CBAM verification for non-EU suppliers: what to expect

If you want your EU buyer to use your real emissions instead of default values, an accredited verifier has to check them. Here's how that works and how to get ready.

Why verification matters to you

Your EU buyer can declare your goods using your actual emissions or the EU's default values. Actual emissions can only be used if an accredited verifier has checked them. If verification doesn't happen, or fails, default values apply, with their built-in mark-up. For suppliers whose real emissions are below the default, verification is what turns good data into lower costs for the buyer.

Who can verify

Verification must be done by an independent verifier accredited by a national accreditation body in an EU member state. Accreditation is granted by activity group, so a verifier accredited for cement can't automatically verify a steel or aluminium installation. Many of the first CBAM verifiers are organisations already accredited under the EU Emissions Trading System.

The Commission expected the first CBAM verifiers to be accredited around September 2026 and publishes the list of accredited verifiers on its CBAM verification page. Check that list before you sign a contract.

What the verifier checks

Verification happens per installation, not per product or per buyer. The verifier looks at:

• How you define your installation and production processes.
• How you measure fuels, materials and output, including meters and invoices.
• How you attribute emissions to each product.
• The emissions of precursors you bought in, and the evidence behind them.
• Your internal controls: who records the data, how errors are caught, how records are kept.

Errors are judged against a 5% materiality threshold. Misstatements that add up to more than that can stop the report from being verified.

The first-year site visit

For data covering 2026, a physical site visit to each installation producing CBAM goods is required. Plan for travel time, language and scheduling. Verifier capacity is limited while the market builds up, especially for less common sector and country combinations.

Timing

How to prepare

1. Calculate your 2026 emissions with the EU method now, so you know whether you're above or below the default.
2. Write down your monitoring method: what you measure, how, and who is responsible.
3. Keep monthly records of fuel, output, precursor purchases and scrap, with the invoices behind them.
4. Ask your metal suppliers whether their own data will be verified. Your buyer's verifier will check precursor evidence too.
5. Contact accredited verifiers early and agree a date for the site visit.
6. Consider a pre-verification check to find gaps while there's still time to fix them.

Frequently asked questions