Ten CBAM guidance documents published: what the Commission expects for the first verification
CBAM Weekly – Issue 108
The Commission publishes ten guidance documents
On 14 August, the European Commission published ten guidance documents for the definitive period of CBAM. They are aimed at operators of installations outside the EU, at authorised CBAM declarants, and at verifiers. The package explains how embedded emissions should be calculated, documented, and evidenced for verification. For importing companies, it is the clearest signal yet of the data quality the Commission expects in the first full compliance round.
Where the four general guides apply the leverage
Guidance No. 1 introduces the core concepts, namely the compliance cycle, roles, deadlines, and exemptions. No. 2 is a quick guide for operators outside the EU. The real weight sits with No. 3 and No. 4. No. 3 sets out the methods for calculating embedded emissions, meaning how a producer monitors and reports its values. No. 4 explains how the number of certificates to be surrendered is reduced to reflect the free allocation that EU producers still receive under the Emissions Trading System. This guide matters in particular, because producers in third countries did not have to perform this calculation during the transitional period. Back then there were neither certificates nor any surrender obligation. The free allocation adjustment only arose as a new task with the definitive period. Together, No. 3 and No. 4 determine what an import actually costs.
Six sector guides with worked examples
The six sector guides cover cement, hydrogen, fertilisers, iron and steel, aluminium, and electricity. Each describes the typical production processes, the value chains, and emissions monitoring for its sector, and backs this up with worked examples. For importing companies, this is the most practical part of the package. A declarant can hand the relevant sector guide to a supplier so that emissions data is collected from the outset in the form the Commission expects. That reduces the reconciliation effort when the values are later verified.
Interpretive guidance, not new law
The guidance documents do not change the text of the regulation. They help to apply it. In the definitive period, verified actual emissions values count. Default values remain fully available, but they are set deliberately high and carry an additional mark-up. By now showing sector by sector how it reads the calculation rules, the Commission turns the package into the de facto benchmark for verifiers. Companies that align their data collection with it now reduce the risk that values will be challenged during verification.
Outlook
The first annual CBAM declaration for goods imported in 2026 is due by 30 September 2027, as is the first surrender of certificates. Until then, declarants should align the data they collect from suppliers with the methods in Guidance No. 3 and the relevant sector guides, so that the values hold up in verification. We will continue to monitor these developments for you.
Support
If you would like to understand how the new guidance documents affect your CBAM processes, for example the calculation of embedded emissions or the free allocation adjustment, please get in touch at helge@kolum.earth.