UBA Report on CBAM: What Verifiers Expect

UBA publishes its research report on origin verification under CBAM

In April 2026, the German Environment Agency (Umweltbundesamt, UBA) published the research report "Identification of possibilities to prove the origin of a product from a specific installation" (Climate Change 27/2026, prepared by Deloitte, adelphi and aimplifin). The report addresses the question of how the specific manufacturing installation of an imported product can be evidenced under CBAM, and it analyses sector-specific verification challenges for cement, fertilisers, steel and aluminium.

With the regular CBAM phase having begun on 1 January 2026, this question has now become operational. Emissions from the 2026 reporting year must be declared and verified for the first time in 2027.

No single document is sufficient to prove the installation of origin

The report assesses two categories of documents, trade and customs documents and internal business records, against four criteria. These are coverage, accuracy of information, tamper-resistance and reliability. The result is unambiguous. No single document can reliably establish the origin of a product at the installation level.

Certificates of origin (COO) and customs declarations identify the country of manufacture but not the installation. A manufacturer's own declaration is not robust because it lacks independent verification. Smart-meter data are highly accurate and tamper-resistant, but they have only limited coverage globally. Even facility certifications such as ISO confirm management systems and not the batch from which a specific product comes.

For importers, this means that a single document will not pass the verification process. Verifiers will require a coordinated set of evidence.

Four documents verifiers will want to see in combination

From this assessment, the report derives a concrete document set. Verifiers should be able to rely on the product's certificate of origin, the delivery note with plant address and company details, supporting production records and direct access to the manufacturer's ERP system.

The certificate of origin establishes the country. The delivery note documents the outbound movement from a specific plant and is more robust than purely internal records because it is exchanged with external parties. Production records, ideally as ERP extracts, allow cross-checking at batch and quantity level. Only direct system access lets verifiers test on a sample basis whether the delivery note matches the underlying data.

The delivery note thereby becomes the central link between the customs document and the installation data. It must specify plant, company and quantities precisely enough to hold up against ERP records.

Direct ERP access replaces the physical on-site visit

One of the report's most far-reaching recommendations concerns verification methodology. Instead of physical site visits, the report proposes virtual site visits via direct ERP access. Verifiers use this approach to check core data points such as installation, batch, dates and quantities against the delivery notes and, where possible, against customs declarations.

Where no ERP system exists, manual documentation must be collected and reviewed with corresponding rigour. All evidence should ideally be submitted via the European Commission's standardised communication template for embedded emissions.

Operationally, this changes what is expected from suppliers. Manufacturers outside the EU will need to provide either ERP extracts or a controlled system access at the time of verification. Importers should clarify this contractually early on, particularly with suppliers in regions where ERP infrastructure is not widespread.

Sector-specific risks in cement, fertilisers, steel and aluminium

The second part of the report addresses the verification of complex goods across the four CBAM sectors. In cement production, a clean separation of emissions between clinker production and cement grinding is central, particularly where equipment is shared between processes.

In fertilisers, the use of multiple precursors and the measurement of nitrous oxide emissions via CEMS are obstacles, since the corresponding instrumentation is often missing at smaller producers. In the steel sector, verification is complicated by the fact that upstream installations are not required to have their data verified externally before passing them on to the producer of the complex good, which increases the depth of audit work at the final manufacturer.

In aluminium, the distinction between pre- and post-consumer scrap is the critical point because post-consumer scrap is treated as zero-emission under CBAM. Here the report recommends additional evidence, including delivery notes with scrap classification according to DIN EN 13920 or ISRI, supplier declarations under ISO 14021 and recycled-content certificates (ASI Chain of Custody, SCS Recycled Content).

Importers of aluminium-containing products should specifically request these documents from their suppliers.

Outlook

The report itself is not legally binding. Its recommendations are, however, among the most detailed practical pointers currently available to importers and verifiers in preparation for the first regular verification rounds. Those rounds will take place in 2027, when importers submit their first regular CBAM declaration with verified emissions data for the 2026 reporting year.

Two developments remain to be watched. First, how the recommended practice of virtual ERP audits is reflected in the accreditations of verifiers. Second, how the European Commission and national competent authorities, such as the German Emissions Trading Authority (DEHSt) in Germany, translate the UBA's recommendations into operational guidance.

Importers should use the remaining months to assess their supplier portfolio for ERP availability, granularity of delivery notes and sector-specific evidence.

Support

If you would like to discuss how the recommendations of the UBA report affect your CBAM verification strategy, including which documents you should now request from your suppliers and how access to ERP data can be addressed contractually, please feel free to write to me at helge@kolum.earth.