What Article 9 allows, which records matter, and how to document a carbon-price deduction without confusing a payment statement with the complete supporting evidence.
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In briefWhat does Article 9 CBAM allow?What evidence can demonstrate that a carbon price was effectively paid?How are rebates and other forms of compensation treated?How should the payment be connected to the relevant emissions and period?Who needs to provide or preserve the supporting information?What happens when the evidence is incomplete or inconsistent?What records should be retained for later scrutiny?What should an importer or declarant request from a non-EU producer?Practical example: a payment statement is not the whole Article 9 fileIssued publication PDFArticle 9 allows an authorised CBAM declarant to reduce the number of CBAM certificates to be surrendered to take account of a carbon price effectively paid in a third country. Under the actual-price route, the record must support the effective payment and take account of any rebate or other compensation. The amended Article 9 also provides a route based on yearly default carbon prices in specified conditions.
Where embedded emissions are determined using actual emissions, an authorised CBAM declarant may claim a reduction in certificates to reflect a carbon price effectively paid in a third country for the declared embedded emissions. Any rebate or other form of compensation that would reduce that carbon price must be taken into account. Article 9 also provides a separate route based on yearly default carbon prices in specified conditions.
Official legal source: consolidated Regulation (EU) 2023/956, Article 9
For the actual-price route, Article 9 requires records showing that the declared embedded emissions were subject to a carbon price that was effectively paid. The file must in particular retain evidence concerning rebates or other compensation, references to the relevant third-country legislation, evidence of actual payment, and the certification and contact details of the independent person required by Article 9(2).
Official legal source: consolidated Regulation (EU) 2023/956, Article 9
The deduction is not based simply on the headline carbon price. Article 9 requires any rebate or other form of compensation that would reduce the carbon price to be taken into account. For the actual-price route, the authorised CBAM declarant must keep evidence relating to available rebates or compensation, including references to the relevant legislation.
Official legal source: consolidated Regulation (EU) 2023/956, Article 9
Article 9 requires the documentation to demonstrate that the declared embedded emissions were subject to the carbon price relied upon. In practice, the file therefore needs a traceable connection between the carbon-pricing mechanism, the liable operator, the relevant installation or production activity, the emissions and reporting period, the payment and the CBAM goods for which the reduction is claimed.
The legal record-keeping duty in Article 9 rests on the authorised CBAM declarant. Non-EU operators or producers may nevertheless need to provide the underlying records that allow the declarant to support the claim. For the actual-price route, the documentation must also be certified by a person independent from the authorised declarant and from the authorities of the third country.
If the record does not establish effective payment, applicable rebates or compensation, or the connection with the declared embedded emissions, the documentary basis for the claimed reduction may be insufficient. The practical response is to identify the missing link, reconcile contradictory records and avoid relying on a carbon-price figure that cannot be traced to the supporting documents.
For the actual-price route, Article 9 requires the relevant records to be kept until the end of the fourth year after the year in which the CBAM declaration was or should have been submitted. A defensible file should preserve the payment evidence, rebate or compensation evidence, relevant legal references, certification details and the records used to connect the carbon price to the declared embedded emissions.
Official legal source: consolidated Regulation (EU) 2023/956, Article 9
As a practical evidence request, ask for the applicable carbon-pricing basis, the operator or entity that bore the charge, the relevant installation and period, the emissions to which the charge relates, evidence of actual payment where the actual-price route is used, details of rebates or compensation, and the records needed to explain how the amount was attributed to the goods concerned. This is a documentary checklist, not a separate legal obligation.
A supplier statement saying that a national carbon price exists and that an amount was paid does not by itself establish every element required for an Article 9 reduction. A stronger file shows what mechanism applied, what was effectively paid after rebates or compensation, which emissions and period were covered, who made or bore the payment, and how that amount connects to the embedded emissions of the CBAM goods concerned.
Current web guide — updated 17 September 2026. The issued PDF remains available as a fixed publication and is not rewritten when the web guide is updated.
Need to apply this principle to a real CBAM file? Start with the evidence you already have.
Request an Evidence Check| Document | Weetra-N002 |
| Version | 4.0 |
| Publication date | 3 September 2026 |
| Status | Public review paper |
| Author | Weetra |
| Editorial responsibility | Founder & Executive Director |
| Last updated | 17 September 2026 |
The issued PDF controls for exact wording and version metadata. The web page is a searchable overview and may be updated to reflect later regulatory developments without rewriting the issued PDF.
