CBAM Data Requirements 2026: The 16 Data Points You Must Collect From Every Supplier

General Summary

CBAM data requirements for 2026 come down to 16 data points that an EU importer must collect from each production installation before it can declare actual embedded emissions under Regulation (EU) 2023/956.

The 16 are the numbered items of the operator's summary emissions report, in point 1.2 of Annex IV to Implementing Regulation (EU) 2025/2547. Nine apply to every installation, two to indirect emissions (chiefly cement and fertilizers) and five to goods that contain precursors. The first CBAM declaration, covering 2026 imports, is due on September 30, 2027. An importer without the data declares default values, with a mark-up of 10% for 2026 that rises to 30% from 2028 (1% for fertilizers).

Last checked against the Official Journal and the DG TAXUD CBAM pages: October 12, 2026.

What Data Must an EU Importer Collect for CBAM?

An EU importer must collect the operator's summary emissions report, 16 numbered data points per installation, together with the verification report that confirms them.

The legal obligation sits on the importer, while the data sits with the installation operator. Articles 6 and 7 of Regulation (EU) 2023/956 make the authorized CBAM declarant declare the embedded emissions and keep the records behind them. The Commission's Guidance No 1 of August 14, 2026 states the other half: "Operators established outside the EU are not obliged to carry out any activities under the CBAM."

That asymmetry turns compliance into a data request that the supplier answers by choice. The CBAM supplier data request generator builds the letter for all six sectors, in six languages.

The table below lists the 16 data points in the order of point 1.2 of Annex IV, the path that needs each one, and the section of the verification report (Annex to Implementing Regulation (EU) 2025/2546) in which the verifier records it.

Three things sit outside the 16: the verification report itself, which carries the summary as its annex; your own customs data on CN code, quantity and country of origin; and evidence of a carbon price paid under Article 9.

The 16 Required CBAM Data Points

The 16 required CBAM data points fall into five families: installation identification, production and activity, direct emissions, indirect emissions and precursors, with carbon price evidence as a sixth, optional file.

Every field below is held by the installation operator, reported in English and attested by the accredited verifier, unless stated otherwise. Those fields decide how many certificates the importer surrenders, a mechanism the EU CBAM guide explains in full.

Installation Identification Data

Installation identification data tie every declared tonne to one operator and one installation, which Annex V of the Regulation requires the importer to keep on file, through the three fields below.

• Operator (1): name, corporate or activity registration number, and full address in English.
• Installation (2): name, CBAM Registry identifier, UN/LOCODE, full address in English, and coordinates of the main emission source (six decimals in the verification report).
• Operator contact (Annex V): contact information, which the summary does not number.

Production and Activity Data

Production and activity data establish which production process and route made the good, which decides how installation emissions are attributed and which CBAM benchmark applies. The five data points are listed below.

• Production processes and routes (3): every CBAM process with its goods and its route, such as blast furnace or scrap-based electric arc furnace.
• Measurable heat (7): imported from or exported to other installations.
• Zero-rated fuels (8): whether used, and the proof of zero rating.
• Waste gases (9): produced, used, imported or exported.
• CO2 capture (10): whether used, and the installation or transport infrastructure that receives the CO2.

The full report and the verification report add the reporting period (the year 2026 for goods imported in 2026), the quantity of each good per CN code, and sector parameters such as the clinker-to-cement ratio, scrap input per tonne of steel and the nitrogen content of fertilizers.

Direct Emissions Data

Direct emissions data produce the figure that enters the declaration under Article 6(2)(b), and the free allocation adjustment deducted from it. The four fields are listed below.

• Specific direct embedded emissions of each good (4): tCO2e per functional unit, converted to tCO2e per tonne of good for the declaration.
• Share of embedded emissions on default values (4): a percentage.
• Specific embedded free allocation of each good (4): tCO2e per tonne, with confirmation of the CBAM benchmark used.
• Total direct emissions (5): tCO2e for the installation and for each production process.

