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Regulatory Series N°002

CBAM Article 9: carbon-price evidence and documentary chain

What documentary evidence is needed when a CBAM position relies on carbon price paid in a third country.

Version4.0
Publication date3 September 2026
Regulatory cut-off3 September 2026

CBAM Article 9: carbon-price evidence and documentary chain

What documentary evidence is needed when a CBAM position relies on carbon price paid in a third country.

A payment record answers only one part of the evidentiary question. The paper examines how the claimed treatment depends on the applicable carbon-pricing mechanism, the liable entity, the relevant installation and emissions, the amount due, rebates or compensation, the amount effectively paid, the relevant period and the relationship between that payment and the CBAM goods concerned.

Scope and central proposition

The current framework distinguishes the legal carbon-pricing mechanism from the effective burden actually borne after rebates or compensation. The evidentiary task is to connect that burden to the relevant installation, emissions, period and imported goods. Where the applicable route relies on actual carbon-price information, the record must support that chain rather than merely show that a payment occurred.

The practical issue is not whether a payment document exists. It is whether the complete documentary chain supports the specific Article 9 treatment being claimed.

CBAM Article 9, carbon price paid, payment evidence, rebates, installation linkage and documentary review.

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This page is a searchable summary of the issued publication. The PDF carries the paper’s exact wording, version and regulatory cut-off. Later legal or methodological developments do not rewrite the issued document.

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