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IMPORTER PERSPECTIVE

CBAM from the EU Importer's Perspective: What to Require from Your Supplier

If you're an EU-based importer, most of your CBAM obligations hinge on the data you get from your supplier. This guide covers what you should be asking your supplier for.

Why You Need to Request Data from Your Supplier

As an EU importer, when you bring in CBAM-covered products, the ultimate responsibility rests largely with you. The data your supplier provides — or fails to provide — directly determines both your reporting burden and the certificate cost you'll pay.

That's why supplier selection and supplier data-sharing processes are no longer purely commercial matters — they're now compliance matters too.

The Core Data You Should Request from Your Supplier

At a minimum, you should be requesting: product-level embedded emissions data (ideally actual values), information on the production method and technology used, documentation on the energy source, and whether a monitoring plan is already in place.

Your supplier's ability to provide this data consistently and reliably is also a meaningful signal of how sustainable your long-term supply relationship will be.

Why You Should Request Verification Documentation

Having your supplier's emissions data verified by an accredited verifier makes your own reporting process easier and increases the likelihood that data will be accepted by the EU.

Working with a supplier who provides unverified data can leave you stuck using default values — and the higher cost that comes with them.

The Cost Advantage of Requiring Actual Values

A supplier that can provide verified actual values translates into a direct cost advantage for you: typically a lower emissions figure than default values, and therefore fewer certificates needed.

This is also becoming a real differentiator in supplier selection — working with lower-carbon suppliers that have strong verification infrastructure delivers a competitive edge.

How to Manage Your Supplier Relationship Under CBAM

It's worth clearly stating your CBAM data requirements to your suppliers, and where possible, making them a contractual obligation. Early, transparent communication keeps both you and your supplier from being caught unprepared when the reporting period arrives.

We cover how your supplier's data verification process works in our verification process guide, and the cost gap between actual and default values in our comparison guide.

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