To meet CBAM requirements, businesses need to clarify who is responsible, who provides the data and when each task must be completed.
The EU declarant needs data to submit declarations and meet financial obligations. Vietnamese businesses need to collect and check data from the correct production installation, agree delivery deadlines and allocate responsibility for the associated costs.
Both parties need to agree clearly on tasks, records and deadlines. These should be documented in a contract or written agreement to provide a basis for implementation and resolving any issues.
Who is responsible for CBAM compliance in the EU?
For imports subject to CBAM obligations, the authorised CBAM declarant is responsible for submitting declarations and purchasing and surrendering CBAM certificates. This may be an importer or an indirect customs representative that meets the prescribed conditions.
Importers established in the EU: Act as the authorised declarant themselves, or use an indirect customs representative that agrees to take on this role.
Importers not established in the EU: Must use an indirect customs representative to meet CBAM obligations as required. Vietnamese businesses should check this situation if they act as the importer in their own name.
Hiring a service provider to prepare or submit declarations does not transfer compliance responsibility. Responsibility remains with the authorised declarant. Businesses should confirm which entity holds this role, rather than merely identifying the customs service provider. See the EC guidance on declarants and customs representatives.
A Vietnamese manufacturer or exporter does not automatically become a CBAM declarant by selling goods to the EU. Businesses need to agree with their EU customers on emissions data, supporting records and delivery deadlines to support CBAM declarations by the responsible party in the EU.
Check scope and exemptions before allocating tasks.
CBAM obligations depend on commodity codes, origin, import procedures and exemption conditions.
For iron and steel, aluminium, cement and fertilisers, importers are exempt under the mass threshold if the total net mass of goods counted towards the threshold does not exceed 50 tonnes in a calendar year. The mass is aggregated across all four groups, shipments and suppliers for each importer. The threshold does not apply to electricity or hydrogen.
See the guidance from Ireland's CBAM authority and guide to checking CBAM scope using CN codes.
How should the parties allocate tasks?
For transactions covered by CBAM, both parties should appoint contacts and agree on tasks, records to be delivered and completion deadlines. The allocation below can serve as a reference.
| Task | EU declarant | Vietnamese business |
|---|---|---|
| Identify the goods | Check CN codes, import conditions and exemptions; identify the party responsible for the declaration. | Provide product lists, technical records, origin information and production installation details. |
| Agree on data requirements | Clarify whether actual data or default values will be used under the rules; confirm the data requirements. | Review available and missing data; agree templates, the data period and delivery deadlines. |
| Prepare records | Match imported goods with the corresponding production installation and dataset. | Organise or coordinate with the factory to monitor and calculate emissions, retain evidence and arrange verification when actual data are used. |
| Declarations and certificates | Submit CBAM declarations, purchase and surrender certificates, manage the account and meet deadlines. | Deliver data and assist with explanations; provide evidence of the carbon price effectively paid if a deduction is claimed. |
| Update and retain records | Assess the impact of changes or discrepancies; amend declaration records as required. | Notify changes, correct data and retain versions together with evidence of delivery. |
The table provides a suggested approach to coordination; both parties should adapt it to their actual roles and transaction conditions. Declarations, certificates and deductions are governed by CBAM rules; see the EC guidance on the definitive period.
In Vietnam, distinguish the roles of manufacturers and trading businesses
Manufacturer
Assign technical, production and environmental teams to collect, calculate and check the factory's emissions data. Coordinate with accounting and purchasing teams to reconcile fuel, raw material and electricity data with supporting records. Appoint one contact to consolidate and review data before supplying it to customers.
Trading and exporting businesses
Pass customer requirements to the correct factory, track progress and ensure data relate to the installation that actually produced the goods. If goods are purchased from several factories, manage each installation's data separately; do not use one factory's data for goods made by another.
Verifier:
Independently assess the calculation methodology, emissions results and supporting records, then issue a verification report.
When actual emissions data are used for CBAM declarations, select a verifier accredited by an EU national accreditation body with an appropriate CBAM scope, and check its registration in the CBAM Registry. See the EC guidance on CBAM verification.
When should the parties coordinate to meet the first CBAM declaration deadline?
