Reducing CBAM costs through verification
Importers of CBAM goods are currently struggling with great uncertainty. Do they have to use the high default values for grey emissions when submitting their CBAM declaration for import in 2026 or are their suppliers able to provide actual verified CBAM data? The cost implication of the two options can differ greatly.
High uncertainties for importers
While CBAM goods could be imported before 1 January 2026 without an obligation to pay, all imports have been subject to a payment obligation since the start of 2026 (see our article regarding the start of the definitive CBAM phase). However, many importers are not yet clear how high the payment for the grey emissions will be. On the one hand, the reason for the unclarity is that CBAM certificate prices for imports during 2026 will only be determined at the end of each quarter.
However, the second and often more critical reason is that if suppliers do not know if their suppliers can provide verified real data for embodied emissions and CBAM benchmarks (specific free allocation) by 30.09.2027 (2026 CBAM declaration deadline for imports). If they cannot, the importer must use default values for reporting. The default values for grey emissions are very high for some countries and products and may double or triple product prices.
The value of verified actual data
Such an increase in costs is not feasible for many companies, which in turn could bring the import of these goods to a standstill or result in high margin reductions for importers. As an example, Figure 1 shows the difference in CBAM costs for importing steel pipes from India, once with verified data and once with the assumption of default values.
Figure 1: Example of CBAM costs using verified data vs. default values (Source: carboneer)
In this case, the cost difference between verified real values and standard values would amount to almost 240,000 EUR. An importer of these products would therefore have to pay CBAM costs of EUR 323 per tonne of imported product using the standard values. With a product price without CBAM of EUR 800-1200 per tonne, the additional CBAM costs are therefore very significant.
For the strategic and economic evaluation of suppliers, goods and products, affected companies should evaluate and compare different suppliers and their products in scenario analyses (see Figure 2 with an excerpt from carboneer’s CBAMCC model).
Figure 2: Scenario analysis for the strategic evaluation of CBAM (Source: CBAMCC carboneer)
Without appropriate assessment and preparation, the CBAM declaration and the obligation to surrender CBAM certificates in 2027 could be a nasty surprise for importers.
Preparation for verification
However, in order to be able to use actual data from suppliers, this data must be available in verified form. Only independent verifiers, accredited by the national accreditation bodies of EU member states, are allowed to determine the authenticity of data under CBAM. Furthermore, suppliers must prepare extensively for verification, as the inspection bodies themselves are not allowed to provide support for the collection or calculation of CBAM data.
It is expected that the first accredited verifiers will not be known until earliest mid-2026. The final verification will also not be completed before the beginning of 2027, as the production data from 2026 will only be available by the start of the new year. Figure 3 shows the data flow from producer to importer.
Figure 3: The annual verification process (Source: carboneer)
In addition to a mandatory inspection of the supplier’s facility by the auditor, producers of CBAM goods must also submit a monitoring plan that describes in detail the methodologies for measuring, calculating and collecting a large number of relevant data points. Without such a plan, no verification of the data can take place.
As of 1 January 2026, the rules for CBAM emission calculation have also changed and other data points, such as the CBAM benchmarks, are necessary to successfully pass a verification. In our experience, only a few producers and suppliers can fully comply with the current CBAM rules. The high number of production sites worldwide as well as potential capacity limitations at the verifiers makes verification without sufficient preparation in many cases unlikely. Without verified actual data, CBAM costs for importers could increase dramatically.
In our experience, structured support can prepare suppliers for verification within a few weeks. Especially if the potential cost savings for the importer would mean tens to hundreds of thousands of euros, direct supplier support is currently one of the most promising ways to limit CBAM costs and gain competitive advantage.
We will dive into further ways to reduce or secure CBAM costs, especially with regard to the management of CBAM certificates, in upcoming articles and webinars.