The functional unit is the tonne of good per CN code, with exceptions in Article 4 of Implementing Regulation (EU) 2025/2547: tonnes of clinker for clinker and most cements, kilograms of nitrogen for nitric acid, ammonia and mixed fertilizers, the Combined Nomenclature supplementary unit for other fertilizers, and kWh for electricity.

Indirect Emissions Data

Indirect emissions data calculate the emissions from electricity consumed in production, which count only for goods outside Annex II of the Regulation, chiefly cement and fertilizers. Annex II confines most iron and steel goods, aluminium, hydrogen and electricity to direct emissions. The four fields are listed below.

• Specific indirect emissions of each good (4): tCO2e, split into the shares from actual and from default values.
• Criteria for actual values (4): confirmation of a direct technical link to the generation source or a power purchase agreement (point 6 of Annex IV to the Regulation).
• Indirect emissions of the installation (6): tCO2e in the reporting period.
• On-site electricity generation (11): cogeneration or separate generation, fossil or renewable sources, and any export.

Precursor Data

Precursor data add the emissions of CBAM goods consumed as inputs, and each precursor needs its own installation-level data. A precursor is any input material itself listed in Annex I: clinker in cement, ammonia in urea, crude steel in rebar, unwrought aluminium in profiles. Its emissions carry into the final good under point 3 of Annex IV to the Regulation.

Importers get this wrong by asking a rolling mill or an extruder only for its own process emissions. Actual values for a purchased precursor count only when they come from a verification report on the installation that produced it. The five data points are listed below.

• Precursors on default values (12): CN code, name, country of origin and default value applied.
• Precursors on actual values (13): CN code, name, country of origin, reporting period and specific embedded emissions.
• Different reporting periods (14): the weighted average used for a precursor made in more than one year.
• Several installations (15): the value used for a precursor bought from more than one installation, and the method.
• Origin (16): operator, installation, CBAM Registry identifier where one exists, and reporting period.

Where the country of production of a precursor cannot be identified, Annex IV of Implementing Regulation (EU) 2025/2621 applies the default of the third country with the highest emission intensity.

Carbon Price Paid Data

Carbon price paid data support a reduction in certificates under Article 9, and you collect them only where the installation effectively paid a carbon price. Article 9(2) requires the four documents listed below.

• Documentation that the declared embedded emissions were subject to a carbon price effectively paid
• References to the legislation on any rebate or other compensation
• Certification by a person independent from the declarant and from the third-country authorities, with name and contact information
• Evidence of the actual payment

An unsubstantiated claim is worse than no claim. Article 19 allows a review of the declaration until the end of the fourth year after it was due, and a rejected claim means additional certificates within one month plus exposure to the Article 26 penalty. The carbon price deduction page tracks the implementing act on Article 9, not adopted as of October 12, 2026.

What Happens When a Supplier Will Not Provide Data

Default values apply, with a mark-up, when a supplier will not provide data.

Article 7(2) of Regulation (EU) 2023/956 allows two bases for embedded emissions: actual emissions or default values. A refusal blocks nothing legally, because the default path needs none of the 16 data points. The consequence is financial.

When Default Values Apply and What They Cost

Default values apply whenever verified actual data are missing for a good or for one of its precursors. Implementing Regulation (EU) 2025/2621, as corrected by Implementing Regulation (EU) 2026/1740 with effect from January 1, 2026, sets a value per country and CN code. The mark-up is 10% for 2026, 20% for 2027 and 30% from 2028 for cement, iron and steel, aluminium and hydrogen, and 1% in every year for fertilizers.

The table below prices one row of Annex I: semi-finished non-alloy steel (CN 7207 11 14) from Turkey, default 2.310 tCO2e per tonne. It uses the official Q3 2026 certificate price of EUR 82.32 per tCO2e, published on October 5, 2026, held constant. The figures are gross, before the free allocation adjustment.

