BRUSSELS, 3 November — An industry assessment published on 2 November estimated that approximately six in ten exporters supplying goods covered by the European Union’s Carbon Border Adjustment Mechanism (CBAM) have gaps in emissions documentation and verification readiness. Based on assessments by accredited verification providers, the estimate highlights a data challenge as the definitive regime approaches.
Installation-level evidence required
From 2026, covered imports into the European Union are subject to CBAM reporting and certificate obligations. The first annual declarations are due in September 2027. The assessment covers exporters supplying steel, aluminium, cement, fertilisers, hydrogen and electricity.
The finding is an industry assessment, not a statistically established measure of readiness across all exporters, as detailed sampling information has not been publicly established. It identifies the issue among suppliers in Serbia, Montenegro and Bosnia and Herzegovina, as well as other Southeast European markets.
European importers seeking to use actual embedded emissions must obtain appropriate installation-level information and independent verification. Factories outside the EU may have sustainability reports or corporate carbon inventories, but those records do not automatically establish emissions for a specific exported steel product, aluminium batch or cement installation.
Calculations can require production-specific records on fuel consumption, process emissions, relevant precursor inputs, monitoring boundaries and allocation methodologies. Where actual emissions are unavailable or insufficiently supported, importers may need to use regulatory default values. Those values can disadvantage producers whose actual emissions are lower.
Supplier selection and financing
For Southeast European exporters, emissions evidence is both a compliance matter and a market-access issue. European buyers may increasingly prefer suppliers able to provide verified information before shipment, particularly for large-volume purchases or long-term contracts.
A shortage of usable evidence could influence procurement decisions even before the first annual CBAM settlement. Banks financing industrial exporters may need to distinguish companies with credible emissions evidence from those whose sales prices remain exposed to uncertain carbon-cost deductions.
Verification providers face increasing demand, making early engagement and confirmation of accreditation scope important for exporters. The assessment identifies installation-level data and independent verification as practical requirements for suppliers preparing to support actual-emissions reporting under the 2026 definitive regime.