The European Commission’s 15 October 2026 update to its Carbon Border Adjustment Mechanism (CBAM) Questions and Answers clarifies how emissions data, production records and verification arrangements must support compliance under the definitive regime. The guidance addresses verified precursor emissions, the allocation of identical goods between export markets, imports of pre-2026 production and the outsourcing of technical verification activities.
For manufacturers and EU importers, the clarifications place greater emphasis on the traceability of emissions information throughout the supply chain. Calculating tonnes of carbon dioxide equivalent is not sufficient where the underlying data cannot be linked to the relevant production process and supported by appropriate verification.
Precursor emissions require a verifiable data trail
Manufacturers producing complex goods must establish a defensible verification chain when their products incorporate precursors made by other companies. For steel, aluminium and other CBAM-covered goods, downstream operators cannot rely solely on unverified supplier emissions figures when seeking to use actual emissions values.
The information must be traceable to the relevant precursor production and supported by the required verification arrangements. This makes the relationship between precursor suppliers, downstream manufacturers and independent verifiers an important part of the compliance process.
EU importers therefore need to extend supplier due diligence beyond collecting a single emissions figure. They need to establish which company produced the precursor, which installation and reporting period the data cover, whether the emissions value has been independently verified, how production volumes were allocated and whether the verifier’s accreditation scope covers the relevant process.
Production allocation must reflect physical and evidential conditions
The Commission’s guidance also addresses the allocation of emissions between goods intended for different markets. Operators cannot create a preferential low-carbon export stream merely by assigning identical output from the same production process to different accounting categories.
Where a process produces identical goods, separating one batch for the EU market and another for non-EU destinations requires a physical and evidential basis. Accounting distinctions alone cannot justify treating one group of products as lower-emissions output and the other as higher-emissions output.
This clarification affects manufacturers seeking to demonstrate different emissions intensities across export consignments. Production records and allocation methods must support the claimed distinction rather than relying exclusively on administrative categorisation.
Imports of goods manufactured before 2026
The updated Questions and Answers also clarify the treatment of inventories manufactured before the definitive CBAM regime began. Goods produced in 2025 can fall under CBAM when they are released for free circulation in the EU during 2026.
The relevant customs event determines whether the definitive regime applies. The manufacturing date and the date of the sales contract do not override the date on which the goods are released for free circulation.
This distinction is relevant to companies holding pre-2026 inventories for subsequent delivery to EU customers. Goods manufactured before the start of the definitive regime may still be subject to its requirements when the relevant customs event occurs in 2026.
Outsourcing is permitted under verifier oversight
The Commission’s clarification on verification activities establishes a controlled route for outsourcing certain technical tasks. Accredited verifiers may outsource eligible activities, including to organisations operating in third countries, but remain responsible for the verification process.
The outsourcing arrangement does not extend to the technical review or issuance of the final verification report. Those responsibilities remain with the accredited verifier.
For industrial operators and technical advisers, this defines the boundary between external support and the responsibilities that must remain with the accredited verification body. The arrangement also makes the verifier’s accreditation scope and responsibility for the final outcome central to the assurance process.
Southeast European producers face broader data-governance demands
The clarifications are relevant to Southeast Europe, where industrial installations depend on EU customers, external verification services and emissions information supplied by other companies in the production chain.
For these manufacturers, compliance requires coordination between installation-level records, precursor data, production allocation and verification documentation. The ability to calculate emissions accurately must be matched by the ability to demonstrate where the data originated, which production it represents and how it was validated.
The Commission’s 15 October 2026 guidance consequently makes supplier traceability and verification arrangements central to the use of actual emissions values. Producers and importers need records that can establish the full evidence chain behind their CBAM calculations, from precursor production and allocation through to independent verification.
