Verification of declared embedded emissions generated during production of goods covered by the EU carbon border adjustment mechanism (CBAM) will not be possible during 2026, as declarants need data for the whole reporting year, German emissions trading authority DEHSt has told Argus.
Provisional — such as quarterly — verification is not provided for in CBAM regulations, and for CBAM compliance based on individual data, "only the complete, verified emissions report for the respective calendar year is valid", a DEHSt spokesperson said.
A CBAM declarant is the entity responsible for importing CBAM goods into the EU and for fulfilling CBAM obligations. CBAM certificates will start circulating from February 2027 and declarants are required to surrender certificates for 2026 emissions by 30 September 2027. They can verify data from the start of 2027 until this deadline.
There is some debate over whether verification for 2026 can and should be done on a quarterly basis or for all of 2026. There are also concerns over national authorities' capacity to have enough certifiers accredited in time for all declarants to meet the 30 September 2027 deadline.
The accreditation timeline depends, among other things, on when authorities open the application process and when certifiers actually apply — or, in the case of existing certifiers, when they apply for accreditation extensions within the framework of the EU emissions trading scheme (ETS), DEHSt said.
German accreditation body DAkkS has told Argus it aims to open the application process this quarter.
"EU conformity assessment bodies, [the technical term for verifiers], will receive timely notification regarding the start of the application process," DAkkS said, adding that certain CBAM requirements — including those related to business with non-EU countries and carbon pricing — still needed reviewing.
While the duration of the accreditation process varies, "the current plan is to complete the corresponding accreditation extension [of verifiers that already certify other aspects of EU ETS] by the end of 2026," DAkkS said. Companies accredited by the German body will be listed on its website.
One market source said they were advising suppliers to seek verification from bodies already involved in verifying EU ETS emissions, adding that it is possible to have a pre-verification report within four to six weeks from such companies.
Verifiers are currently offering pre-verification services, which could fast-track formal verification in 2027. Some importers of CBAM goods with strong ties to producers are closing deals based on actual producer data. But even with a trusted producer, there could be discrepancies between their methodology and a verification body's, the same market source told Argus. Such differences could become significant financial burdens for importers once verification is complete in 2027.
Default values are punitive, and many importers would be priced out of the market when using these over actual data.
"Pricing decisions should be based on a careful risk assessment that considers the probability of receiving actual data and their magnitude. For internal budgeting purposes, however, importers should also account for a scenario in which they are required to declare default values in 2027, to mitigate the risk of financial distress," CBAM consultancy Carboneer's chief executive, Hendrik Schuldt, told Argus.
