Supplier emissions-data requests

CBAM supplier emissions-data request templates

Under CBAM you must report the carbon emissions embedded in the goods you import, and from 2027 surrender certificates against them. Verified actual data from your suppliers is almost always cheaper than the EU default values. This guide tells you precisely what to ask for, in what form, and gives you ready-to-send emails, for EU importers asking suppliers and for non-EU exporters replying.

TL;DR

From each supplier you need, per installation: the direct embedded emissions and indirect embedded emissions per tonne, the monitoring methodology and reporting period behind them, and any carbon price already paid in the country of production (which is deductible). Verified actual values usually beat the default values, which carry a conservative mark-up.

What data you actually need from suppliers

CBAM makes you report the embedded emissions of every in-scope good you import. To use your supplier's real figures, rather than the conservative EU default values, you need a specific set of data for each production installation. Here is the short version of what to get.

  • Installation details

    Which installation produced the goods: its name, address and country, and the products it makes. Embedded emissions are reported at installation level.

  • Direct and indirect embedded emissions

    Per tonne of product: the direct emissions from the production process, and the indirect emissions from the electricity used. Indirect emissions are counted for cement and fertilisers, with a narrower, largely direct approach for steel and aluminium. Regulation (EU) 2023/956 sets out how embedded emissions are defined and counted.

  • Monitoring methodology and period

    How the figures were calculated and which reporting period they cover. Actual values are preferred over default values, and usually cheaper, but only if you can show how they were derived.

  • Any carbon price paid in the country of origin

    A carbon price already paid abroad on the same emissions can be deducted from your CBAM obligation, if it is substantiated and verified. So ask your supplier to document it and keep the evidence. Reg. (EU) 2023/956, on the carbon-price deduction.

New to these terms? See the glossary or the declarant guide.

Why actual data is worth the effort

You can always fall back to the EU default values, but they are deliberately conservative and carry a mark-up, so they usually overstate emissions and cost you more. Verified actual figures from the installation that made your goods are almost always the cheaper route.

  • Default-value mark-up: a conservative add-on, around 10% in 2026 rising toward 30% by 2028 (about 1% for fertilisers), applied when you use default values instead of verified actual data.
  • Verification: actual values are checked by an accredited verifier; importers relying only on default values are not subject to verification.
  • Foreign carbon price: any carbon price your supplier has already paid abroad can be deducted from the CBAM bill, if documented and verified.

Frame it as a price conversation

Many non-EU suppliers have not set up emissions monitoring yet. Rather than threatening, explain that the EU default values carry a mark-up and make their goods more expensive to import, so good data protects their price competitiveness. That is usually more persuasive than a compliance demand. European Commission, CBAM certificate price and default values.

Copy-paste, free

Two emails to move the data

Plain-English and ready to send: one for the EU importer asking a supplier, one for the non-EU exporter replying. Copy the text, swap in your details, hit send. No email or signup needed to use these.

Template 1: EU importer asking a supplier

Send this to your non-EU supplier when you first ask for embedded-emissions data.

Subject

Embedded-emissions data we need from you for the EU CBAM

Body

Hi [Supplier name],

We import [product, e.g. hot-rolled steel] from you into the EU. From 1 January 2026 the EU Carbon Border Adjustment Mechanism (CBAM) requires us to report the carbon emissions embedded in these goods, and from 2027 to surrender certificates against them. Verified data from you is almost always cheaper for us than the EU default values, so it directly affects the price we can offer.

For the goods you supply, for each production installation, please send us:

1. Installation details: name, address and country, and which of your products it makes.
2. Direct embedded emissions per tonne of product (tCO2e/t): emissions from the production process itself.
3. Indirect embedded emissions per tonne (tCO2e/t): emissions from the electricity used in production. (Relevant especially for cement and fertilisers; for steel and aluminium the count is narrower.)
4. The monitoring methodology used to calculate the above (e.g. the EU method, or an equivalent), and the reporting period the figures cover.
5. Any carbon price already paid in the country of production for these emissions, with evidence, since that can be deducted from our CBAM obligation.

If your figures have been checked by an accredited verifier, please include the verification details too.

The easiest way to send this is to fill in the structured fields we've shared and email them back. If anything is unclear, reply and we'll walk you through it. We'd rather sort it out early than have to fall back to the default values.

Could you send this by [date]? Thank you.

[Your name]
[Your company]

Select the text above to copy it, then swap in the [bracketed] details for your situation.

Template 2: Non-EU exporter replying to an EU customer

Use this if you are the supplier and your EU customer has asked for CBAM data.

