Our CBAM verification came back negative. What happens to our EU buyers?

Question

Accepted Answer

Your EU buyers cannot use your figures for that year. They, and any plant that uses your goods as a precursor, must switch to the Commission's default values plus the mark-up, 10% for 2026 production. Fix the findings, update the monitoring plan and set up next year's verification early. Material misstatements you did not correct before the report was issued. The verifier lists them in the report. Scope too limited: primary data missing and only totals available, a monitoring plan that no accredited verifier has assessed as satisfactory, a plan too vague to verify against, or information you did not hand over. Non-conformities that leave too much doubt for reasonable assurance, for example meters never calibrated and the gap left uncorrected year after year. The Commission's guidance is blunt: a report with a negative statement cannot supply actual specific embedded emissions or actual free allocation figures. Every importer of those goods, and every operator using them as a precursor, has to use the default values. Defaults are set so they do not understate emissions, so your buyer's CBAM bill usually rises. The importer files the annual declaration by 30 September for the previous year's imports, and the guidance suggests they want verification reports by mid-August at the latest. That is why a late negative result hurts: there is no time left to fix anything for that declaration. Tell each EU buyer in writing which goods and which year are affected, so they plan on default values instead of waiting. Tell any customer who uses your goods as a precursor. Their verifier will check your report and will not accept a negative one. Sit with the verifier's findings list and sort each item: data you can recover, a meter or lab gap you must fix, or a plan section to rewrite. Update the monitoring plan and record what changed. Non-conformities left uncorrected can be escalated to material in later years. Agree next year's timeline with the verifier now, with a plan assessment early in the year rather than after 31 December. Most negatives can be avoided before the report is issued. Materiality is not a tolerance band: the verifier asks you to correct every misstatement it finds during the engagement. Answer findings fast, keep primary documents for every figure, and do not let a verification finish with corrections still open.

Our CBAM verification came back negative. What happens to our EU buyers?

The three ways a statement turns negative

What changes for your buyers

What to do this week

Avoid it next time

Worked example: 1,000 t of hot-rolled coil, CN 7208, made in India in 2026

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