The net cost is lower, because Article 31 of the Regulation deducts the free allocation that EU producers of the same good still receive. For a good on default values, Implementing Regulation (EU) 2025/2620 sets that deduction per tonne as the CBAM factor (97.5% for 2026 under Article 10a(1a) of Directive 2003/87/EC), times the cross-sectoral correction factor (100% for 2026 to 2030 under Implementing Decision (EU) 2026/1862), times the CBAM benchmark. Certificates per tonne are the embedded emissions minus that deduction and any Article 9 reduction, never less than zero (Commission Guidance No 1).

The default benchmark for this row is 1.364 tCO2e (Column B, blast furnace route), so the deduction is 1.330 tCO2e. The 2026 default of 2.541 tCO2e nets to 1.211 tCO2e, about EUR 99.70 per tonne.

The 2026 obligation is therefore not a flat 2.5% of gross emissions: only a good whose emissions equal its benchmark pays 2.5%. The deduction does not grow with the emissions declared, so every tonne of CO2e above the benchmark, the whole mark-up included, is charged at the full certificate price. The actual-value path uses the Column A benchmarks and adds the free allocation embedded in precursors, so model both paths. The CBAM default values page covers the country tables.

How to Escalate a Data Request Commercially

Escalate a refused data request in the six steps below, moving to contract terms only when the earlier steps fail.

1. Quantify the gap. Send the supplier the cost per tonne of its default value against a verified figure.
2. Split the request into phases. Ask first for installation identification, production route and precursor origins, then for the verified summary report.
3. Offer the methodology. Share the Commission's Guidance No 2 for non-EU operators and sector guidance No 5a to 5f, published on August 14, 2026 on the DG TAXUD guidance page.
4. Remove the confidentiality objection. Point to registration in the CBAM Registry, which Guidance No 2 describes as "limiting the information seen by the declarant to a summary of the emissions report".
5. Write the data into the contract. Require the verified summary report by a fixed date, with a price adjustment equal to the default-value cost where it is missing.
6. Price the alternative. Compare the landed cost, default uplift included, with a quote from a supplier that already holds a verification report.

Mark-ups, default values and the report template change by implementing act. CBAM Brief (EUR 199 a month) reports each change to data and verification requirements by email.

How to Request CBAM Data From a Supplier

Request CBAM data from a supplier in writing, per installation, in the seven steps below.

1. Identify the installation. Trace each imported CN code back through any trader to the installation that produced it.
2. Generate the request. Build the letter with the data request generator, which selects the sector-specific fields.
3. Ask for three documents. Request the summary emissions report for the reporting year, the verification report, and the full emissions report where the operator is not registered in the CBAM Registry.
4. Ask for precursor origins. Request the installation, country and reporting period of every purchased precursor.
5. Ask about carbon pricing. Request the Article 9 documents only where a carbon price was effectively paid.
6. Set dates. Work back from the September 30, 2027 CBAM declaration deadline. The Commission's timeline has verifiers issuing first verification reports in January 2027.
7. Check the verifier. Confirm the CBAM accreditation certificate before you rely on a report.

The exporter data requirements page explains the same request from the producer's side and can be forwarded with your letter.

Before you send the letter, the CBAM supplier questionnaire template page shows the 15 data points the generator can request and the production routes each one is included for.

What the EU Communication Template Covers

The EU communication template covers the operator's side of the exchange. In the definitive period it is the operator's emissions report, with minimum content set in Annex IV to Implementing Regulation (EU) 2025/2547. It replaced the optional electronic communication template of the transitional period with what the Commission's Guidance No 3 calls "a mandatory structure of three documents", listed below.

• Full operator's emissions report: 35 numbered items, including activity data per production process, calculation factors, data gaps and sector-specific parameters.
• Summary emissions report: the 16 data points, the version made accessible to declarants and annexed to the verification report.
• Declarant-specific addendum: for imported electricity only, with the declarant's EORI number and the qualifying quantity of electricity.

