The practical risk is not limited to the emissions calculation. For 2026 imports, the file needs to connect imported goods to the quantities, supplier, producer, installation, emissions information and source records that may ultimately support the first annual CBAM declaration due on 30 September 2027.
Regulatory content last reviewed 1 October 2026
An authorised CBAM declarant must keep records of the information required to calculate embedded emissions. Those records must be sufficiently detailed to support accredited verification where applicable and later review of the CBAM declaration by the Commission or competent authority.
Under the current definitive-regime framework, the first annual CBAM declaration covers imports made during 2026 and must be submitted by 30 September 2027. By that same deadline, the corresponding CBAM certificates must be surrendered.
The Commission’s latest certificates factsheet confirms that the annual CBAM declaration reports the quantity of CBAM goods imported during the preceding year, their embedded emissions and the corresponding number of CBAM certificates. For the first declaration, that means the documentary record being created around 2026 imports matters now.
Regulatory references provide the legal context. Weetra does not file the CBAM declaration, provide legal advice or perform accredited verification.
Depending on the file, Weetra can examine the imported goods, CN classification context, origin, quantities, customs and commercial records, supplier and producer identity, installation and reporting period. It can also check actual or default emissions, supplier documents, verification records, carbon-price evidence where relevant, precursor dependencies and document versions.
Customs records: 1,024.8 tonnes.
Supplier production allocation: 1,038.2 tonnes.
The gap is recorded rather than silently normalised.
The supplier named on the invoice is identified, but the supplied emissions file does not clearly establish the manufacturing installation to which the reported actual emissions relate.
Do customs, commercial and supplier records describe the same goods, population and period?
Does the evidence establish which production installation the relied-upon emissions information actually relates to?
Can the emissions value, calculation basis and supporting records be traced and reproduced to the extent the supplied evidence allows?
Where actual emissions are used in the CBAM declaration, the current framework requires those emissions to be verified by an accredited CBAM verifier. The Commission also states that the third-country producer must provide verified emissions data on total embedded emissions. The importer therefore needs more than a supplier figure: the documentary relationship behind that figure has to remain identifiable.
The Evidence Check can identify issues for the importer, supplier or producer to address independently. If deeper review is justified, the file can move directly to Level I, II or III according to complexity rather than through a mandatory commercial sequence.
€490 excl. VAT per dossier
Request an Evidence CheckWhen a deeper review is commissioned, Weetra records what was received, what was relied on, what conflicted, what was corrected, what changed and why the final conclusion was reached. That history makes the file easier for an adviser, verifier or authority to understand later.
Supplier identity can differ across documents. A commercial seller may not be the producer. Customs and invoice quantities may not reconcile. Reporting periods can differ from supporting records. Actual-emissions values may rely on incomplete installation evidence. Precursor information may be missing. Carbon-price evidence may not establish the amount effectively paid.
A plausible emissions number does not resolve those documentary questions.
Imported goods → customs record → supplier → producer → manufacturing installation → reporting period → quantities → emissions information → supporting evidence → verification where applicable → annual CBAM declaration.
The practical question is whether the file can make those relationships clear enough to be understood and reviewed without rebuilding the evidence chain later.
The importer does not need a perfect dossier before starting. The €490 excl. VAT Evidence Check reviews the documents already available and identifies visible gaps, inconsistencies and broken documentary relationships.
For 2026 imports, starting early also means that supplier, producer and installation questions can be raised while the underlying records are still being assembled, rather than when the first annual declaration is already approaching.
A deeper review can be useful where several installations are involved, customs, commercial and producer records conflict, quantity reconciliation remains unresolved, precursor dependencies are significant, emissions inputs have unclear source history, or later corrections materially change the file.
A deeper review can lead to a Weetra Determination and, depending on the mandate, a Determination Package showing the documents reviewed, the relevant versions, the inconsistencies found, the corrections made and why the conclusion was reached.
The Case Library shows how quantity reconciliation, installation attribution, monitoring-plan versions and supplier evidence can become material documentary issues in representative documentary scenarios.
Each Evidence Check finding identifies the documents concerned, what appears to be missing, inconsistent, contradictory or insufficiently established, why the issue matters, the relevant document versions and the finding status.
The Evidence Check does not include a remediation plan, recommended corrective action or detailed correction instructions.
Start with the evidence already available. Receive findings, correct or obtain evidence independently, stop if no deeper work is needed, or move to a deeper review only where the file justifies it.
If no deeper review is required, no further engagement is recommended.
A deeper Weetra review can record what was received, what conflicted, what changed, what was corrected, what was ultimately relied on and why the conclusion was reached. That history can later support internal review, professional advice or subsequent accredited verification, while each receiving professional remains responsible for its own assessment.
| Stage | Examples |
|---|---|
| Provide | Import records, invoices, supplier declarations, producer and installation information, emissions data, verification material where applicable, carbon-price evidence where relevant and the calculations relied on. |
| Test | Goods and quantities, supplier/producer/installation identity, reporting period, calculation trail, source versions, actual-emissions relationships, verification relationships and unresolved contradictions. |
| Receive | Traceable findings identifying visible documentary weaknesses; at deeper review depth, a Determination and structured review record where included in the mandate. |
The first annual CBAM declaration covers 2026 imports. The Commission’s 30 September 2026 materials confirm that the declaration and corresponding certificate surrender fall due on 30 September 2027. The documentary record supporting those imports is therefore being created now.
Weetra does not file the CBAM declaration, purchase or surrender CBAM certificates, perform accredited verification, or guarantee how an authority or verifier will treat material outside the reviewed scope.
€490 excl. VAT per dossier
