8) What Data Do I Need for CBAM Reporting?

Three Data Categories#

CBAM reporting requires installation information, emissions data, and sector-specific parameters. Each category serves a different purpose in determining certificate obligations and demonstrating compliance.

Installation information identifies where goods were produced and which production processes were used. Emissions data quantifies carbon released during production. Sector-specific parameters provide product characteristics that affect how emissions are calculated and attributed.

Missing any category creates compliance problems. Incomplete installation data prevents verification. Missing emissions data forces use of defaults. Absent sector parameters may result in incorrect calculations or regulatory queries.

Installation Information#

You need basic facility identification for each supplier. Installation name, location, operator details, and production processes used. This establishes the source of your imports and allows competent authorities to verify information if needed.

Production route information matters because different technologies have different emission profiles. Blast furnace steel differs from electric arc furnace steel. Primary aluminium differs from secondary aluminium. The production method affects which calculation methodologies apply.

System boundaries must be understood. Which processes are included in emissions calculations? Which are excluded? Where precursor materials are used, those boundaries extend to precursor production. Understanding boundaries determines what emissions data is needed.

Emissions Data Requirements#

Emissions data splits into direct and indirect components. Direct emissions come from fuel combustion and industrial processes at the installation. Indirect emissions come from electricity consumed during production.

For direct emissions, you need information about fuel consumption, process inputs, and emission factors used. The calculation approach (calculation-based, measurement-based, or mass balance) affects which specific data points are required.

For indirect emissions, you need electricity consumption quantities and emission factors representing the electricity source. Default country factors are simplest. Actual factors for specific electricity sources require substantial additional documentation.

The distinction between actual and default values matters throughout. Actual emissions require detailed monitoring data and verification. Default values require only product type and country of origin but typically result in higher certificate obligations.

Precursor Materials Data#

When your suppliers use CBAM goods as inputs, those precursor emissions must be included. Steel products may use crude steel as precursor. Cement uses clinker. Fertilisers use ammonia or nitric acid.

You need to know which precursors were used, in what quantities, and what their embedded emissions were. This extends data requirements beyond your direct supplier to their suppliers.

Precursor data chains can be long. If precursors themselves incorporated precursors, you need data through multiple supply tiers. This creates visibility challenges in complex supply networks.

Sector-Specific Parameters#

Each CBAM sector requires additional product characteristics beyond emissions data. These parameters affect calculations, classifications, or both.

Cement requires clinker content percentages. Steel requires information about scrap usage, alloy composition, and reducing agents used. Aluminium requires scrap usage rates and alloy specifications. Fertilisers require nitrogen content and formulation details. Hydrogen requires production method documentation.

These parameters are not optional extras. They determine how emissions are attributed, which calculation methodologies apply, and sometimes whether products are even in CBAM scope.

Where Data Collection Fails#

Supplier engagement is the primary challenge. Suppliers in countries without carbon reporting requirements have never monitored emissions. They do not understand CBAM. They may view emissions data as commercially sensitive.

Getting data from reluctant suppliers requires explaining why it matters for market access, how it affects their competitiveness, and potentially offering support to establish monitoring systems.

Data quality varies enormously. Some suppliers have sophisticated monitoring. Others provide estimates or incomplete information. Validating data accuracy without installation access is difficult.

Multi-tier supply chain visibility is limited. Your direct supplier may not know their supplier emissions for precursor materials. Obtaining data through supply chains requires coordination and sometimes collective customer pressure.

Verification requirements from 2026 add complexity. Data must be prepared to standards that third-party verifiers will accept. Many suppliers are unfamiliar with verification processes and documentation requirements.

Internal coordination across functions often breaks down. Procurement holds supplier relationships. Technical teams understand production processes. Quality validates data. Compliance submits reports. Finance manages costs. Without clear ownership and coordination, data collection becomes fragmented.

What Data Requirements Mean#

Knowing that CBAM requires installation information, emissions data, and sector parameters is straightforward. Understanding which specific data points apply to your products, how to obtain them from your particular suppliers, and how to validate and maintain data systematically requires deeper analysis.

Which production routes do your suppliers use? What system boundaries apply to your products? Can your suppliers provide actual emissions or must you use defaults? Which precursors are relevant? How should you structure data requests?

These questions have answers but the answers depend on your specific supply chain, products, and supplier capabilities. Generic data requirement lists explain what is needed. Implementation requires mapping those requirements to your actual situation.