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CBAM

The Carbon Border Adjustment Mechanism (CBAM) is a regulatory instrument introduced by the European Union to align the carbon costs of imported goods with those produced within the EU. Its purpose is to ensure that imports reflect comparable CO₂ pricing, thereby supporting climate policy objectives and addressing imbalances in environmental standards.

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All you need to know about CBAM

CBAM Verification: Independent Assessment of Your CBAM Data for Compliant CO₂ Border Adjustment

By implementing CBAM, the EU aims to mitigate the risk of carbon leakage, where production is relocated to regions with less stringent climate regulations to reduce operational costs. The mechanism contributes to the broader framework of the EU climate strategy by promoting consistent emissions accountability across global supply chains.

Since 1 January 2026, the regulation has entered its full implementation phase. It initially covers carbon-intensive sectors such as steel, aluminium, cement, fertilizers, electricity, and hydrogen. The scope may be extended to additional industries over time in line with EU climate targets.

From this date onwards, CBAM reports based on actual emissions must undergo verification by an accredited and independent verification body.

Who is CBAM Verification Relevant For?

CBAM requirements apply to various stakeholders involved in international trade between third countries and the European Union.

Operators in Third Countries

If your organization manufactures goods outside the EU that fall under CBAM, you are required to quantify and report the associated CO₂ emissions. These emissions reports must be independently verified. Verified data enables your EU-based customers to declare actual emission values within their CBAM submissions, avoiding reliance on default values.

Approved CBAM Declarants in the EU

If your organization imports goods into the EU from CBAM-relevant sectors — including iron, steel, aluminium, cement, hydrogen, fertilizers, or electricity — you must submit an annual CBAM declaration. This requires verified emissions data from your suppliers.

The applicability of CBAM to specific products is determined by their CN (Combined Nomenclature) classification, as outlined in Annex I of Regulation (EU) 2023/956.

Is TÜV NORD Accredited for CBAM?

TÜV NORD is in the process of obtaining accreditation as a CBAM verification body. Preparatory measures are already in place to align internal procedures, methodologies, and governance structures with the requirements defined for accredited verification bodies under CBAM.

The objective is to perform verification activities in accordance with applicable standards, ensuring impartiality, traceability, and technical reliability. Once accreditation is granted, TÜV NORD Middle East will provide formal CBAM verification services for companies requiring compliant emissions data validation.

CBAM Verification with TÜV NORD: Key Aspects

Verification of CBAM reports supports regulatory compliance and provides a reliable basis for emissions reporting within international trade.

Key aspects include:

  • Independence and technical verification competence
    TÜV NORD builds on established expertise from emissions trading systems such as EU ETS and national schemes.
  • Regulatory compliance assurance
    Verified emissions data is required to declare actual values. Without verification, predefined default values must be applied, which may result in higher CO₂ cost exposure.
  • Transparency for authorities and stakeholders
    Verified reports provide credible and consistent emissions data for regulatory authorities and business partners.
  • Supply chain risk management
    Independent verification reduces uncertainties related to data quality and regulatory obligations.
  • Support for sustainability positioning
    Documented and verified emissions data contributes to transparent environmental performance across supply chains.

Scope of CBAM Report Verification

The verification process conducted by TÜV NORD focuses on assessing whether reported emissions meet the regulatory and methodological requirements defined by CBAM.

Typical verification activities include:

  • Review of documentation completeness and consistency
  • Assessment of applied calculation methodologies for CO₂ emissions
  • Evaluation of data collection and monitoring systems
  • Verification of reported emission values
  • Confirmation of compliance with CBAM regulatory requirements

These activities are carried out independently and in accordance with applicable verification standards.

CBAM Reporting Obligations for Companies

Organizations subject to CBAM must prepare and submit emissions reports for imported goods on a regular basis. These obligations are derived from the EU’s “Fit for 55” framework, which aims to reduce greenhouse gas emissions across key sectors.

CBAM reports are required to:

  • be submitted annually to the European Commission
  • include detailed data on both direct and indirect emissions generated during production
  • undergo independent verification when actual emissions data is used instead of default values
  • The transitional phase, during which quarterly reporting was required, concluded on 31 December 2025. Full regulatory obligations became applicable from 1 January 2026.
  • Companies must ensure that their verified CBAM reports are submitted within the specified regulatory deadlines. The submission of verified emissions data to the European Commission is required no later than 31 August 2027.

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Do you have any questions regarding our auditing and certification services? Feel free to get in touch with us.

TUV NORD Middle East L.L.C. – Certification | Shibu Davies