A registered operator can disclose only the summary through the CBAM Registry. Guidance No 2 warns unregistered operators that "authorised declarants are obliged to request complete verification reports and emissions reports from you".

Is the Communication Template Mandatory?

Yes, in its definitive-period form: Article 10(1) of Implementing Regulation (EU) 2025/2547 obliges an operator that reports actual values to prepare the emissions report and its summary with at least the Annex IV content, and Article 10(4) requires English. The transitional template was optional. The duty binds only operators that choose to supply actual values, so no supplier is forced to report.

How Long Importers Must Retain Supplier Data

Importers must retain supplier data "until the end of the fourth year after the year in which the CBAM declaration has been or should have been submitted". Article 7(6) of Regulation (EU) 2023/956 sets that period for the Annex V records, including the verification report, and Article 9(3) repeats it for carbon price documentation. Data for 2026 imports, declared in 2027, stay on file until December 31, 2031.

Operators run a different clock: at least six years after the reporting period, under point A.2 of Annex II to Implementing Regulation (EU) 2025/2547. The CBAM record keeping guide sets out a filing structure by declaration year.

What a Verifier Checks in the Data You Collected

A verifier checks the collected data against the monitoring plan and the calculation rules, then records the result in the verification report. The six checks below follow Implementing Regulation (EU) 2025/2546.

• Conformity: the operator followed its monitoring plan and the calculation methodology.
• Materiality: misstatements stay within 5% of each good's specific embedded emissions and specific embedded free allocation.
• Site visit: a physical visit, replaced by a virtual visit or waived only under Articles 2 to 4.
• Data compilation: emissions, quantities per CN code and benchmarks used.
• Precursors: the origin of each precursor and the verifier behind its actual values.
• Verification statement: reasonable assurance that the report is free from material misstatements and non-conformities.

The CBAM verification guide explains each stage of that process and its cost.

Frequently Asked Questions About CBAM Data Requirements

The six questions below cover industry averages, shipment-level data, accounting standards, carbon prices, verification fees and customs brokers.

Can I use an industry average instead of supplier data?

No. Article 7(2) of Regulation (EU) 2023/956 allows actual emissions or the Commission's default values, and nothing in between. The one flexibility is a region-specific adaptation of a default value, which a declarant has to demonstrate to the Commission from official sources (Annex V to Implementing Regulation (EU) 2025/2547).

Do I need emissions data for every shipment or for every installation?

You need data per installation, per good and per reporting period, not per shipment. The reporting period is a calendar year, so one verified report covers every shipment of that good from that installation in that year. The embedded emissions calculation page shows how the annual figure is built.

What if my supplier uses a different accounting standard?

A product carbon footprint under another standard does not qualify as actual values. Guidance No 2 notes that the CBAM scope differs from methods such as the GHG Protocol or ISO 14067. The supplier has to recalculate under Implementing Regulation (EU) 2025/2547 and have the result verified.

What if the installation is in a country with its own carbon price?

Collect the Article 9 documents and keep them, but do not budget for a deduction yet: the implementing act on the evidence rules had not been adopted as of October 12, 2026. Article 9(4) also lets the Commission set yearly default carbon prices from 2027.

Who pays for the supplier's verification?

The operator contracts the verifier, and the law does not say who bears the fee, so the split is a commercial term. Verification vendors quote EUR 5,000 to 50,000 per installation, a market estimate and not a Commission figure. As of October 12, 2026 the Commission's list of accredited CBAM verifiers was still unpublished.

Can a customs broker collect CBAM supplier data for me?

Yes, anyone can collect the data, but the obligation stays with the authorized CBAM declarant. Guidance No 1 identifies the declarant as the person lodging the customs declaration, usually the importer and in some cases the indirect customs representative. A broker acting in that capacity carries the CBAM obligations itself.