Why supplier emissions data is now critical for CBAM

Are you importing goods covered by the EU’s Carbon Border Adjustment Mechanism (CBAM)? CBAM is now in its definitive phase, and imports from January 2026 onwards create certificate cost exposure. That makes supplier-specific emissions data a cost driver, not just a reporting requirement.

Default values for the transitional period of 1 October 2023 and 31 December 2025 are no longer enough.

To report correctly, you need actual embedded emissions data at product and installation level, calculated using the EU methodology and prepared for verification. Conservative fallback approaches can overstate emissions, increasing the CBAM certificates you need to surrender and your total cost over time.

The challenge? Most suppliers still aren’t ready. DNV reports that importers are struggling to trace manufacturers, navigate CBAM’s complex methodology, and verify the credibility of supplied data.

At this stage, supply chain emissions data is the single biggest blocker to CBAM compliance.

In this article, we break down what data you need from suppliers, how to collect it, and how software tools can help you scale and streamline the process.

What do importers and suppliers need to report under CBAM?

Let’s take a look at the key requirements for both sides of the coin: importers and their suppliers.

Importers must report embedded emissions per installation, per product

Under CBAM, importers are required to declare the embedded CO₂ emissions of in-scope goods at product and installation level, based on where the goods were produced. This means reporting must be done at the level of each import declaration, not just once per product or supplier.

During the transitional period (ending 31 December 2025), reporting was done on a quarterly basis via the CBAM Transitional Registry. From 1 January 2026, reporting shifts to an annual CBAM declaration, with the first annual report due by 30 September 2027.

Suppliers must deliver data in line with the Monitoring & Reporting Regulation (MRR)

Manufacturers (operators) exporting CBAM-covered goods to the EU must provide emissions data calculated using the EU’s Monitoring and Reporting Regulation (MRR) methodology.

Data must be reported at installation level and appropriately allocated to products and process units. From 2026 onwards, reported emissions must be verified by an accredited third party.

Communication should follow the EU-provided template to ensure consistency and compatibility with importer submissions.

Why general ESG reports or lifecycle assessments (LCAs) aren’t enough

Generic ESG reports and scope 3 lifecycle assessments often rely on industry averages or high-level assumptions, which don’t meet CBAM’s requirements. 

What’s needed instead are granular, installation-level measurements with high accuracy. That means analysing the production methods, quantifying total emissions at the installation level, allocating those emissions across different processes, and linking them directly to the production of CBAM-covered goods.

CBAM requires data calculated using its approved methodology, based on the EU’s Monitoring and Reporting Regulation (MRR). 

This differs from standard LCA practices, which often cover broader lifecycle impacts and aren’t designed to align with regulatory reporting. As a result, LCAs and EPDs may support sustainability reporting, but they are not sufficient for CBAM compliance or for managing certificate exposure from 2026 imports.

How do you collect supplier emissions data for CBAM compliance?

Below is a clear, actionable process to ensure you obtain data aligned with CBAM requirements.

1. Identify who to contact

Start by tracing each product back to its production facility. From there, aim to connect with someone responsible for environmental data at the site level. This is typically someone in:

• Sustainability or climate reporting
• Environmental, Health, and Safety (EHS)
• Site operations or plant management
• Occasionally, quality assurance or technical product leads.

Avoid only sending requests to general sales contacts as they often lack access to installation-level emissions data.

2. Make the request simple, structured, and CBAM-ready

Provide suppliers with a clear, pre-formatted template (e.g. Excel or API form) aligned with the Annex IV format from the EU. Be specific about what’s required and include an example file or completed sample to guide them.

Here’s a breakdown of the minimum data points to request:

Also include: 

• A clear submission deadline 
• A named contact person on your team for questions
• A note explaining what happens if data is missing or late 

You can allow alternate file formats, but make it clear that these minimum fields must still be provided.

3. Follow up and escalate

Use a central dashboard to track outreach and responses. Set clear follow-up rules like sending one reminder, then escalating to procurement or legal teams if suppliers don’t respond. 

Be explicit about the consequences of missing data. Suppliers that cannot provide installation-level emissions data should be prioritised for support, third-party assistance, or replacement to avoid overstated emissions and increased certificate exposure for 2026 imports.

{{custom-cta}}

What data should importers request from suppliers for CBAM compliance? 

Ensure you’re asking for installation- and product-specific data that meets CBAM’s regulatory and verification requirements. Here’s what to include and how to vet it.

1. Embedded emissions by product and installation

Request emissions data that are:

• Tied explicitly to the production installation and product, not corporate averages
• Broken down into direct (Scope 1) and indirect (Scope 2) emissions
• Aligned to the reporting structure in CBAM’s official Annex IV template 

2. Production methods and input materials

Data must cover:

• Production processes and routes, including inputs and precursor materials
• Quantities and types of fuels, energy, and raw materials used
• System boundaries as defined in CBAM’s Annex II, Section 3 – e.g., cement kiln types, steel production method 
• Precursor emissions: include emissions embedded in input materials 

3. Emissions methodology used

Clarify how emissions were calculated:

• Tier level (Tier 1–4), as per MRR standards
• Emission factors and activity data sources
• Any approved fall-back or default values used (valid only for ≤ 20% of total emissions post-1 July 2024) 
• Explicit declaration of methodology, following Annex IV 

4. Whether the data has been verified

As of 1 January, 2026 is now mandatory for emissions data to be verified by an independent, accredited third party.

