Short answer: the Regulation has no "CBAM document" that an authority issues to a producer. A buyer who asks for one usually wants your installation's emissions data and an accredited verifier's verification report. You prepare the data, the verifier issues the report, and the authorised CBAM declarant in the EU files the annual declaration.
There is no office where you apply for a "CBAM document". The Carbon Border Adjustment Mechanism (CBAM) splits the work between three parties, and each prepares a different document. This article follows Regulation (EU) 2023/956 and the regulations adopted under it. The information was read from the sources on 13 October 2026.
Is there a CBAM document, and who issues it?
The Regulation names specific documents: the CBAM declaration (2023/956 Art. 6), the operator's emissions report and its summary (2025/2547 Art. 10), the verification report (2023/956 Annex VI) and the CBAM certificate (Art. 3(24)). None is a "certificate of compliance" issued to a producer outside the EU.
The only official record on the producer's side is optional: at the operator's request, the Commission registers the operator and its installation in the CBAM registry for five years (2023/956 Art. 10(1), 10(3)). That is a registry entry, not a document approving your product's emissions.
What does a buyer mean by "CBAM document"?
The buyer's declaration states the total embedded emissions of the goods. Where those are based on actual emissions they must be verified, and copies of the verification reports go into the declaration (2023/956 Art. 6(2)(b), 6(2)(d)). So two things are expected from you:
- Installation emissions data: the summary of the operator's emissions report. It shows the specific embedded emissions of each product and the share for which default values were used (2025/2547 Annex IV, point 1.2). The Commission's Excel file, the CBAM communication template for installations, is a tool for passing this summary to the declarant.
- The verification report: issued by an accredited verifier (2023/956 Art. 8(1), Annex VI).
How the data is collected and calculated is covered in CBAM report for producers.
Who prepares which document?
| Document | Prepared by | Source |
|---|---|---|
| Operator's emissions report and summary | The operator of the installation, that is, the producer. In English. | 2025/2547 Art. 10(1), 10(4) |
| Verification report | The accredited verifier, on the Commission's electronic template in the CBAM registry. | 2023/956 Art. 8(1); 2025/2546 Art. 6 |
| Annual CBAM declaration | The authorised CBAM declarant in the EU. | 2023/956 Art. 6(1) |
| CBAM certificate | Nobody: a Member State sells it, the authorised declarant buys it. | 2023/956 Art. 20(1) |
Ensuring verification is the declarant's obligation (2023/956 Art. 8(1)), but what gets verified is your installation's data. A registered operator has its own emissions verified and may disclose the verified information to a declarant, who may use it to meet that obligation (2023/956 Art. 10(5)(b), 10(7), 8(2)).
Who needs authorised CBAM declarant status?
The importing side, not the producer. Goods in scope may be imported into the customs territory of the Union only by an authorised CBAM declarant (2023/956 Art. 4). An importer established in a Member State applies for the status before importing (Art. 5(1)). Where the importer is not established in a Member State, the indirect customs representative obtains the status (Art. 5(2)).
The competent authority of the Member State where the applicant is established grants the status (Art. 17(1)). The criteria include being established in that Member State and holding an EORI number (Art. 17(2)(c), 17(2)(d)). A producer outside the EU therefore cannot obtain the status in its own name.
An importer whose imports in a calendar year do not exceed 50 tonnes of net mass in total is exempt (Art. 2a(1), Annex VII), so small buyers may not ask you for data. The exemption does not apply to electricity or hydrogen (Art. 2a(4)).
What is CBAM verification, and where is a verifier accredited?
A verifier is a legal person accredited by a national accreditation body at the time it issues a verification report (2025/2551 Art. 1(1)). That body is appointed by each EU Member State (2023/956 Art. 3(32)) and grants the accreditation (Art. 18(2)).
An applicant not established in a Member State requests accreditation from the national accreditation body of any Member State that provides the service (2025/2551 Art. 3(2)). A request covers one or more CBAM activity groups (Art. 3(3)). When you choose a verifier, check that the accreditation is valid and that its scope includes your product group.
Accredited verifiers request registration in the CBAM registry within two months of accreditation, but not before 1 September 2026 (2023/956 Art. 10a(1)).
What is in a verification report?
The minimum content is listed in point 2 of Annex VI to 2023/956. It includes:
- The installation, the operator and the reporting period.
- The verifier's name, accreditation number and accreditation body.
- The date of the installation visit, or the reasons for not carrying one out.
- Quantities of each type of goods produced and the installation's direct emissions.
- How emissions are attributed to the goods and, for goods made with precursors, the precursors' quantities and emissions.
- The verifier's statement that it finds, with reasonable assurance, that the report is free of material misstatements and non-conformities.
A misstatement is "material" above 5% of the total specific embedded emissions or 5% of the total specific embedded free allocation, per tonne of goods by CN code (2025/2546 Art. 5(1)). Installation visits are mandatory. A virtual visit is possible only if a physical visit took place in the preceding reporting period and the other conditions are met (2023/956 Annex VI, point 1(c); 2025/2546 Art. 3(1)).
Is a CBAM document the same as a CBAM certificate?
No. A CBAM certificate is an electronic certificate corresponding to one tonne of CO2e of embedded emissions (2023/956 Art. 3(24)). From 1 February 2027 Member States sell certificates on a common central platform to authorised declarants (Art. 20(1)). By 30 September each year the declarant surrenders the number that corresponds to the emissions it declared (Art. 22(1)). The importer in the EU buys it. A producer does not buy one or apply for one. For more, see CBAM certificate price.
When will your buyer ask for the documents?
The authorised declarant submits the declaration for the preceding calendar year by 30 September, for the first time in 2027 for 2026 (2023/956 Art. 6(1)). The reporting period is the calendar year, and for goods imported in 2026 it is 2026 (2025/2547 Art. 7(1)). If actual emissions are used, your report has to be prepared and verified before that date.
What happens if you do not provide data?
Embedded emissions are determined from actual emissions or by reference to default values (2023/956 Art. 7(2)). With no data from you, your buyer is left with default values: the average emission intensity of the exporting country for that product, increased by a mark-up (2023/956 Annex IV, point 4.1). Default values need no verification (Art. 8(1)), but the mark-up raises the declared emissions and the number of certificates that follows.
A declarant that surrenders too few certificates because of incorrect information from an operator or a verifier is liable for a penalty. The competent authority may reduce it, but the outstanding certificates must still be surrendered (2023/956 Art. 26(1a), 26(3)).
The Registamp CBAM module keeps your installation data with its evidence, calculates embedded emissions per product and prepares the summary for your buyer and the file for your verifier. See the CBAM module page.
This article is general information, not legal advice. For your own case, refer to the text of the Regulation and, where needed, to a specialist.
Sources
- Regulation (EU) 2023/956, CBAM (consolidated text of 20 October 2025): eur-lex.europa.eu/eli/reg/2023/956/oj
- Implementing Regulation (EU) 2025/2546, application of the verification principles: eur-lex.europa.eu/eli/reg_impl/2025/2546/oj
- Implementing Regulation (EU) 2025/2547, methods for calculating embedded emissions: eur-lex.europa.eu/eli/reg_impl/2025/2547/oj
- Delegated Regulation (EU) 2025/2551, accreditation of verifiers: eur-lex.europa.eu/eli/reg_del/2025/2551/oj