CBAM Iron & Steel: documentary evidence and verification readiness

For iron and steel, the record should connect the imported product to the producing installation and the relevant production route, then to the reporting period, production quantities, precursor steel inputs where relevant, allocation method and the source data used in the embedded-emissions calculation. Route and installation matter because the same commercial product description can mask different production processes and different emissions evidence.

Common breaks include a seller that is not the producer, a producer name that does not identify the installation, precursor values from a different period, customs tonnage that does not reconcile with the production or allocation population, or a calculation based on a monitoring-plan revision that is absent from the file. Scrap or other input information, where relevant to the methodology, can also be difficult to trace back to the source record actually used.

A producer may need to support the installation and production process, production quantities, direct-emissions source data, energy and material inputs, relevant precursor values, allocation across production processes or goods, and the monitoring-plan version that governed the reported period. Where actual values are communicated, the file should allow a reviewer to reproduce how the reported steel value was built from those records.

An EU importer needs to connect the imported iron or steel goods and quantities to the producer, producing installation, relevant verified emissions information where applicable, reporting period and source package supplied upstream. If the commercial seller is an intermediary, the file should still preserve the link back to the manufacturing source rather than stopping at the invoice.

Steel calculations can change when a monitoring plan, precursor dataset, production quantity or allocation basis changes. A file should therefore show which production route and monitoring-plan version applied to the reporting period, which precursor or activity data were used, whether actual or default values were relied upon, and what changed when a correction was made.

Before accredited verification, the record should make the production route, installation boundaries, source data, precursor treatment, quantities, calculations and corrections easy to trace. Weetra can review that documentary continuity and identify contradictions or missing support; the accredited verifier remains responsible for the independent statutory verification.

Weetra tests whether the steel dossier can be reconstructed from the goods and quantity back through the producer and installation to the production route, source records, precursor data, calculation and applicable versions. The focus is not a generic sector checklist but whether the evidence in scope actually supports the position being relied upon.

For steel, preserving the record later means retaining the production route, installation attribution, precursor basis, quantities, calculation version and remediation history that explain why a particular emissions position was used.

Weetra steel cases illustrate recurring issues such as quantity reconciliation, monitoring-plan version conflicts, trader-to-producer continuity, installation attribution and precursor lineage. These cases show why a value that looks plausible in isolation may still be difficult to defend when the chain behind it cannot be reconstructed.