Why supplier emissions data is now critical for CBAM

Are you importing goods covered by the EU’s Carbon Border Adjustment Mechanism (CBAM)? As of 1 July 2024, you’re required to report the actual embedded emissions of your imports from non-EU manufacturers. Default values are no longer enough.

During the initial phase (1 October 2023 to 30 June 2024), importers could rely entirely on default values if verified supplier data wasn’t available. 

That flexibility has now been significantly reduced: default values are now only permitted for complex goods, and only for up to 20% of total reported emissions. This limit remains in place through the end of the transitional period, on 31 December 2025.

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 for each shipment of in-scope product, tied explicitly to the installation 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 phase (ending 31 December 2025), reporting is on a quarterly basis via the CBAM Transitional Registry, detailing both direct and indirect emissions per CN‑coded goods. As of 1 January 2026, reporting shifts to an annual basis, with the first report due by May 31, 2027.

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

Manufacturers (Operators) exporting to the EU must deliver emissions data that aligns with MRR/ETS standards. 

This means data must come from a verified monitoring plan, detailing emissions per installation, disaggregated per process unit. 

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 be useful for other purposes, but they’re not sufficient for CBAM compliance.

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. 

Clarify fallback procedures. For example, allowing default values only until July 31, 2024, and none thereafter.

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

Ask if emissions data were verified by an independent, accredited third party (mandatory from 2026; voluntary but encouraged during the transition) 

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

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

If suppliers fail to provide the necessary emissions data, importers need to follow a clear decision path. Up until 31 July 2024, it’s still possible to fall back on default values. But from 1 August 2024 onward, that option is limited to complex goods, covering up to 20% of total reported emissions. 

If no actual emissions data is available, the importer cannot submit a compliant CBAM declaration for those goods. This exposes the company to enforcement risks, even during the transitional phase.

Enforcement risks if data is missing in reports

Although importers don’t yet need to purchase CBAM certificates, the penalties for non-compliance are real. 

Between 2023 and the end of 2025, inaccurate or incomplete reports can result in fines ranging from €10 to €50 per tonne of unreported embedded emissions. 

From 2026, these risks escalate sharply. 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 quarterly 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 doesn’t respond, you can still use default values until 31 July 2024, and only for complex goods, and even then, only for up to 20% of total reported emissions. After that date, no data means no compliant declaration, and affected goods may become non-reportable under CBAM.

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

Default values can only be used after 1 August 2024 for complex goods and must not exceed 20% of reported emissions per product. For all other goods and percentages above that threshold, actual emissions data from the supplier is required.

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

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

From 2026 onwards, third-party verification becomes mandatory.

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?

Not yet, but soon. Third-party verification is not required during the transitional phase but will become mandatory starting 1 January 2026. Preparing now by working with verifiers or setting audit-ready documentation standards will ease that transition and reduce future compliance risks.

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.