The EU Carbon Border Adjustment Mechanism (CBAM) places responsibility for submitting a correct declaration on the authorised declarant, even though much of the emissions evidence originates at manufacturing facilities outside the importer’s control. This division requires importers to establish reliable links between purchased goods, their producing installations and the verified emissions information used in compliance reporting.
Supplier selection therefore involves more than comparing purchase prices. Importers need to establish where goods were manufactured, obtain emissions data suitable for CBAM reporting and reconcile those figures with customs records. Verification can strengthen the reliability of factory emissions information, but importers remain responsible for using the appropriate data in their declarations.
The authorised declarant may be the importer or an indirect customs representative that has accepted the role under the applicable arrangements. The appointment of a customs broker to process entries does not automatically mean that the broker has assumed CBAM responsibilities. Import contracts, representation agreements and internal procedures should identify the responsible legal entity before shipments arrive.
Declarant Responsibilities and Exemption Checks
Importers must also determine whether their goods fall within CBAM’s scope and whether an exemption applies. The annual mass threshold of 50 tonnes applies to the relevant goods, while electricity and hydrogen are excluded from that threshold exemption.
For declarations based on actual emissions, the regulatory framework requires verification by an appropriately accredited CBAM verifier. The first annual declaration covering 2026 imports is due on 30 September 2027, separating the period in which production data are generated from the following year’s annual compliance process.
The later submission deadline does not remove the need for complete factory records. Missing measurements or inadequate supplier documentation may remain difficult to reconstruct after the relevant production period has ended.
Importer Controls Must Connect Customs and Emissions Records
A coordinated control system can bring procurement, customs, sustainability and finance functions into the same reporting process. Procurement teams establish emissions-data obligations with suppliers, while customs personnel maintain imported quantities and product classifications.
The carbon or sustainability team checks whether the emissions information corresponds to the correct producing installation and reporting period. Finance assesses the resulting certificate exposure and the funding needed to meet the associated obligations.
A common register of suppliers and production installations can connect these responsibilities. It also provides a reference for checking whether the emissions documentation received corresponds to the goods recorded in customs and purchasing systems.
Distributors create an additional traceability challenge because the contractual seller may not operate the factory that produced the goods. If a distributor changes its manufacturing source during the year, the importer needs to establish which installation supplied each delivery and whether the associated emissions information remains applicable.
A corporate sustainability report alone cannot establish that connection. Importers need records that link the relevant goods to the producing installation and the emissions information applicable to the specific reporting period.
Verification Reports Need Product and Installation-Level Checks
Importers should examine the scope of each verification report before using it in a declaration. The producing installation, goods, reporting period and verification conclusion must correspond to the information supporting the reported imports.
Where a report is corrected or replaced, the importer should track the revision and prevent obsolete versions from remaining in active calculation spreadsheets. Earlier versions should nevertheless remain accessible through a controlled record history.
These procedures are recommended management controls rather than a requirement for every importer to repeat the factory’s audit independently. The importer’s task is to use the verified information correctly and maintain a defensible link between that information and the imported goods.
EU authorities can review submitted declarations and the associated verification information. Importers therefore need to retain sufficient documentation to explain how the figures used in their declarations relate to their purchases and customs records.
Supplier Documentation Becomes a Commercial Consideration
For exporters in Southeast Europe, clearly identifying producing installations, agreeing data-delivery schedules and assigning responsibility for corrections can make transactions easier for EU customers to manage.
These arrangements do not necessarily require changes to production technology. They depend on reliable information flows between the manufacturer, any distributor and the importing customer, supported by procedures that establish which emissions records apply to each delivery.
The first annual declaration covering 2026 imports will require importers to connect factory-level evidence with the goods entered into the EU market. A verified factory report remains useful only when the importer can demonstrate that it corresponds to the products and installations covered by its declaration.
