On May 7, 2026, the European Commission held an official online seminar to deeply interpret the core compliance rules for the full implementation phase of CBAM, and provide official explanations on key regulatory provisions such as Implementing Regulation (EU) 2025/2547.

As a critical year for the full rollout of CBAM, this meeting clarified that the mandatory monitoring plan is the primary prerequisite for enterprise compliance and the core focus of this rule update.

Based on the official content of this meeting, SKYCO2 breaks down the four core upgrades to CBAM calculation rules and the mandatory requirements for monitoring plans, sorts out compliance key points for global export enterprises, and helps enterprises adapt to the new rules, simplify declaration processes, and effectively control carbon tariff costs.

I. Four Core Upgrades to CBAM Calculation Rules

In the full implementation phase, CBAM comprehensively optimizes calculation standards around four dimensions: functional units, production processes, system boundaries, and precursor product management. It clarifies emission reporting and monitoring verification specifications for enterprises in third countries, and enterprises need to adjust their internal monitoring and management priorities accordingly:

Introduce unified functional units to achieve standardized accounting across enterprises
                  In the full implementation phase, standardized functional units replace the general product classification of the transition period: conventional goods such as steel, aluminum, cement, and hydrogen uniformly use tonnes as the functional unit; electricity uses megawatt-hours (MWh) as the unit; fertilizers prioritize the auxiliary unit of measurement under the CN code (such as nitrogen content), and use tonnes when there is no auxiliary unit. Enterprises must strictly use unified functional units to organize data in their monitoring plans to ensure compliance with accounting calibers.

Redefine production processes with CN codes as the sole basis
                  In the full implementation phase, enterprises are prohibited from independently splitting production processes under the same CN code. If products with different CN codes differ only in size/shape and use the same precursors, they must be defined as a single multi-functional production process for accounting; if different production routes (such as electric arc furnace vs converter) in the same facility produce goods with the same CN code, emissions must be calculated separately for each route, and weighted averages cannot be used.

Redefine production processes with CN codes as the sole basis

Delimit industry-specific system boundaries to simplify accounting for steel and aluminum industries
The system boundaries for steel and aluminum products only cover direct emissions, explicitly excluding emissions from downstream processing links such as cutting, welding, electroplating, and finishing, aligning with the scope of the EU ETS; cement and fertilizers need to account for both direct emissions and indirect emissions from electricity consumption; all complex goods must calculate the embedded emissions of all relevant precursors.

Optimize precursor management to improve declaration flexibility
The new rules cancel the fixed precursor list, and precursors originating from the EU and countries listed in Annex III are uniformly recognized as zero emissions; enterprises are allowed to use a combination of actual values for their own processes and default values for precursors when calculating; however, unverified data provided by suppliers cannot be used as actual values and must be replaced with EU default values.

This meeting and Implementing Regulation (EU) 2025/2547 clarified that compliance in the full implementation phase of CBAM is based on the mandatory monitoring plan. Enterprises must build a complete end-to-end system for data monitoring, recording, and reporting to ensure that declared data is monitorable, traceable, and verifiable.

Different from the "Monitoring Methodology Document (MMD)" in the transition period, the "Monitoring Plan (MP)" implemented from 2026 is a mandatory, formatted, and verifiable official document, serving as the core connecting carrier between annual emission reports and third-party verification. The EU does not provide a unified template, but requires that it must fully cover 22 core elements such as product distribution, monitoring methods, energy consumption data, waste gas control, and data quality assurance. Missing elements will directly result in a determination of non-compliant declaration.

Meanwhile, a tiered submission mechanism for emission reports is implemented in the full implementation phase: the full version of the report is exclusively for third-party audit and verification; the simplified version can delete sensitive information such as production process descriptions and be provided to EU importers for CBAM annual declarations; when declaring the electricity sector using actual data, an additional special customized report is required.

Currently, full compliance with CBAM has entered a countdown period, and enterprises need to complete the following work as soon as possible:
● Comprehensively sort out their own CBAM-controlled products and corresponding CN codes, and lock in the monitoring scope and core emission nodes
● Start the preparation of compliant monitoring plans as soon as possible to ensure full coverage of the 22 core elements without omissions
● Build a complete data monitoring ledger and quality control system to achieve full traceability of emission data
● Promote upstream suppliers to complete third-party verification of precursor emission data to avoid using high-cost default values
● Leverage the services of professional institutions to avoid policy understanding deviations and reduce the difficulty of compliance practice

SKYCO2 has been deeply engaged in the dual-carbon digital field for more than ten years. In response to the pain points faced by enterprises such as difficulty in building monitoring systems, unclear implementation standards for the 22 elements, and insufficient practical experience in data collection, it has launched a CBAM-exclusive MRV compliance system construction service.

We provide two core services: First, customize and compile a compliant "CBAM Monitoring Plan" in strict accordance with EU regulations, covering four links: installation and process definition, emission source identification, monitoring method grading, and data flow responsibility division; second, build a full-dimensional data quality control and internal audit system, realize automatic data collection and tamper-proof management through digital tools, and establish standardized quality control processes and a normalized internal audit mechanism.

WRelying on the four core advantages of accurate compliance benchmarking, systematic closed-loop implementation, digital cost reduction and efficiency improvement, and professional customized guarantee, SKYCO2 will help enterprises efficiently complete CBAM compliance construction, successfully pass EU verification, and stably expand the EU market.