A CBAM dataset needs to clearly identify the production installation, emissions calculation methodology and records supporting the results.
When an EU customer requests data, businesses should confirm the products, data period and intended use before completing a template. This article explains how to compile factory records, check the data and finalise them for the customer.
Correct installation · Correct data period · Auditable records
What should you clarify with the customer before completing a template?
A request for “carbon data” may support a quotation, supplier assessment or CBAM declaration. Businesses should confirm the following in writing:
- Products and production installations: Product names, CN codes, factories and relevant shipments. If goods come from several factories, identify each source clearly.
- Purpose and data approach: Does the customer need indicative figures or data for a CBAM declaration? Establish whether actual data or default values under the rules will be used.
- Data period: Year of production, year of importation and the reporting period to use; clarify how to determine the data period for goods held in stock.
- Delivery requirements: Template, recipient, initial and final submission deadlines, and data verification requirements.
For goods other than electricity, the rules allow the use of verified actual emissions data or default values. Electricity has its own methodology and conditions. Businesses should agree the approach with the EU CBAM declarant. See the EC's general CBAM guidance.
The record groups to prepare
Businesses can organise their records into the following six groups when preparing actual emissions data. The information required depends on the product, production process and applicable CBAM methodology.
Products and production installations
Factory name and address; operator and contact person; CN codes, product descriptions, production processes and reporting period. Match internal product codes with the goods imported by the customer to avoid confusion.
Information sources: Technical records, product lists, production and export teams.
Output and materials
Output from each production process within the calculation boundaries; quantities of raw materials and precursors consumed; and, where relevant, inventory, losses and scrap data. Distinguish quantities purchased, quantities actually consumed, production output and export quantities.
Information sources: Production logs, weighing records, warehouse receipts and issue records, invoices and accounting ledgers.
Energy and emissions parameters
Fuel consumption, heat and electricity data within the required monitoring scope; calculation factors and analysis or emissions measurement results under the applicable methodology. Specify the sources, reasons for selecting factors, units and conversions.
Information sources: Measuring equipment, invoices, test results and technical documentation.
Precursor data
Identify which input materials qualify as precursors under CBAM. For each supply source, compile the quantity consumed, production installation, data period and emissions information. An appropriate verification report is needed if actual precursor data are used.
Information sources: Precursor manufacturers, through the purchasing department or trading business.
Calculation methodology and results
Monitoring plan, calculation boundaries, allocation of emissions to each production process, calculation spreadsheets and emissions report. Each result should specify the product, production installation, data period and unit.
Information sources: Technical and environmental teams, working with the departments supplying data.
Adjustment and verification records
Prepare information for adjusting the number of CBAM certificates to account for EU free allocation, including technology and precursor information where needed. Any deduction claimed for a carbon price effectively paid requires evidence that meets the prescribed conditions. Include the verification report when actual emissions data are used.
Information sources: Technical and finance teams, suppliers and the verifier.
Check groups A–E against the calculation methodology guidance and EC guidance on preparing for monitoring. For group F, also see the guidance on the free allocation adjustment and verification requirements.
Organise data for easy checking and reconciliation
Businesses can start with spreadsheets and shared folders with controlled access. Each data item should have a clear source, responsible person and update date.
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Create a data register
Record each data item, unit, related evidence, responsible person and missing information. Appoint one coordinator to track compilation progress.
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Standardise data collection
Identify the equipment or records supplying each figure, when it is recorded and how it is reconciled. Collection frequency must match the applicable monitoring methodology.
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Check regularly
Reconcile production data with warehouse and accounting records. Promptly record changes in technology, materials, measuring equipment or production installations.
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Manage versions
Retain source data, calculation spreadsheets and the documentation packages sent. Record the date, changes and reviewer for every revision to prevent the wrong version from being used.
The reporting period at the production installation is the calendar year. The data period used for imported goods must follow CBAM rules on the time of production and evidence establishing it. Do not substitute an average of a few months for full-year results; use prior-year data only when the applicable conditions are met. See the EC guidance on reporting periods.
A factory purchases steel from two sources
A factory produces CBAM steel goods using materials from installations A and B. It should keep each source's information separately from the purchasing stage and update the quantities actually consumed during production:
Quantity consumed, production installation, data period and emissions records.
The same information, with missing documents and the person responsible for providing them clearly identified.
Identify which production processes consume the materials from each source and the corresponding output for emissions calculations.
Keeping source information separate helps businesses compile data using the correct methodology. Do not use the lowest-emission source's data for all materials, or assign that source exclusively to goods sold to one customer without sufficient grounds under the rules. See the EC guidance for the iron and steel sector.
What should you check before sending data to a customer?
Businesses should appoint a reviewer other than the person who compiled the data. The following questions can support the internal review:
- Correct product and factory?Do the product code and production installation in the records match the goods supplied to the customer?
- Correct data period?Do the reports, spreadsheets and supporting records match the reporting period? If there are differences, have the reasons and basis for using the data been explained?
- Correct units?Have kg and tonnes, kWh and MWh, and total emissions (tCO₂e) and emissions per tonne of product (tCO₂e/tonne) been distinguished?
- Complete input data?Have any precursors, fuels or related data been omitted or double-counted?
- Traceable supporting records?Can the aggregated results be traced back to source data, supporting records and the calculation basis?
- Clear record status?Are draft, final and verified data clearly identified?
If data are incomplete
Clearly state the missing information, responsible person and expected completion deadline. Distinguish gaps in factory data from missing precursor supplier data to choose the appropriate response.
Subject to the prescribed conditions, it is possible to combine default values for precursors with actual data for the factory's production process. Do not fill gaps with zeroes or unsupported estimates. See the EC guidance on the calculation methodology.
Internal checks do not replace independent verification. Actual emissions data used in CBAM declarations must be verified by a verifier with the appropriate CBAM accreditation scope, granted by an EU national accreditation body. The verifier must be registered in the CBAM Registry. See the EC guidance on verification.
How can you deliver data with fewer resubmissions?
Each submission should include a summary to help the recipient quickly identify the data scope, available documents and outstanding information.
Information to include in the delivery summary
- Data scope: Products, CN codes, production installation and data period.
- Document list: File names, versions, issue dates and verification status.
- Points to note: Actual data or default values, incomplete items and intended use.
- Contact information: Sender, recipient, submission date and response deadline.
Use an appropriate template. Check whether the customer's template meets the definitive-period requirements or still uses the transitional reporting structure. Consult the latest documents on the EC's CBAM guidance page.
Agree on data sharing and confidentiality. The O3CI module in the CBAM Registry helps non-EU production installations share data with declarants. Before granting access, confirm the correct recipient legal entity and its EORI number. Data sharing does not replace the declarant's obligation to submit a CBAM declaration.
Agree a delivery deadline earlier than the declaration deadline. The first CBAM declaration deadline for goods imported in 2026 is 30/09/2027. Both parties should agree an earlier delivery schedule to allow time for checking, supplementing and finalising records. See the EC's CBAM guidance.
Clearly notify revisions to data already sent. Identify the version to be replaced, the changes and the updated documents. Ask the recipient to confirm receipt of the new version and stop using the old one.
Start with one product at one factory
Choose one CBAM product currently exported to the EU, prepare a record checklist using the six groups above, and identify what is available, missing or needs checking. Then assign responsibility, set completion deadlines and agree a suitable delivery schedule with the customer.
Learn more about CBAM embedded emissions verification at GIC Vietnam.
Updated as of 9 September 2026. This article focuses on the definitive period, based on Regulation (EU) 2023/956, as amended, and the EC's relevant legislation and guidance.
