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How to collect CBAM supplier emissions data

The embedded-emissions number that drives your CBAM cost comes from your supplier. Here is how to request it, track it, and handle the gaps when suppliers go quiet.

Reviewed 30 June 2026 · Written by Igor Dabić, TheLoomLabs

Under CBAM, the cost you carry is driven by the embedded emissions of the goods you import — and that figure originates with your supplier, the producer outside the EU. For most importers this is the single hardest part of the regime, because it depends on people you do not control answering questions they may never have been asked. This is a practical process for getting it done.

What you are actually asking for

You need, per product and ideally per production facility:

  • Direct emissions from the production process.
  • Indirect emissions from electricity used in production (this matters enormously for aluminium).
  • The production route or method (for steel, blast furnace versus electric-arc furnace changes the number dramatically).
  • The basis of the figures — measured, calculated, or estimated — and any third-party verification.

Vague, whole-company averages are not enough. CBAM expects emissions tied to the specific goods you imported.

A request process that actually works

A one-off email rarely produces usable data. Treat it as a tracked workflow:

  1. Send a structured request. Use a consistent template with clearly labelled fields and units, not a free-text ask. The easier you make it to fill in, the more likely you get something back.
  2. Explain why. Many suppliers respond better when they understand CBAM affects whether EU buyers keep ordering from them.
  3. Set a deadline and log it. Record what you asked, when, and what is outstanding.
  4. Chase on a cadence. First reminder, second reminder, escalation to the commercial relationship. Track each touch.
  5. Validate what comes back. Check units, completeness, and whether the figures are plausible for that production route before you rely on them.
The real deliverable is the tracker, not the email. What protects you at declaration time is a living record of every request, response, partial answer, and missing field — across every covered shipment — so nothing falls through the cracks of an inbox.

When the data doesn’t come

Suppliers go quiet. CBAM allows the use of default values when actual supplier data is unavailable, but defaults are deliberately conservative — they generally cost you more than accurate, evidenced figures would. So the goal is to maximise real data and fall back to defaults only where you must, with the gap clearly logged.

What you never want is a silent gap: a shipment with no data and no record of having tried. At review time, “we requested this three times and the supplier did not respond, so we applied the default value” is a defensible position. A blank is not.

Keeping it audit-ready

Every figure that ends up in your annual CBAM declaration — due 30 September 2027 for 2026 imports (see deadlines) — should trace back to either a supplier response or a logged decision to use a default. That traceable trail is the core of a clean evidence archive.

Where CarbonBorder Desk fits

Chasing suppliers is exactly the work that falls between procurement, customs, and finance and gets dropped. We run it as an operational process: prepare the request templates, send and track them, chase on a cadence, maintain the missing-field log, and keep every response filed against the right shipment. We do not give legal or customs advice — we make sure the data behind your declaration is collected and evidenced. It usually starts with a pilot diagnostic.

Not legal or customs advice. This page is general operational information about the EU Carbon Border Adjustment Mechanism, accurate to the review date above. CBAM rules and figures change — always confirm current obligations with official EU guidance and your national competent authority. CarbonBorder Desk prepares documents and evidence; it does not file declarations or give legal opinions.