Under the Carbon Border Adjustment Mechanism (CBAM), European Union importers, industrial producers and accredited verifiers have distinct responsibilities. The compliance process requires emissions information to move between several independent organisations across borders.
For manufacturers in the Western Balkans, producing reliable embedded emissions calculations is only one element of the workflow. The information must also be independently verified, provided to the appropriate EU importer and incorporated into the importer’s regulatory reporting arrangements.
The division of responsibilities becomes more complex when production data come from multiple companies. Electricity suppliers, raw-material producers and industrial processors can each contribute to emissions evidence, while none controls every stage of the final declaration.
When contractual obligations are unclear, issues can arise including missing documentation, delayed verification and disputes over responsibility for correcting reported information. A defined governance framework is intended to help each participant identify its obligations before relevant reporting deadlines.
EU importers manage CBAM declarations and certificate obligations
The EU importer, or the relevant indirect customs representative, is responsible for fulfilling applicable CBAM declaration obligations. This includes managing required authorisation, registry procedures and CBAM certificate obligations.
Importers also need to ensure that emissions information used in regulatory submissions corresponds to the goods imported. They must establish which producing installation supplied the relevant products.
Importers are expected to confirm whether associated emissions information remains current. They also need to verify that actual emissions values have undergone the required independent verification.
Even when exporters provide underlying industrial information, submitting an emissions spreadsheet does not shift regulatory responsibilities to the manufacturer. The importer must maintain a reliable connection between goods entering the EU and corresponding emissions documentation.
Changes in supplier information, production methods or verified emissions factors therefore need to be communicated through agreed procedures. This requirement links updates in upstream inputs to the documentation used in regulatory reporting.
Non-EU operators hold operational data for embedded emissions
The non-EU producing installation holds operational information used to calculate embedded emissions of manufactured goods. Records include production routes, fuel consumption, electricity use, material inputs, manufacturing output and relevant operating conditions.
The industrial operator must set up monitoring arrangements capable of generating emissions calculations under the applicable CBAM methodology. Where actual values are used, supporting information must be available for independent verification.
Manufacturers are responsible for preserving underlying evidence and maintaining consistency between production records and emissions information supplied to customers. For Western Balkan exporters, this requires coordination across production, engineering, procurement and reporting departments.
The factory must be able to explain how reported emissions are derived from its operating data. It must also demonstrate that the calculation applies to the relevant products exported into the EU market.
Accredited verifiers conduct independent assurance separate from operators
The accredited CBAM verifier operates separately from both the industrial operator and the importing company. The verifier examines monitoring methodology, emissions calculations and supporting documentation before issuing an independent verification conclusion.
The verifier’s effectiveness depends on maintaining impartiality throughout the assessment process. Industrial manufacturers may use engineering consultants or technical advisers during preparation activities.
Engineering advisers can develop metering arrangements, establish monitoring procedures and prepare reporting systems. However, the independent verifier should not be placed in a position of assessing work for which it was responsible during design and implementation stages.
This separation distinguishes technical preparation from formal regulatory verification. An engineering adviser can improve evidence quality and organisation, while the accredited verifier provides independent assessment required for actual emissions reporting.
Upstream suppliers add data access requirements across supply chains
CBAM-related responsibilities can extend beyond the manufacturer exporting finished products. Electricity generators, utilities, material traders, steel mills and aluminium smelters may possess information needed to determine emissions associated with manufacturing inputs.
Where exporters rely on these records, procurement agreements should define necessary data-access rights and delivery obligations. A manufacturer requesting upstream emissions information only after a reporting period ends may find that suppliers did not retain sufficient detail.
This risk is particularly relevant for multi-tier supply chains. In one example described in the material, a Western Balkan steel fabricator buys material through a trader, performs additional processing and exports a CBAM-covered product to an EU customer.
The fabricator needs sufficient information about relevant precursor emissions to prepare its calculations. The importer then requires the final verified emissions result associated with imported goods.
Maintaining material traceability and product genealogy supports movement of information through the supply chain without losing its connection to original production activities.
Contracts define data ownership, corrections and authorised disclosures
Commercial agreements can define how emissions information moves between upstream suppliers, industrial operators, verifiers and EU importers. Provisions include data ownership, submission deadlines, confidentiality requirements, correction procedures and authorised disclosure arrangements.
Manufacturers should know which records they must provide to importers. They also need clarity on which supporting information they are contractually entitled to obtain from electricity and material suppliers.
Contracts can specify whether sensitive production information may be disclosed directly to an accredited verifier rather than distributed more broadly among commercial counterparties. Data corrections require particular attention when previously issued reports are affected by changes.
If a meter adjustment changes an operator’s previously issued emissions report, manufacturers need a controlled procedure for updating calculations and reissuing relevant information. Where an EU importer has already used earlier results, parties must determine how revised data will be communicated within the applicable reporting process.
An evidence chain is expected to preserve not only updated emissions values but also records of changes affecting previously distributed information.
RACI matrices support escalation when deadlines or technical issues arise
Industrial companies can use a Responsible, Accountable, Consulted and Informed (RACI) matrix to divide reporting responsibilities under CBAM processes. The matrix should identify who prepares, reviews, approves and receives individual evidence items rather than assigning broad duties only by job title.
The framework can also establish escalation procedures when documentation is missing or technical disagreements remain unresolved. If an upstream supplier misses an emissions-data deadline, procurement escalation can be initiated before the reporting period closes.
Where an accredited verifier identifies a technical deficiency, engineering can coordinate a response. If an importer challenges methodology used in an emissions calculation, commercial and legal departments can participate in resolving the issue.
Preliminary internal estimates must remain distinct from verified results
A governance requirement concerns when internal emissions information becomes an external declaration or commercial claim. Manufacturers may calculate preliminary embedded emissions values during the reporting year for operational management and discrepancy identification.
Internal estimates and provisional calculations should remain distinguishable from final actual emissions values that have undergone agreed review and verification procedures. A controlled release process can define who authorises distribution of results to customers and which supporting documentation accompanies them.
This approach is intended to prevent preliminary figures being treated as verified regulatory evidence by exporters or importers. Internal management dashboards can reinforce separation by tracking metering records, material information, outstanding supplier requests, verification findings and customer submissions as separate categories.
An unresolved supplier request should not appear as completed verified evidence. Completion of an independent verification report does not establish that an EU importer has fulfilled its own declaration and certificate obligations.
Standardised verified datasets can support multiple EU customers without shifting responsibility
Manufacturers supplying several EU customers can reduce duplication by maintaining a standardised core dataset of verified installation-level emissions information. Underlying records can remain consistent while customer-specific documentation formats or commercial information are provided for individual importers.
This structure limits recreating the same emissions calculation separately for each buyer while reducing risk of inconsistent figures being circulated. Standardising supplier evidence does not transfer regulatory responsibilities between participants under CBAM arrangements.
Each EU importer continues managing its own CBAM declaration while the industrial operator remains responsible for accuracy, traceability and maintenance of source information. A centralised evidence repository with defined approval and release procedures allows exporters to provide consistent documentation across multiple commercial relationships while preserving separate legal and technical responsibilities within the CBAM reporting chain.