Steel producers supplying the European Union are being urged to establish their CBAM monitoring plans and emissions records ahead of the definitive reporting cycle, with verification expected to require evidence extending beyond a completed emissions spreadsheet.
Jerónimo Casas, an SGS specialist, presented the requirements at the SteelOrbis and IREPAS meeting in Belgrade from 27–29 September. He said monitoring documentation needs to cover the relevant installation, production processes, covered goods, system boundaries and the methods used to determine reported emissions.
The preparation also extends to purchased inputs. Producers relying on emissions information from upstream suppliers need to establish what data those suppliers can provide, when it will become available and whether it covers the relevant reporting period.
Monitoring systems need traceable production data
For exporters, the underlying evidence must allow reported figures to be reproduced. Meter readings, fuel records, production totals and supplier information need to reconcile sufficiently for an independent reviewer to trace the emissions calculation.
Data gaps identified only toward the end of the reporting process can be difficult to resolve. Records generated during production therefore form an important part of the evidence required for the EU Carbon Border Adjustment Mechanism.
The requirements also create a distinction between preparing a monitoring system and subsequently verifying it. Casas stressed the need for independence between consultancy and verification, meaning a business involved in designing or implementing a monitoring system cannot assume that the same team, or an affiliated entity, can independently verify its own work.
European Commission expands verifier resources
The European Commission published additional resources for CBAM verifiers on 28 September, addressing accreditation, registry access and practical implementation.
The materials contribute to the assurance infrastructure being developed for the definitive CBAM regime. For steel suppliers, the verification process consequently depends on the quality and traceability of information generated before the review begins.
Commercial contracts are also affected by the availability of evidence. A commitment to supply a low-emission steel product provides limited value to an EU purchaser if the exporter cannot supply verifiable emissions data within the timeframe required for the purchaser’s declaration.
First reporting cycle will test production records
The first definitive reporting cycle will place emphasis on records accumulated during manufacturing rather than solely on the process of appointing a verifier close to the deadline.
Steel suppliers will need the production and emissions evidence supporting their calculations to remain sufficiently complete for independent review. Records that were not captured during production may not be capable of being reconstructed when the reporting deadline arrives.
