Under the Carbon Border Adjustment Mechanism (CBAM), European Union importers, non-EU 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 process. The emissions information also needs independent verification, transfer to the relevant EU importer and inclusion in that importer’s regulatory reporting arrangements.
The division of responsibilities becomes more complex when production data come from multiple companies. These can include electricity suppliers, raw-material producers and industrial processors, which contribute to the emissions evidence chain without controlling every stage of the final declaration.
Where contractual obligations are unclear, documentation can be missing, verification can be delayed, or disputes can arise over who must correct reported information. A defined governance framework is intended to help participants identify their obligations before reporting deadlines.
EU importers manage CBAM declarations and certificate obligations
The EU importer, or the relevant indirect customs representative, is responsible for meeting CBAM declaration obligations. This includes managing required authorisation, registry procedures and CBAM certificate obligations.
Importers must also ensure that emissions information used in regulatory submissions corresponds to the goods imported. They are expected to determine which producing installation supplied the relevant products.
Importers need to confirm whether associated emissions information remains current and whether actual emissions values have undergone required independent verification. Although exporters provide underlying industrial information, submitting an emissions spreadsheet does not shift the importer’s regulatory responsibilities to the manufacturer.
The importer must maintain a reliable link between goods entering the EU and the corresponding emissions documentation. Changes in supplier information, production methods or verified emissions factors therefore need to be communicated through agreed procedures.
Non-EU producers generate monitoring data for embedded emissions
The non-EU producing installation holds operational information needed to calculate embedded emissions for manufactured goods. Records include production routes, fuel consumption, electricity use, material inputs, manufacturing output and relevant operating conditions.
The industrial operator is expected to establish 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 among production, engineering, procurement and reporting departments.
The factory must be able to explain how reported emissions are derived from operating data. It also needs to demonstrate that the calculation applies to the relevant products exported to EU customers.
Accredited verifiers assess monitoring methods and calculation evidence
The accredited CBAM verifier operates separately from both the industrial operator and the importing company. The verifier reviews the operator’s monitoring methodology, emissions calculations and supporting documentation before issuing an independent verification conclusion.
The effectiveness of verification depends on maintaining impartiality throughout the assessment process. Industrial manufacturers may appoint engineering consultants or technical advisers for metering arrangements, monitoring procedures and reporting systems.
However, an independent verifier should not be placed in a position of assessing work it was responsible for during design and implementation stages. This separation is intended to distinguish technical preparation from formal regulatory verification.
An engineering adviser can improve the quality and organisation of factory evidence. The accredited verifier then provides the independent assessment required for actual emissions reporting.
Upstream electricity and materials add further documentation requirements
CBAM responsibilities can extend beyond the manufacturer exporting finished products. Electricity generators, utilities, material traders, steel mills and aluminium smelters may hold information needed to determine emissions linked to manufacturing inputs.
Where exporters rely on such records, procurement agreements should set out data-access rights and delivery obligations. A manufacturer requesting upstream emissions information only after a reporting period has ended may find that suppliers did not retain sufficient detail.
This issue is particularly relevant in multi-tier supply chains. For example, a Western Balkan steel fabricator may buy material through a trader, perform additional processing and export a CBAM-covered product to an EU customer.
The fabricator needs sufficient information about precursor emissions to prepare its calculations. The importer requires the final verified emissions result associated with imported goods.
Contracts define data access, confidentiality and correction processes
Commercial agreements can specify how emissions information moves between upstream suppliers, industrial operators, verifiers and EU importers. Provisions can cover 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 also 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 meter adjustments change previously issued operator reports.
If an earlier operator emissions report is updated due to a meter adjustment, 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.
RACI governance supports timely evidence preparation and escalation
Industrial companies can use a Responsible, Accountable, Consulted and Informed (RACI) matrix to divide reporting responsibilities. The matrix should identify who prepares, reviews, approves and receives individual evidence items rather than assigning broad duties by job title alone.
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.
If an accredited verifier identifies a technical deficiency, engineering departments can coordinate responses. If an importer challenges methodology used in an emissions calculation, commercial and legal departments can participate in resolving issues.
Preliminary internal estimates must be separated from verified results
A governance requirement concerns when internal emissions information becomes an external declaration or commercial claim. Manufacturers may calculate preliminary 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 emissions 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 track metering records, material information, outstanding supplier requests, verification findings and customer submissions as separate categories.
Standardised datasets can support multiple EU importers 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 identical emissions calculations separately for each buyer while reducing risks 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 commercial relationships while preserving separate legal and technical responsibilities within the CBAM reporting chain.