Ask your supplier for the right thing the first time

Published 14 September 2026

An importer's CBAM year has one moment that decides most of what follows: the first request to a supplier for emissions data. Ask for "your carbon footprint" and the reply is a brochure figure nobody can declare. Ask for what the declaration needs, in the acts' own terms, and the reply can go straight into the filing. This guide sets out what to ask for, and why.

What the declaration needs from each supplier

The CBAM declaration is filed in the CBAM registry by 30 September, for the first time in 2027 for the year 2026 (Regulation (EU) 2023/956 Art. 6(1)). Article 6(2) lists what it carries: for each type of goods, the total quantity imported in the year, in tonnes (megawatt-hours for electricity); the total embedded emissions in those goods, in tonnes of CO2e per tonne of goods, calculated under Article 7 and, where determined from actual emissions, verified under Article 8; the number of CBAM certificates to surrender after the reduction for a carbon price paid in a third country and the adjustment for free allocation; and, where applicable, copies of the verification reports.

So from each installation you buy from, the filing needs three things: the specific embedded emissions of each good, per tonne; a verification of those figures by an accredited verifier where they are actual rather than default; and, where the producer paid a carbon price at home, the evidence for it. A quantity you already have from your own customs records. A brochure figure, a corporate average or an unverified spreadsheet gives you none of the three.

What a registered operator is obliged to hold

A producer can register its installation in the CBAM registry (Art. 10(1)); the registration carries the operator's name, address, registration number and contact details, the installation's location with coordinates to six decimals, and its main economic activity, and it is valid for five years (Art. 10(2), 10(3)). A registered operator then has duties of its own under Article 10(5): to determine the embedded emissions by the methods in Annex IV, by type of goods produced; to have those emissions verified by an accredited verifier under the Annex VI principles; to keep the verification report and the calculation records for four years; and, where applicable, to determine the carbon price paid and upload the evidence for it.

Article 10(7) is the sentence that makes the request work: an operator may disclose the information on the verification of embedded emissions and on the carbon price paid to an authorised CBAM declarant, and the declarant is entitled to use it to meet the verification duty of Article 8. Article 8(2) says the same from the declarant's side. So the right request to a registered supplier is not "send me a number" but "disclose your verified figures to me under Article 10(7)".

What the verified report contains

The document behind that disclosure is the operator's emissions report, whose template is Annex IV of Implementing Regulation (EU) 2025/2547. The shorter of the two is the Operator's Summary Emissions Report: Annex IV, point 1.2 lists the information from the operator's emissions report that it must also contain. It carries, at least:

• Who and where. The operator's name, registration number and address in English; the installation's name, its unique installation identifier in the CBAM Registry, its UN/LOCODE, its address and the coordinates of its main emission source.
• What is made. The list of all CBAM production processes and routes at the installation, with the goods produced by each.
• The figures per good. The specific direct embedded emissions of each good; the share of embedded emissions for which default values were used; for goods not listed in Annex II of the base act, the shares of indirect emissions from actual and from default values, the confirmation that the criteria for actual values are met, and the specific indirect emissions; and the specific embedded free allocation of each good.
• The installation totals and flags. Total direct emissions for the reporting period and per production process; whether measurable heat is imported or exported; whether zero-rated fuels are used and how that is shown; whether waste gases are produced, used, imported or exported.

When a supplier sends a figure, this is the list to check it against. A figure with no installation identifier, no production route and no statement of how much of it rests on default values is not the report; it is a number.

The precursor questions to ask at the same time

Most CBAM goods contain precursors, and the acts settle how a precursor's emissions travel into the finished good. Where an installation receives, from another installation, precursors under one CN code produced during different reporting periods, the emissions embedded in the finished good take, for the part embedded in those precursors, the weighted average across those periods (IR 2025/2547 Art. 14(1)). Where the precursors under that CN code come from several installations, the default is again the weighted average of that part across those installations (Art. 14(2)); the emissions of a single installation, or of a subset of installations, are used only where the operator gives the verifier sufficient evidence that the production process used precursors from that installation or subset alone (Art. 14(3)). And for each precursor the method records the specific mass consumption, the mass of precursor per unit of finished good, so that the data can be used independently of activity levels (Annex III).

So ask your supplier, in the same request: which precursors are in the good, from which installations, and on what basis their emissions were taken. Our guide on why a supplier's precursor number is usually not usable explains what happens when that basis is missing.

The transitional template, and why it still matters

During the transitional period a reporting declarant could ask an operator to use an electronic template provided by the Commission and to supply the content set out in Annex IV to Implementing Regulation (EU) 2023/1773 (Art. 3(5)). The workbook for installations is that template; its summary sheet carries the installation details (name, address, economic activity, country, UNLOCODE, coordinates, reporting period start and end) and, for each product, the production process it arises from, whether it is an aggregated good or a precursor, the CN code and name, the product name used for communication with the declarant, and the specific embedded emissions, direct, indirect and total, with the unit. Many suppliers still hold their data in that shape, and most of what it carries is what the definitive report also asks for; our platform reads it directly. What the template cannot supply is the verification: a filled template is the producer's statement, and for actual values the filing needs the verifier's report behind it.

How to ask, in one message

• Name the year and the goods by CN code, and ask for the specific embedded emissions per tonne of each, direct and, where the good is not in Annex II, indirect.
• Ask whether the installation is registered in the CBAM registry and, if it is, for the disclosure of its verified figures under Article 10(7). If it is not, ask for the operator's emissions report and the verification report, not a promise of one.
• Ask for the share of each figure that rests on default values, and for the production route.
• Ask which precursors are in the good, from which installations, and whether their emissions are single-installation or weighted-average figures.
• Ask whether a carbon price was paid at home and, if so, for the evidence.

A supplier who can answer all five is holding what a registered operator's duties under Article 10(5) produce. A supplier who cannot is telling you, early, that the filing will rest on default values for that line, and it is better to learn that in March than in September.

Regulatory sources: Regulation (EU) 2023/956 Art. 6(1) and 6(2), Art. 8(1) and 8(2), Art. 10(1), 10(2), 10(3), 10(5) and 10(7); Implementing Regulation (EU) 2025/2547 Art. 14(1) to 14(3), Annex III, Annex IV point 1.2; Implementing Regulation (EU) 2023/1773 Art. 3(5) and Annex IV. The transitional communication template referred to is the Commission's workbook for installations, version of 13 December 2024.