Subject

CBAM embedded-emissions data for [product]

Body

Hi [Customer name],

Thank you for explaining what the EU Carbon Border Adjustment Mechanism (CBAM) requires. Here is the embedded-emissions data for the [product] we supply to you.

For each installation:

- Installation: [name, address, country] — produces [product(s)].
- Direct embedded emissions: [value] tCO2e per tonne of product.
- Indirect embedded emissions (electricity): [value] tCO2e per tonne of product.
- Monitoring methodology: [e.g. the EU method / equivalent], covering the period [start]–[end].
- Carbon price paid in [country] on these emissions: [amount and scheme, or "none"], with supporting evidence attached.

[If verified:] These figures were verified by [accredited verifier], report reference [number].

If you need the data in a particular format or with any additional breakdown, tell me and I'll provide it. We want to make sure you can use our actual figures rather than fall back to default values.

Best regards,

[Your name]
[Your company]

Select the text above to copy it, then swap in the [bracketed] details for your situation.

If you are the non-EU exporter

If your EU customers have started asking for CBAM data, here is what they need from you and why it is in your interest to provide it. Your EU buyer must report the embedded emissions of the goods you supply. If you give them verified actual figures, they pay on those; if you do not, they must use the EU default values, which carry a mark-up and make your goods more expensive to import, and less competitive.

So gather, per installation: your direct and indirect embedded emissions per tonne, the methodology you used and the period covered, and evidence of any carbon price you have already paid at home (which your customer can deduct). Where you can, have the figures checked by an accredited verifier. Template 2 above is a ready reply you can adapt.

How to run the ask well

Start early. Your first annual CBAM declaration and first surrender for 2026 imports are due 30 September 2027. Collecting verified data from installations abroad is the slowest part of CBAM work, so give yourself months, not weeks. European Commission, CBAM. Not sure whether you are even in scope? Try the scope checker first.

Contact the right person. Send the request to whoever actually knows the installation's emissions: the plant or the producer, not a trading desk that cannot answer.

Lead with the price logic. Many suppliers go quiet not because they refuse, but because they have not set up monitoring. Explain that verified data avoids the default-value mark-up, and offer to point them to the EU method. A short call beats five emails.

Keep your records. Store the emissions figures, the methodology, any verification details and evidence of a foreign carbon price somewhere you can retrieve them, ready to support your CBAM declaration if a competent authority asks.

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Questions suppliers (and you) ask

What data exactly does my EU customer need from me?

Installation-level data: which installation made the goods (name, address, country); the direct embedded emissions per tonne (from the production process); the indirect embedded emissions per tonne (from electricity used); the monitoring methodology and reporting period behind those figures; and any carbon price already paid in the country of production, with evidence, since that is deductible. If an accredited verifier has checked the figures, include that too.

What is the difference between direct and indirect embedded emissions?

Direct emissions come from the production process itself, for example fuel burned to make the product. Indirect emissions come from the electricity consumed in production. CBAM counts indirect emissions for cement and fertilisers, and takes a narrower, largely direct approach for steel and aluminium. Provide both where you can; your customer will apply the rules for each good.

What if my supplier will not (or cannot) provide actual data?

Start by helping: many suppliers simply have not set up emissions monitoring yet. Explain that without their verified actual values you must use the EU default values, which carry a conservative mark-up (10% in 2026, rising toward 30% by 2028; about 1% for fertilisers) and usually make the goods more expensive to import. That cost difference is often enough to get the data flowing. If it still does not arrive, you can report on default values, but be honest early that it affects pricing.

Do these figures need to be verified?

In the definitive period, actual embedded-emissions data is verified by an independent accredited verifier. Importers who rely only on default values are not subject to verification. The first-year (2026) site-visit and verification rules are still being finalised, so confirm the current position before committing to a particular route.

Does a carbon price paid abroad reduce the CBAM bill?

Yes. A carbon price already paid in the country of production for the same emissions can be deducted from the CBAM obligation, provided it is substantiated and verified. So ask your supplier to document any carbon price they have paid, and keep the evidence.

Sources

  1. [1]Regulation (EU) 2023/956 (CBAM), on EUR-Lexretrieved 8 Jun 2026
  2. [2]European Commission (DG TAXUD), Carbon Border Adjustment Mechanismretrieved 8 Jun 2026
  3. [3]European Commission, CBAM Registry and reportingretrieved 8 Jun 2026
  4. [4]European Commission, price of CBAM certificates and default valuesretrieved 8 Jun 2026
  5. [5]European Commission, 2025 Omnibus simplifications to CBAMretrieved 8 Jun 2026

This is guidance to help you understand CBAM, not legal or tax advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser.