Evidence case

Vietnam → EU
Iron & Steel

Detailed review of installation-specific actual-emissions support

ProductConstructed Vietnamese steel file
Regulatory cut-off3 September 2026
StatusIllustrative specimen

What this case demonstrates

This illustrative case shows how a CBAM file can become difficult to defend when the documents, quantities, versions or production links do not agree.

The review tests whether the actual-emissions figure can still be supported when a sceptical reviewer questions the source history, installation attribution and consistency between the records used. The issue is the documentary support, not the arithmetic alone.

Detailed review of installation-specific actual-emissions support

Why this matters for CBAM review

A mature file should remain understandable when the reviewer does not share the assumptions of the team that assembled it.

A large file is not necessarily a reliable file. The records still need to agree on the goods, installation, period, quantities and calculation inputs. Any exception or version change should be explained in the file rather than left for a reviewer to infer.

This work can make accredited verification easier to prepare for. The verifier still performs its own independent procedures, but the supporting documents, unresolved issues and calculation trail are clearer before that work begins. This scenario shows that preparation; it does not replace verification.

Documentary records to reconcile

The review does more than check that documents are present. It checks whether they refer to the same goods, installation, period and calculation population, whether the correct versions were used, and whether another professional could follow how the reported result was reached.

  • primary production evidence
  • installation attribution records
  • calculation trail
  • cross-system reconciliations
  • future accredited-verification dependency

What the case shows

For importers, advisers and customs professionals, the useful output is not a score. It is a clear account of which relationships hold, which do not, and what still needs to be resolved before the file is relied on or prepared for verification.

How this case can be used

Use this case to see how the same type of issue can appear in a real file. The full PDF sets out the scenario, the relevant legal references and the detailed analysis.

installation-specific actual-emissions figure under detailed review

Scope discipline

The scenario is illustrative. It does not describe a real client engagement, rank a country, supplier or sector, or predict acceptance by an accredited verifier or competent authority. Its conclusion applies only to the evidence described in the scenario.

Related CBAM review topics

CBAM documentary review before accredited verification & verification readiness
CBAM documentary review
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