Guide
Treat Verified Emissions Data as an Export Asset Before Your EU Customers Ask
Your EU customers carry the CBAM duty, and the evidence sits in your plant. We build a system of record in which each figure traces to its source and method.
4-minute read5 November 2026
In Brief
- Without verified data, your EU customers use default values. If your actual emissions are lower you cannot show it, and 2026 fuel, stock and meter records may be impossible to rebuild later.
- We see four actions: draw the installation boundary, capture fuel, heat, electricity and precursor data by process, trace precursors to their producers, and arrange verification.
- Thinqmesh sets up a system of record on your own energy and supplier data within four weeks, each figure linked to its source and method, and plans a first traceable footprint at eight.
An exporter of steel, aluminium, cement or fertilisers to the European Union will often hear that the Carbon Border Adjustment Mechanism is the importer's problem. In law that is broadly true, and it is also why exporters underestimate it. The importer carries the duty, while the people who can produce the evidence work at your plant. We think verified emissions data should be treated as a commercial asset now.
The Evidence Sits at the Installation
Operators outside the EU have no CBAM obligation of their own. Their EU customers can use default values set by the Commission when no actual data is available, so what you provide is a commercial choice. Actual data counts only if an accredited verifier has checked it, with one report for each installation, tracing emissions to production processes, precursors and goods by customs code.
Declarations for goods imported in 2026 are due by 30 September 2027, and the fuel, stock and meter records for 2026 are being created now. Records that were not kept may be impossible to rebuild. We help you build the system of record while the year is still running.
Four Actions That Make Your Data Ready to Verify
Start with the records being created now, because data from 2026 cannot always be rebuilt later.
Draw the Installation Boundary
Verification applies at the level of the installation, so a company-wide figure does little here.
Establish which installation, which production processes and which routes you are covering, and tie each good to its Combined Nomenclature code. A clear boundary lets a verifier see exactly what they are looking at.
Get started
- List each installation that makes goods sold into the EU.
- Match each product to its customs code.
Capture the Data Behind Emissions, Process by Process
Fuels, materials, heat and electricity are measured and recorded for each production process.
Record the fuels and materials consumed with their calculation factors, measurable heat attributed to the processes that use it, and electricity consumed in each process. A plant that generates its own power monitors that plant too.
Get started
- List the meters and invoices that cover each process.
- Check that the records run from 1 January 2026.
Trace Precursors to Their Producers
Each precursor used must be accounted for, with the producer's own verified data where it is bought.
There is no threshold for leaving out small quantities, so every precursor needs a quantity and a source. Ask suppliers early for their data, because supplier data is often incomplete or late.
Get started
- List every precursor used in the goods you export.
- Send each supplier a request for their data.
Arrange Verification With an Accredited Verifier
Actual data replaces default values only if an accredited verifier has checked it.
Plan the verification as a date in your calendar, with the evidence assembled in advance. A verifier will want to follow a figure from the report back to a meter, an invoice or a calculation.
Get started
- Ask your EU customers whether they want actual data.
- Identify an accredited verifier and ask what evidence they require.
How Thinqmesh Solves This
We begin with the data. Every figure links to its source and its method, so that a question about it has an answer, and the same records show which plant, route or supplier deserves attention first.
- Week 1
Your Energy Data, With Its Sources
We gather your energy and related data and establish where each figure comes from.
- Week 2
Supplier Data and Methods
Supplier data is requested and assessed, and each calculation method is written down.
- Week 3
Connection to Your Systems
The system of record is connected to the sources you already use, so that figures can be followed back to them.
- Week 4
A System of Record in Use
Your team is working from one system of record, with gaps in the data visible ahead of the first footprint.
You finish the first four weeks with a system of record in use on your own data and the gaps made visible. A first traceable footprint follows at eight weeks, because supplier data is often incomplete or late.