Agree a data delivery deadline earlier than the EU declaration deadline. The declarant needs time to check records, resolve discrepancies and obtain enough CBAM certificates.
Covered imports become subject to CBAM obligations in the definitive period. Businesses need to collect data and retain records for the 2026 compliance year.
Declarants can begin purchasing CBAM certificates, including certificates for obligations relating to goods imported in 2026.
By this date, the declarant must submit the CBAM declaration and surrender the required certificates for goods imported in 2026.
From 2027, declarants must also meet the requirement to hold a minimum number of certificates in their account at the end of each quarter. See the EC's CBAM Questions and Answers.
Plan the work around the agreed delivery deadline
- Before committing to supply data
Confirm the products, production installation, data period, recipient and verification requirements. If records are incomplete, clarify what is missing and when it will be supplied.
- During production and delivery
Collect data regularly and record changes in materials, technology or production installations. Work with customers to reconcile delivered goods with the information needed for declarations.
- Before the delivery deadline
Finalise the dataset and arrange verification when actual data are used; allow enough time to supplement and correct records. When delivering data, specify the version, data period and corresponding products.
Do not automatically use the previous year's data for the following year's imports. Both parties need to confirm the appropriate data period for the goods and the applicable CBAM methodology.
What should be agreed with customers?
Businesses should document CBAM coordination requirements in a contract annex or written agreement, focusing on:
Data scope
Identify the products, production installation, data period, units and emissions calculation methodology. Clarify whether the customer needs estimates for quotations or data that meet CBAM declaration requirements.
Deadlines and contacts
Agree the first submission date, completion deadline, response times and the person who will confirm the records. Allow enough time to fill data gaps and correct discrepancies.
Verification and costs
Identify who selects, contracts and pays the verifier, and who prepares records and coordinates at the factory. Separate data preparation costs, verification costs and CBAM certificate purchase costs.
Confidentiality and data sharing
Specify who may receive, use and share information; how sensitive data will be transferred; access rights; and record retention periods.
Changes and issue resolution
Agree how to notify changes in production installations, materials or emissions calculation results; how to correct records; and who pays any additional costs. Any indemnity clause should specify when it applies, its basis and how amounts are calculated.
Cost-sharing agreements need a clear basis. When a customer proposes a purchase price adjustment due to CBAM, businesses should clarify the quantity of goods, emissions data used, certificate prices and relevant adjustments before agreeing the costs to be shared.
O3CI can be used to share data. This is the module for non-EU production installations in the CBAM Registry, which supports uploading and sharing installation information and emissions data with declarants. Confirm the correct recipient entity, EORI number and access rights. Sharing through O3CI does not replace the declarant's obligation to submit a CBAM declaration.
What should you do if data are incomplete or contain discrepancies?
The customer requests actual data, but factory records are incomplete
Clearly identify the missing data, whether they can be provided and the expected completion date. Both parties need to agree how to complete the records, verify actual data or use default values under the rules for goods other than electricity.
The declarant should confirm the approach to using the data. Do not present estimates as verified results. Electricity has its own methodology and conditions; see Articles 7–8 of the amended CBAM Regulation.
Goods are purchased through a trading business or from several factories
Identify the correct production installation and ensure records correspond to the goods supplied. Where data are sensitive, the parties may agree that the factory sends them directly to the declarant or verifier. The trading business needs confirmation of the record scope and delivery schedule.
Discrepancies are found after data have been sent
Notify the recipient immediately, specifying the affected dataset, products, data period and corrections needed. The declarant assesses the impact and amends CBAM records as required. If the discrepancy concerns verified data, the factory needs to work with the verifier to resolve it.
An immediate action: Choose one EU customer and one product group, and prepare a task allocation table showing the work, responsible person, records to deliver and deadlines. Use this to identify what needs to be completed before committing to the customer.
Clear responsibilities, effective coordination
CBAM implementation requires coordination between the EU declarant, manufacturer and exporter. Agreeing tasks, contacts and deadlines early helps the parties prepare complete records, allocate resources and clarify who pays the associated costs.
Learn about the independent data verification process on the GIC Vietnam CBAM Embedded Emissions Verification page.
Updated as of 8 September 2026. This article focuses on CBAM's definitive period, based on Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083, together with the relevant legislation and guidance.
