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, it identifies a data challenge ahead of the definitive regime, which applies to covered imports from 2026 and includes reporting and certificate obligations.
The estimate concerns suppliers of steel, aluminium, cement, fertilisers, hydrogen and electricity. The assessment should not be treated as a statistically established measure of readiness across all exporters because detailed sampling information has not been publicly established. It identifies the issue in Serbia, Montenegro, Bosnia and Herzegovina and other Southeast European markets, where emissions evidence can affect both compliance and market access.
European buyers may increasingly favour suppliers able to provide verified emissions information before shipment, particularly for large-volume purchases and long-term contracts. A shortage of usable evidence could influence procurement decisions even before the first annual CBAM settlement, the assessment said.
Installation-level data and verification
Importers seeking to use actual embedded emissions must obtain appropriate installation-level information and independent verification. Factories outside the European Union may have sustainability reports or corporate carbon inventories, but these do not automatically establish emissions linked to a specific exported steel product, aluminium batch or cement installation.
Calculations can require detailed production records covering 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, according to the assessment.
The first annual CBAM declarations are due in September 2027. 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 seeking to support actual-emissions reporting.