The entry of the Carbon Adjustment Mechanism at the Border (CBAM) in its definitive period brings new challenges for companies that export products to the European Union. In addition to calculating embodied emissions, the ability to prove quality becomes important, the traceability and consistency of the data used.
In August of 2026, the European Commission has published new guidance on verification and accreditation in CBAM, detailing requirements for verification bodies and National Accreditation Bodies. The topic was also covered in the webinar “Verification and accreditation in CBAM for verifiers and National Accreditation Bodies”, promoted by IACBAM (International Association of CBAM Consultants and Carbon Markets) in 2 of September, with the participation of Luigi Villani, organization's CBAM specialist.
The new guidance therefore helps to clarify how this verification structure should work and what the responsibilities of the different actors involved will be..
How the verification will work
The European declarant may use emissions data from an installation located outside the European Union only after an independent body, accredited by a National Accreditation Body of the European Union, carry out verification of this data. To declare actual emissions in CBAM, the declarant must use data previously verified by that body.
The process is not limited to the final number of emissions. Among the elements analyzed are the monitoring plan, emission sources, activity data, fuels, electricity, heat, emission factors, precursors, measuring instruments, calculations and documents that support the information presented.
Verification also involves an analysis of the processes and controls used by the facility to generate and record data. The European Commission foresees, as a general rule, carrying out visits to facilities, allowing the verifier to evaluate production processes, emission sources, monitoring systems and available documentation.
In this way, the consistency between the recorded data and the processes actually carried out in the production unit becomes a relevant aspect of the assessment.
Accreditation is a fundamental step
The verifier's performance depends on a specific accreditation structure. Interested bodies need to demonstrate technical competence, independence and ability to apply consistent verification procedures.
The new guidance allows companies to carry out some steps of work while the accreditation process is still ongoing. Preliminary analyzes, Risk assessment and certain preparedness activities may proceed prior to accreditation, but the official verification report can only be issued by a duly accredited verifier registered in the system.
Thus, after accreditation, the verifier also needs to gain access to the CBAM Registry, platform used for interaction with facility operators, data analysis and issuance of verification reports.
The European Commission established September 2026 as the start of registration of accredited verifiers, while the first official verification reports could be issued from January 2027.
Traceability gains importance
For exporting companies, This structure reinforces the need to maintain a chain of information capable of demonstrating the origin of the data used to calculate emissions.
Fuel consumption records, electricity, raw materials and precursors need to be accompanied by evidence and controls that allow understanding how this information was obtained and incorporated into the final result.
This care also applies to data coming from suppliers. When embodied emissions rely on precursor information, the quality and traceability of these data directly influence the ability to demonstrate the reliability of the calculation.
The rule of 5% does not represent a margin of error
Another relevant point in the European Commission's guidance is the use of a limit of 5% as a materiality reference for certain embodied emissions calculations.
This reference, Nonetheless, should not be interpreted as a margin of tolerance. An inconsistency below 5% does not authorize the person responsible to simply disregard it. The verifier must evaluate the identified information and determine if there are any errors or non-conformities that need correction before completing the process.
This reinforces the importance of internal controls capable of identifying inconsistencies before data is submitted for verification..
Relationship with the EU ETS
Experience gained from verifying emissions in the European Union Emissions Trading System (EU ETS) can also contribute to the work at CBAM. Verifiers that already have certain accreditations can use part of their existing structure, but CBAM presents specific requirements.
Among them are the evaluation of the installation's monitoring plan, aspects related to embodied emissions, electricity, precursors and other specific information on products covered by the mechanism.
That is why, previous experience with emissions verification can make the process easier, but does not eliminate the need to meet CBAM's own skills and requirements.
The role of preparation
The new CBAM stage reinforces that companies' preparation should not only focus on preparing the annual calculation. It is important to evaluate the monitoring structure in advance, internal procedures, those responsible for the data, measurement systems and available documentation.
For Brazilian companies subject to the mechanism, This preparation can reduce difficulties during future verification and contribute to greater security in presenting information to the European market.
The European Commission also published, in August, a series of specific guidelines for operators of installations located outside the European Union, including general documents and materials aimed at the different sectors covered by CBAM.
A new scenario for exporters
With the advancement of the CBAM verification and registration infrastructure, the reliability of the data starts to occupy an even more important position in the implementation of the mechanism.
For Brazilian exporters, Keeping up with these changes means not only understanding regulatory requirements, but also strengthen internal monitoring processes, documentation and traceability.
In this context, Companies that structure their data and procedures in advance will be better prepared to demonstrate their emissions and respond to new requirements associated with access to the European market.
Preparation is also a strategy
With the advancement of CBAM requirements, structuring reliable emissions data and ensuring their traceability becomes an important part of the preparation of companies operating in international trade.
In this context, biO3 supports organizations in managing greenhouse gas emissions, in structuring environmental data and adapting to sustainability and market requirements, helping to keep information organized, documented and aligned with applicable requirements.
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