised CBAM declarant (ACD) status if they import more than 50 tonnes of CBAM-covered goods into the EU.

Once authorised, importers will need to:

buy CBAM certificates from the national authorities in their country of establishment;

declare the embedded emissions associated with their imported goods each year;

surrender the corresponding number of CBAM certificates annually; and

deduct any eligible carbon price already paid during production, if they can provide proof.

Certificate prices are tied to the EU Emissions Trading System (ETS) allowance auction prices, expressed in euros per tonne of CO2 emitted. In 2026, prices are calculated as a quarterly average; from 2027 onward, they are calculated as a weekly average.

5) What is the cost for using CBAM default values in 2026?  

Default values now carry a 10-30% markup, making it increasingly costly to avoid actual reporting. This markup is incremental and takes place over time: 10% markup in 2026, 20% in 2027, and 30% in 2028.  

6) What is the fee for not submitting enough CBAM certificates?

In the definitive period, which began in January 2026, the cost per tonne of CO2e is €100 Euros, plus importers must pay for any underreported values of CO2. This fee applies specifically to the failure to surrender enough certificates, which is a compliance failure.  

7) What are default values for fertilizers under CBAM? 

Due to fertilizer’s vital importance within the global food system, the European Commission decided to cap its default value so as to protect food security and curb excessive agricultural price inflation. To this end, fertilizers are treated differently under CBAM and carry a much lower default value markup of 1%.  

8) What is an Authorized CBAM Declarant (ACD), and how do I apply?  

An Authorised CBAM Declarant (ACD) is the importer or indirect customs representative authorised to import CBAM-covered goods into the EU. The ACD is responsible for declaring embedded emissions, purchasing and surrendering CBAM certificates, and retaining evidence to support the declaration.

EU importers or their indirect customs representatives must apply for ACD status if they import more than 50 tonnes of CBAM-covered goods per year. Applications are submitted through the CBAM Registry's Authorisation Management Module and reviewed by the national competent authority where the applicant is established.

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Gerard van der Ven
Author

Gerard van der Ven

Project Manager, Program Development Europe