To let its EU importer declare actual emissions, a non-EU supplier provides an installation-level data pack. It holds the installation identity, production route, activity data and specific embedded emissions per tonne, direct plus indirect where the good counts both, together with verification status. Providing it is the supplier’s choice. Without it, the importer can only declare the marked-up default value.
The five fields of a CBAM supplier data pack
A CBAM data pack sent from a non-EU producer to its EU importer collapses into five fields. Each field feeds the importer’s CBAM declaration and traces a per-tonne emissions figure back to the installation that made the goods.
| Field | What the supplier reports |
|---|---|
| Installation identity | The producing installation’s name, location, operator and process boundary, so every figure ties to a known source. |
| Production route | The manufacturing route or technology, which largely sets the emissions profile. |
| Activity data | Production output and the fuel and energy inputs behind the period’s emissions. |
| Specific embedded emissions | Direct emissions per tonne of product, plus indirect emissions where the good counts both. The indirect figure uses the default electricity factor unless the conditions in Annex IV to Regulation (EU) 2023/956 for actual values are met. |
| Verification status | Whether an accredited verifier has verified the figures. Without a verification report the importer cannot declare them as actual emissions. |
Direct only, or direct plus indirect
How many emissions lines the pack carries depends on the product group. Two of the six covered groups price indirect emissions alongside direct ones; the rest price direct emissions only.
| Emissions counted | Covered groups |
|---|---|
| Direct plus indirect | Cement, fertilisers |
| Direct only | Iron and steel (except agglomerated iron ore, CN 2601 12 00), aluminium, hydrogen, electricity |
So the indirect line, mainly purchased electricity, is needed only where the good sits in the direct-plus-indirect group. For a direct-only good the pack reports direct process and fuel emissions and leaves indirect out.
From default values to actual data
Under the definitive rules the importer may declare the supplier’s actual emissions or country-of-origin default values, which carry a mark-up. A complex good may also mix the two, with default values for one or more precursors, under Article 15 of Implementing Regulation (EU) 2025/2547. The direct figure is built through a calculation-based or a measurement-based approach, and declared actual emissions must be verified by a verifier accredited under Commission Delegated Regulation (EU) 2025/2551.
GreenSutra builds the supplier data pack, calculating embedded emissions and readying installation figures for that independent verification. The CBAM discovery session maps the data gap between supplier and importer, the CBAM guide sets out the reporting timeline, and the CBAM consulting service prepares the pack for verification by an accredited verifier.
Sources: Regulation (EU) 2023/956 · Implementing Regulation (EU) 2025/2621 · European Commission CBAM
Related: CBAM Monitoring Plan in 2026: Template and What It Must Contain.