European Union importers, industrial producers and accredited verifiers have distinct responsibilities under the Carbon Border Adjustment Mechanism (CBAM), creating a cross-border compliance process in which emissions information must move between several independent organisations.
For manufacturers in the Western Balkans, preparing reliable embedded emissions calculations represents only one part of this process. The information must also be independently verified, transferred to the appropriate EU importer and incorporated into the importer’s regulatory reporting arrangements.
The division of responsibilities becomes particularly important when production data originate from several companies, including electricity suppliers, raw-material producers and industrial processors. Although these organisations contribute to the emissions evidence chain, none controls every stage of the final declaration.
Unclear contractual obligations can result in missing documentation, delayed verification or disputes over who is responsible for correcting reported information. Establishing a defined governance framework allows each participant to identify its obligations before the relevant reporting deadlines.
EU Importers Retain Responsibility for Regulatory Declarations
The EU importer or relevant indirect customs representative is responsible for fulfilling the applicable CBAM declaration obligations.
This includes managing the required authorisation, registry procedures and CBAM certificate obligations, as well as ensuring that the emissions information used in regulatory submissions corresponds to the imported goods.
Importers must establish which producing installation supplied the relevant products, whether the associated emissions information remains current and whether actual emissions values have undergone the required independent verification.
Although exporters provide the underlying industrial information, submitting an emissions spreadsheet does not transfer the importer’s regulatory responsibilities to the manufacturer.
The importer must maintain a reliable connection between the goods entering the EU and the corresponding emissions documentation. Changes in supplier information, production methods or verified emissions factors therefore need to be communicated through agreed procedures.
Industrial Producers Control the Underlying Emissions Evidence
The non-EU producing installation holds the operational information necessary to calculate the embedded emissions of manufactured goods.
This includes records of production routes, fuel consumption, electricity use, material inputs, manufacturing output and relevant operating conditions.
The industrial operator must establish monitoring arrangements capable of generating emissions calculations under the applicable CBAM methodology. Where actual values are used, the supporting information must also be available for independent verification.
Manufacturers are responsible for preserving the underlying evidence and maintaining consistency between production records and the emissions information supplied to customers.
For Western Balkan exporters, this requires coordination between production, engineering, procurement and reporting departments. The factory must be able to explain how reported emissions are derived from its operating data and demonstrate that the calculation applies to the relevant products.
Accredited Verifiers Provide Independent Assurance
The role of the accredited CBAM verifier is separate from both the industrial operator and the importing company.
The verifier examines the operator’s monitoring methodology, emissions calculations and supporting documentation before issuing an independent verification conclusion.
Its effectiveness depends on maintaining impartiality throughout the assessment process.
Industrial manufacturers may appoint engineering consultants or technical advisers to develop metering arrangements, establish monitoring procedures and prepare reporting systems. However, the independent verifier should not be placed in a position of assessing work for which it was responsible during the design and implementation stages.
This separation distinguishes technical preparation from formal regulatory verification.
An engineering adviser can improve the quality and organisation of the factory’s evidence, while the accredited verifier provides the independent assessment required for actual emissions reporting.
Upstream Suppliers Form an Additional Layer of the Evidence Chain
The responsibilities associated with CBAM can extend beyond the manufacturer exporting the finished product.
Electricity generators, utilities, material traders, steel mills and aluminium smelters may possess information required to determine the emissions associated with manufacturing inputs.
Where the exporter depends on these records, procurement agreements should establish the necessary data-access rights and delivery obligations.
A manufacturer requesting upstream emissions information only after the reporting period has ended may discover that the supplier did not retain the required level of detail.
This is particularly relevant for multi-tier industrial supply chains.
For example, a Western Balkan steel fabricator may purchase material through a trader, perform additional processing and export a CBAM-covered product to an EU customer.
The fabricator needs sufficient information about relevant precursor emissions to prepare its calculations. The importer, in turn, requires the final verified emissions result associated with the imported goods.
Maintaining material traceability and product genealogy allows information to move through the supply chain without losing its connection to the original production activities.
Supply Contracts Need Clear Data Ownership and Correction Procedures
Commercial agreements can define how emissions information moves between upstream suppliers, industrial operators, verifiers and EU importers.
Relevant provisions include data ownership, submission deadlines, confidentiality requirements, correction procedures and authorised disclosure arrangements.
Manufacturers should know which records they are required to provide to importers and which supporting information they are contractually entitled to obtain from electricity and material suppliers.
Contracts can also specify whether sensitive production information may be disclosed directly to an accredited verifier rather than distributed more broadly among commercial counterparties.
Data corrections require particular attention.
If a meter adjustment changes a previously issued operator emissions report, the manufacturer needs a controlled procedure for updating the calculation and reissuing the relevant information.
Where an EU importer has already used the earlier result, the parties must determine how the revised data will be communicated and addressed within the applicable reporting process.
A reliable evidence chain therefore needs to preserve not only the latest emissions value but also a record of changes affecting previously distributed information.
Responsibility Matrices Can Prevent Reporting Delays
Industrial companies can establish a formal division of reporting responsibilities through a Responsible, Accountable, Consulted and Informed (RACI) matrix.
The matrix should identify who prepares, reviews, approves and receives individual evidence items, rather than assigning only broad responsibilities to job titles.
The framework can also establish escalation procedures when documentation is missing or technical disagreements remain unresolved.
If an upstream supplier misses an emissions-data deadline, the procurement department can initiate escalation before the reporting period closes.
Where an accredited verifier identifies a technical deficiency, the engineering department can coordinate the response. If an importer challenges the methodology used in an emissions calculation, commercial and legal departments can participate in resolving the issue.
These arrangements reduce the likelihood that unresolved questions accumulate with one sustainability manager immediately before a regulatory deadline.
Provisional Calculations Must Remain Separate From Verified Results
A further governance requirement concerns the stage at which internal emissions information becomes an external declaration or commercial claim.
Manufacturers may calculate preliminary emissions values throughout the reporting year to support operational management and identify potential discrepancies.
However, internal estimates and provisional calculations should remain distinguishable from final actual emissions values that have undergone the agreed review and verification procedures.
A controlled information-release process can establish who authorises the distribution of emissions results to customers and which supporting documentation must accompany them.
This protects both exporters and importers from mistakenly treating preliminary information as verified regulatory evidence.
Internal management dashboards can reinforce this distinction by tracking metering records, material information, outstanding supplier requests, verification findings and customer submissions as separate categories.
An unresolved supplier request should not appear as completed verified evidence. Similarly, completion of an independent verification report does not establish that the EU importer has fulfilled its own declaration and certificate obligations.
Shared Emissions Datasets Can Serve Multiple EU Importers
Manufacturers supplying several EU customers can reduce reporting duplication by maintaining a standardised core dataset of verified installation-level emissions information.
The underlying records can remain consistent while the manufacturer provides customer-specific documentation formats or commercial information required by individual importers.
This structure limits the need to recreate the same emissions calculation separately for each buyer and reduces the risk of inconsistent figures being circulated.
However, standardising the supplier’s evidence does not transfer regulatory responsibilities between participants.
Each EU importer continues to manage its own CBAM declaration, while the industrial operator remains responsible for the accuracy, traceability and maintenance of the source information.
A centralised evidence repository, supported by defined approval and release procedures, allows exporters to provide consistent emissions documentation across multiple commercial relationships while preserving the separate legal and technical responsibilities within the CBAM reporting chain.
