When using actual emissions under the CBAM mechanism, importers often face a practical question: Who is responsible for providing the verification report, and who actually engages the accredited verifier?

Understanding this distinction is important because the CBAM system assigns different responsibilities to the producer of the goods and to the authorised CBAM declarant.

The verification report is provided by the producer of the CBAM goods

Where actual emissions are used to determine the embedded emissions of CBAM goods, the emissions data must be appropriately verified.

The services of an accredited verifier are engaged by the producer of the CBAM goods, i.e. the operator of the installation in the third country.

This means that the importer or authorised CBAM declarant is not responsible for finding a verifier and arranging the verification of the producer’s emissions.

What is the role of an accredited verifier?

The role of an accredited verifier can be compared, in simplified terms, to that of an auditor performing an audit of financial statements.

Based on a review of the production processes, emissions data, methodologies applied and other relevant information, the verifier assesses whether the reported emissions data are reliable and whether the calculated actual emissions appropriately reflect the actual situation.

The verification process results in a verification report.

How does the importer obtain the verification information?

The authorised CBAM declarant may obtain the relevant emissions and verification information in two ways:

→ through the CBAM Registry, where the operator of the installation in the third country is registered in the CBAM Registry and the relevant data have been made available there; or

→ directly from the producer or indirectly through the supplier of the CBAM goods.

It is therefore important for importers to establish in good time whether the producer will be able to provide the required actual emissions data and the corresponding verification documentation.

What does this mean for importers of CBAM goods?

If an importer intends to use actual emissions when determining its CBAM obligations, timely communication with the producer or supplier is essential.

We recommend that importers check:

• whether the producer has calculated the actual embedded emissions of the goods;
• whether the relevant emissions data have been verified by an appropriately accredited verifier;
• whether the producer or installation operator is registered in the CBAM Registry; and
• how the authorised CBAM declarant will obtain access to the necessary emissions data and verification documentation.

Article prepared with the help of AI by: Mojca Müller, Certified tax expert