Evidence that withstands scrutiny
Evidence that withstands scrutiny
The most consequential CBAM decision a non-EU operator makes is whether its declaration rests on actual monitored data or on default values. It is frequently made by omission — the data was not collected during the year, so defaults are the only remaining option. This note sets out what the rules permit and what each path requires.
Implementing Regulation (EU) 2025/2547 sets out the methods for calculating emissions embedded in goods, covering direct emissions, indirect emissions from electricity consumption, and the embedded emissions of precursor materials. Its Article 11 restricts the use of default values to situations where actual values cannot be determined; Article 12 permits alternative default values only where specific conditions are satisfied and after formal adoption. Source: EUR-Lex — Implementing Regulation (EU) 2025/2547, checked 01 September 2026.
The regulation also allows the two to be combined: Article 15 permits actual emissions to be calculated for a complex good while default values are used for one or more of its precursors. That is a legitimate, documented mixture — not a licence to fall back wherever the data is inconvenient.
A rough internal calculation, even at low precision, tells you which side of the default you sit on. This costs days, not months, and it determines everything that follows.
Week 1Multiply the difference between your intensity and the applicable default by the tonnage exported to the EU. That figure is the annual value of the monitoring investment — and it is usually the number that settles the internal argument.
The business caseActual values are unavailable retrospectively. A plan adopted mid-year covers only the part of the year that follows it, and the verifier will say so.
Before 1 JanuaryYour suppliers hold data you need and have no obligation to give it to you. That obligation is created in the purchase contract, not in a request email during the verification.
Supply chainActual for the good, defaults for named precursors, is permitted under Article 15 — but it must be documented as a decision with its reason, not discovered by the verifier as a gap.
DocumentationEnergy Up International is a validation and verification body. We can examine a monitoring plan, an emissions calculation and an evidence file, and we can tell you whether they are verifiable. We cannot design your monitoring, calculate your emissions, or select your values — doing so would disqualify us from verifying the result.
Preparation work of that kind is available from advisory firms, including Extreme Energy Solutions within this group, which operates as a separate entity. Where a client uses that route, the verification is performed by a different body with no involvement in the preparation, or by an independent function with no conflict of interest.
Accredited CBAM verification is not yet something we offer. Our application has been formally accepted by ACCREDIA under ref. DC26PRT0296 and the assessment is underway. Until it is granted, we say so on every page where CBAM appears.
Editorial note. Author and technical review above are editorial functions. They are separate from the independent technical review and the decision functions required under ISO/IEC 17029:2019, which apply to validation and verification engagements and not to published articles. Nothing on this page is advice on a specific engagement, and nothing here extends or replaces the accreditation records.
Tell us what must be relied on, who will rely on it and by what date. We will confirm the correct programme, evidence requirement and responsible entity — or tell you it is outside our scope.
