WEETRA’s review process asks a simple question of every material reporting position. Does the evidence behind it hold up? The question is asked before formal verification or regulatory review, not after.
The references below separate what the law requires from how WEETRA structures evidentiary review and from controls that WEETRA adds for robustness.
Version references, Evidence Manifests and SHA-256 integrity references are WEETRA controls. The Regulation does not prescribe those specific tools.
Official sourceRegulation (EU) 2023/956 · Art. 7(5)-(6) · Annex V · Art. 19(2)
Records supporting embedded-emissions calculations must be sufficiently detailed for verification and later review, and retained until the end of the fourth year after the relevant declaration year.
WEETRA tests whether the reviewed corpus preserves the source, fact and period relationships needed to reconstruct the evidentiary state later.
Version references, Evidence Manifests and SHA-256 integrity references are WEETRA controls. The Regulation does not prescribe those specific tools.
Official sourceRegulation (EU) 2023/956 · Art. 8 · Annex VI · Implementing Regulation (EU) 2025/2546 · Arts. 5-6 and Annex
Where actual emissions are used, the CBAM framework requires verification by an accredited verifier. Implementing Regulation 2025/2546 specifies materiality levels and minimum verification-report information.
WEETRA reviews and structures the documentary basis before regulated verification. The accredited verifier then performs its own procedures and reaches an independent conclusion.
WEETRA Review Levels define different depths of examination. They are not regulatory verification categories.
Official sourceImplementing Regulation (EU) 2025/2547 · Arts. 13-15
For complex goods, precursor reporting periods and source installations can affect the embedded-emissions calculation. Evidence may be required to establish the actual precursor period or installation subset.
WEETRA examines whether precursor values can be traced to the relevant producer, installation, period and evidentiary basis.
Official sourceRegulation (EU) 2023/956 · Art. 9(1)-(3)
A reduction based on carbon price paid requires records demonstrating the carbon price, relevant rebates or compensation, independent certification and evidence of actual payment, with retention through the fourth year.
WEETRA examines whether the file supports the carbon-price treatment being claimed and records documentary limitations where the evidentiary chain remains incomplete.
Primary legal texts prevail. Commission guidance is explanatory and is identified separately from binding law.
WEETRA uses a structured review process to examine the evidentiary state of a reporting file. It is currently applied to CBAM.
WEETRA does not certify regulatory compliance. It examines whether the information supporting a reported position can be traced to source, is internally coherent and can still be reconstructed later.
The review is organised into ten areas of examination, B1 to B10. Together they cover approximately 140 points of control.
That figure describes the breadth of WEETRA’s review, not a fixed checklist applied identically to every engagement. Which points apply depends on the mandate, the evidence actually present and the source conditions encountered.
Examines the identity and status of the declarant, the regulatory perimeter of the file and the governance conditions under which it is reviewed.
Examines how goods are identified, classified and quantified, and whether those figures hold across the file.
Examines which installation and which operator stand behind the goods, and how origin is established.
Examines the declared emissions, the method used to obtain them, the monitoring period and the verification evidence relied upon.
Examines the instrument, the payment and the allocation behind a carbon-price claim, and whether it reconciles with the emissions it is said to cover.
Examines account activity, purchase, holding and surrender, and how these resolve into the net position claimed.
Examines invoices, values, payments and lots, and whether commercial, customs and emissions records describe the same movement.
Examines provenance, signatures and evidential integrity, and whether the documentary state can be reconstructed later.
Examines how the evidence base is organised for later scrutiny, including audit readiness and the data infrastructure behind it.
Examines the conditions that block, limit or permit a Determination, and how a reviewed state is locked and released.
B4 examines verification evidence. It does not perform verification. Where accredited verification is required, an accredited verifier performs it and reaches its own conclusion.
These areas show how the review is organised. How evidence becomes a Determination is described under Review Approach.
WEETRA currently applies this review process to CBAM. Digital Product Passport requirements and customs-reform evidence chains remain areas of research and possible future extension. They are not separately available operational services.
The review follows three connected stages. First, WEETRA reads the regulatory requirement and identifies what the file must support. Second, the evidence is examined and a professional Determination is reached. Third, the reviewed evidence and its integrity are preserved so the conclusion can still be explained later.
WEETRA’s Determination complements these roles by documenting what the reviewed evidence supports within the agreed mandate. Accredited verification, where required, remains the independent statutory function of the verifier. Mandate & Boundaries →