Collect verifier credentials and dates of verification and confirm if the data has been uploaded to the CBAM registry by the supplier.

{{cbam-calculator-injectable}}

What happens if a supplier doesn’t provide emissions data?

If a supplier does not provide the required installation-level emissions data, importers need a clear escalation and mitigation path. Default values are not a standard option and were only permitted in limited cases in the transitional period which ended 31 December 2025.

From 2026, if you cannot obtain supplier-specific data aligned with the EU methodology, you risk being unable to support a compliant CBAM declaration for those imports and may face enforcement and financial exposure.

Enforcement risks if data is missing in reports

From 2026 onwards, CBAM creates a direct financial and compliance obligation.

Importers must submit an accurate annual CBAM declaration and surrender the correct number of CBAM certificates for their imports. Importers who fail to surrender the correct number of CBAM certificates will face penalties of €100 per excess tonne, and only authorized declarants will be allowed to import CBAM-covered goods. 

Any unauthorized imports may be blocked or penalized more severely.

So, what are your options to drive compliance?

Before anything else, the priority should be to build a collaborative relationship with your suppliers. Many may be unfamiliar with CBAM requirements or lack the internal capacity to provide compliant data. 

Supporting them with clear guidance, training materials, or access to user-friendly software tools can go a long way in helping them report accurately, and on time.

Once a foundation of support is in place, it’s important to define a clear escalation plan for suppliers who remain unresponsive. 

This can include embedding CBAM data obligations into supplier contracts, setting expectations around timelines and quality, and, where useful, offering commercial incentives such as pricing tiers or preferred supplier status for those who comply. 

A structured follow-up process should also be in place: for example, after an initial request and one reminder, escalate the issue to your procurement or legal team with a clear consequence outlined.

Here’s a sample escalation message to send to unresponsive suppliers:

“Dear [Supplier],

This is a follow-up regarding the emissions data request shared on [date]. 

As part of EU CBAM compliance requirements, we must receive verified embedded emissions data for your product by [deadline]. 

If we do not receive a complete response, we will not be able to continue sourcing CBAM-regulated goods from your facility beyond this date. 

Please let us know immediately if you need support or clarification.”

How can software help you manage CBAM supplier data collection?

Managing CBAM compliance across a global supplier base is no small task, but software can simplify and scale the process. Instead of relying on scattered spreadsheets and email threads, digital tools allow you to upload your full supplier list and manage outreach from a single platform. 

Many solutions come with pre-built data request templates aligned with the EU’s Monitoring and Reporting Regulation (MRR), ensuring you’re asking for the right information in the right format. From there, the system can automatically send reminders to suppliers who haven’t responded and trigger escalation workflows based on custom rules. 

Once supplier data is received, it should be consolidated and validated in a structured format that integrates seamlessly into your annual CBAM reporting workflow. This reduces manual effort, cuts down the risk of missing or inconsistent data, and helps ensure compliance.

You can avoid repeated data requests by onboarding your suppliers once to provide emissions data per product, per installation. You can then manage ongoing reporting internally by mapping that emissions data against your actual order volumes over time.

This approach is far more scalable, especially for companies managing dozens or even hundreds of affected suppliers, and makes automation not just helpful, but essential to stay ahead of CBAM’s evolving requirements.

Preparing for CBAM? We can help

At Coolset, we make it easier for companies to manage sustainability and emissions reporting at scale, so you’re not scrambling to meet deadlines, but setting up systems that keep you ahead of the curve. 

Ready to simplify CBAM compliance? Get in touch to see how we can support your team.

FAQ – Supplier data and CBAM compliance

Let’s take a look at some common questions about supplier data and CBAM compliance.

1. What if my supplier doesn’t respond to data requests?

If a supplier does not provide installation-level emissions data aligned with the EU methodology, you risk being unable to support a compliant CBAM declaration. In practice, this means you must escalate, provide support, involve third parties, or switch suppliers to avoid inflated emissions and enforcement risk.

2. Can I still use default values after August 2024?

Default values are no longer a standard option in 2026. CBAM compliance now depends on supplier-specific emissions data calculated at installation level. Relying on fallback approaches can overstate emissions and increase the number of CBAM certificates you must surrender.

3. What counts as “verified” emissions data under CBAM?

During the transitional period (2023–2025), third-party verification is optional but encouraged. Verified emissions data is installation-level data calculated according to EU ETS/Monitoring and Reporting Regulation (MRR) standards, and supported by an independent, accredited verifier. 

4. Can my supplier send a lifecycle assessment (LCA) or EPD instead?

No. LCAs or Environmental Product Declarations (EPDs) typically use averaged or scope 3 emissions data and do not align with CBAM’s methodology. CBAM requires installation-specific, meter-based emissions data that follows the MRR. 

Submitting an LCA instead will simply not meet the compliance requirements.

5. Do I need third-party audits of supplier data?

Yes, third-party verification is mandatory as of 1 January, 2026. Importers should ensure supplier data and documentation are audit-ready well before annual declaration deadlines.

Related guides

• CBAM explained: Understand the mechanism and key importer obligations
  
  
• CBAM-covered goods: See which product categories fall under CBAM
  
  
• What is a CBAM certificate?: Learn how certificates are priced and managed

• How to calculate CBAM costs: Estimate your financial exposure using actual emissions data.