For importers wishing to use actual data to calculate emissions, it is crucial to obtain embedded emissions data for imported CBAM goods in a timely manner. It is also important that the emissions data be verified by an accredited verifier; otherwise, it cannot be used. An importer can obtain actual emissions data in two ways: (1) through the CBAM Registry or (2) directly from its supplier or the manufacturer of the CBAM goods in a third country.

1. The manufacturer in a third country is registered in the CBAM Registry

If the manufacturer of the CBAM goods is registered in the CBAM Registry, obtaining the actual emissions data is straightforward. The manufacturer shares the actual emissions data with the importer directly through the CBAM Registry. According to European Commission data from May 2026, approximately 3,000 manufacturers from third countries had registered in the CBAM Registry. This figure suggests that manufacturers in third countries have shown interest in using the CBAM Registry, although the number of users from third countries is still relatively low.

2. The manufacturer in a third country is not registered in the CBAM Registry

If the manufacturer of the CBAM goods is not registered in the CBAM Registry, the importer must obtain the actual emissions data directly from the supplier or the manufacturer of the CBAM goods in a third country. During the transitional period, most manufacturers used the Excel communication template to exchange information with importers. An updated and adapted Excel template will also be used for periods after 1 January 2026. Use of the communication template is not mandatory; however, using it is the simplest option for everyone involved.

3. What should be done if the supplier does not provide actual emissions data?

If the importer does not receive actual emissions data and confirmation that the data are accurate (issued by an accredited verifier), it must use emissions data based on default values. Importers expecting to import larger quantities of CBAM goods will generally benefit from identifying suppliers that can provide verified actual emissions data. As accreditation of prospective verifiers only began in September 2026, it is expected that by the end of 2026 it will become clear whether suppliers will be able to provide actual emissions data.

Communication with suppliers or manufacturers in third countries can be handled by an external expert

Collecting actual emissions data is not a simple task, so importers may wish to entrust it to an external expert. ANOVA and its team of CBAM experts can assist you. For more information, please email us at info@anova.si or call us on +386 30 730 505.

Prepared by: Mojca Müller, Certified tax adviser at SIR