We started making a new CN code in the middle of the year. What will the CBAM verifier check?
The verifier checks that the new product has the right CN code and sits in the right production process, with no gap or double count in the emissions. It also checks that only saleable goods count in the activity level, packaging material is out, and the goods were made inside the reporting period.
The checks on a new line
- Are the goods and interim products assigned to the correct CN codes?
- Are goods attributed to production processes without gaps or double counting?
- Are non-CBAM goods wrongly included in the boundary of a process?
- Was the new good put into a suitable production process?
What goes into the activity level
- Only goods that meet the specification for sale, or are used in another process. Off-spec goods, scrap and waste are not counted.
- Only goods that fall in that process by CN code.
- Packaging material is excluded. The emissions of a packaging step, such as shrink foil, stay in the embedded emissions.
Made inside the calendar year
The reporting period is the calendar year. Exact stock counts at midnight on 31 December are hard, so verifiers may accept a gap of one or two working days if you set a firm cut-off, such as 30 December at 18:00. Measure emissions, production and stocks as close to that point as is reasonable, document it, and use the same cut-off to start the next year.
Sector parameters
The verifier also checks details such as the alloy grade of a steel, the clinker content of cement or the nitrogen content of a fertiliser, and may compare them with your customers' purchase orders.
What Senseible does here
Senseible reads your fuel, power and steam bills into verified emission records, so the monthly figures a monitoring plan needs are ready to hand to your verifier. Verified here means rule checks passed against the evidence. It is not third-party assurance, and a CBAM verifier still signs the report.
Sources: European Commission, Guidance on CBAM verification and accreditation (24 August 2026)
Last reviewed 2026-11-04.