The levy period of the EU Carbon Border Adjustment Mechanism (CBAM) will start in January 2026. The relevant draft regulations on the verification system issued by the EU have clarified the core rules for carbon data verification during the levy period.
This rule is directly related to the order compliance and market access of enterprises exporting to the EU. For exporters and raw material suppliers, there is no need to get bogged down in complex details. By grasping the core logic of verification and making basic preparations, you can effectively avoid trade risks and smoothly access the EU market.

Whether CBAM carbon verification is required depends on the carbon emission calculation method chosen by the enterprise, with clear and easy-to-judge rules:
• If an enterprise chooses to calculate product carbon emissions based on its own "actual production data", it must confirm the authenticity and accuracy of the data through third-party verification. This is a basic requirement for declaring actual measured data and a key to ensuring compliance.
• If an enterprise directly uses the "default values" provided by the EU to calculate carbon emissions, no additional verification is required, and the declaration process can be completed directly based on the default data.
Enterprises can flexibly choose the calculation method based on their own data management capabilities. Actual measured data is usually more in line with the enterprise's actual emission situation, helping to avoid potential cost overestimation caused by default values. Enterprises with conditions can give priority to this option.

The core goal of CBAM verification is to ensure the accuracy of carbon emission calculation and avoid omissions or miscalculations. It mainly focuses on two core dimensions. Enterprises do not need to prepare complicated materials; they only need to focus on the following directions to complete basic work:
• Clarify production boundaries: Ensure that the factory's production scope, production lines involving CBAM products, and related emission sources (such as production equipment, energy-consuming facilities, etc.) are clearly defined, without missing key emission links.
• Standardize data allocation: For the consumption data of purchased energy, raw materials, etc., allocate them to the production processes of CBAM products in accordance with reasonable principles to ensure accurate data attribution and no confusion.
Enterprises need to retain basic materials such as production accounts, energy consumption records, and emission source lists in advance, and establish a simple and traceable data collection mechanism to meet the basic requirements of verification.

For precursor materials (relevant raw materials) within the scope of CBAM regulation, the verification requirements are consistent with those of the main products, and the core judgment basis is still the calculation method:
• If "actual values" are used to calculate the carbon emissions of precursor materials, it is necessary to obtain third-party verification certificates for the materials to ensure the integrity and compliance of the supply chain data chain.
• If compliant verification certificates cannot be provided, EU official default values must be used for calculation, which may lead to higher overall carbon emission calculation results.
• If the default values for precursor materials provided by the EU are used directly, no additional verification documents need to be prepared, and they can be used directly for declaration.
Enterprises only need to communicate and coordinate with upstream suppliers in advance to clarify the carbon emission calculation method of precursor materials, ensuring that the required certification documents are complete or the use of default values is compliant. There is no need to overthink the detailed processes.

1.Clarify the calculation method: Based on your own data recording capabilities, determine in advance whether to use actual measured data or default values to avoid compliance delays caused by temporary adjustments.
2.Organize basic materials: Sort out key data records according to the production process to ensure that information such as emission sources, energy consumption, and data allocation is traceable and verifiable.
3.Connect with the supply chain: Collaborate with upstream and downstream partners to clarify the verification requirements for precursor materials, ensuring consistent data standards and compliance across the entire chain.
4.Follow rule updates: Focus on tracking key policy adjustments issued by EU authorities. There is no need to conduct in-depth research on complex details; just optimize your own compliance plan in a timely manner.

Although CBAM verification rules are clear, enterprises may still face issues such as unclear data organization and inadequate understanding of verification requirements when advancing alone.
Based on in-depth interpretation of CBAM verification rules and industry practice, SKYCO2 provides compliance services tailored to enterprises' actual needs:
• Assist in clarifying the calculation method and verification trigger conditions, and provide adaptive suggestions based on the enterprise's actual situation to avoid deviations in compliance direction.
• Guide the organization of basic materials such as production boundaries and emission source lists, provide data collection and recording templates, and establish a simple and operable data management mechanism.
• Assist in connecting with upstream suppliers, clarify the relevant requirements for precursor material verification, and promote the unification of supply chain data standards.
• Real-time track the dynamics of EU CBAM verification rules, synchronize key adjustment content in a timely manner, and provide suggestions for optimizing compliance plans.
If your enterprise is troubled by CBAM verification preparations or wants to proactively layout compliance for the levy period, please feel free to contact SKYCO2.
We will use pragmatic and concise services to help you lay a solid foundation for compliance, calmly meet the challenges of the 2026 CBAM levy period, and firmly seize EU green trade opportunities.