The accredited “CBAM Verification” service provided by TÜV AUSTRIA Hellas concerns the mandatory verification of embedded emissions for “CBAM Goods” imported from non‑EU countries. The service supports obligated Organizations in ensuring the accuracy, completeness, and compliance of the submitted data with the requirements of the CBAM regulatory framework.
The Carbon Border Adjustment Mechanism (CBAM) enters full implementation for the year 2026 and directly affects imports of specific goods into the European Union. From 2026 onwards, imports of goods listed in Annex I of the Regulation will be subject to a carbon cost based on their embedded emissions.
“CBAM Goods”: Which goods are affected?
- Iron and steel
- Aluminum
- Cement
- Fertilizers
- Electricity
- Hydrogen
Who is concerned?
- Importers established in an EU Member State
- Indirect customs representatives acting on behalf of importers
- Operators located in a third country that wish to gain competitive advantage in the market, by proactively verifying the emissions of their goods, enabling their customers to use this information to comply with the Regulation
The obligation is triggered when importers exceed the single annual threshold of 50 tonnes of net mass per importer. Imports of hydrogen and electricity are not subject to the 50-tonne threshold.
What changes from 2026?
- Mandatory acquisition of Authorized CBAM Declarant status (application to be submitted to the competent National Authority by 31/03/2026).
- Mandatory collection and monitoring of embedded emissions data throughout the year.
- Submission of a verified annual CBAM Declaration for embedded CO₂e emissions by 30/09/2027 (for the year 2026), where actual values are used.
- Surrender of the corresponding number of CBAM certificates, equaling to emission levies.
- From 2027 onwards: Maintenance of CBAM certificates in the CBAM Registry at the end of each quarter, corresponding to at least 50% of the emissions embedded in the total imported goods since the beginning of the calendar year.
Actual or default values?
If verified actual values – based on primary data derived by manufacturers or suppliers – are not used for the calculation of the embedded emissions, predefined (default) values are applied. These default values include safety margins, which may lead to:
- Higher declared emissions
- An increased number of required CBAM certificates (emission levies)
- Significantly higher financial costs
What are the required steps for operators of installations in third countries?
- Submission of request to the European Commission to be included in the CBAM registry
- Provision of relevant information required upon registration
- Calculation of embedded emissions by type of goods produced in the installation, in line with Annex IV of the Regulation
- Verification of embedded emissions in accordance with the principles of the Regulation
- Determination, where applicable, of the carbon price paid in the third country
Once these steps are completed, operators can disclose the verified emissions data and any applicable carbon price information to their customers who are authorized CBAM declarants, enabling them to fulfil their reporting and compliance obligations.
Verification services
TÜV AUSTRIA Hellas provides:
- Preliminary compliance readiness assessment through verification of 2025 data
- Verification of data for 2026 and subsequent years
