The EU Carbon Border Adjustment Mechanism CBAM assigns responsibility for submitting a correct declaration to the authorised declarant, even when emissions evidence is generated at manufacturing facilities outside the importer’s control. The compliance approach requires reliable links between purchased goods, their producing installations, and the verified emissions information used in reporting.
Supplier selection under CBAM involves more than comparing purchase prices. Importers need to identify where goods were manufactured, obtain emissions data suitable for CBAM reporting, and reconcile those figures with customs records. Verification can support the reliability of factory emissions information, but the importer remains responsible for using the appropriate data in its declaration.
Authorised declarant and role of customs representatives
The authorised declarant can be the importer or an indirect customs representative that has accepted the role under applicable arrangements. Appointing a customs broker to process entries does not automatically mean that broker has taken on CBAM responsibilities. Import contracts, representation agreements, and internal procedures are expected to identify the responsible legal entity before shipments arrive.
Before submitting declarations, importers also need to determine whether their goods fall within CBAM’s scope and whether an exemption applies. The annual mass threshold of 50 tonnes applies to relevant goods, while electricity and hydrogen are excluded from that threshold exemption.
Verification requirements and 2026 declaration timing
For declarations based on actual emissions, regulatory requirements include verification by an appropriately accredited CBAM verifier. The first annual declaration covering 2026 imports is due on 30 September 2027. The schedule separates the period when 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.
Internal controls linking procurement, customs and emissions data
A coordinated control system can connect procurement, customs, sustainability and finance functions within the same reporting process. Procurement teams set emissions-data obligations with suppliers, while customs personnel maintain imported quantities and product classifications.
The carbon or sustainability team checks whether emissions information matches the correct producing installation and reporting period. Finance assesses certificate exposure resulting from the calculations and determines funding needs associated with those obligations.
A common register of suppliers and production installations can connect these responsibilities. It also provides a reference for checking whether emissions documentation received corresponds to goods recorded in customs and purchasing systems.
Traceability issues when distributors change sourcing
Distributors can add traceability complexity because the contractual seller may not operate the factory that produced the goods. If a distributor changes its manufacturing source during the year, importers need to determine which installation supplied each delivery and whether related emissions information remains applicable.
A corporate sustainability report alone cannot establish that connection. Importers need records linking relevant goods to producing installations and identifying which emissions information applies to each specific reporting period.
Using verification reports correctly in declarations
Importers are expected to examine the scope of each verification report before using it in a declaration. The producing installation, goods covered, reporting period, and verification conclusion must correspond to information supporting reported imports.
If a report is corrected or replaced, importers should track revisions and prevent obsolete versions from remaining in active calculation spreadsheets. Earlier versions should still be accessible through a controlled record history.
These procedures function as recommended management controls rather than requiring every importer to repeat a factory audit independently. The importer’s task is to use verified information correctly while maintaining a defensible link between that information and imported goods.
Documentation retention for potential authority review
EU authorities can review submitted declarations alongside associated verification information. Importers therefore need sufficient documentation to explain how figures used in declarations relate to purchases and customs records.
Southeast Europe supplier documentation arrangements for EU customers
For exporters in Southeast Europe, clearly identifying producing installations can support transactions with EU customers under CBAM requirements. Agreeing data-delivery schedules and assigning responsibility for corrections are also intended to make compliance processes easier for importing parties to manage.
These arrangements do not necessarily require changes to production technology. They depend on reliable information flows between manufacturers, any distributors, and importing customers, supported by procedures establishing which emissions records apply to each delivery.
The first annual declaration covering 2026 imports requires importers to connect factory-level evidence with goods entered into the EU market. A verified factory report remains useful only when an importer can demonstrate it corresponds to products and installations covered by its declaration.