How long do importers and non-EU producers have to keep CBAM emissions records?

Question

Senseible · Accepted Answer

The CBAM Regulation asks authorised declarants to keep their records until the end of the fourth year after the year the declaration was or should have been submitted, and non-EU operators to keep verified emissions records for four years. For 2026 imports declared in 2027, plan on keeping evidence to at least the end of 2031. The authorised CBAM declarant keeps the information needed to calculate embedded emissions, including the verifier's report for actual emissions and the evidence for any carbon price paid abroad. The Commission and national authorities can review a declaration during the same four-year window, so the records must be retrievable, not just archived. Fuel invoices, electricity bills and meter readings used for the reported period. Production records by product (CN code) and records of precursors bought in. The monitoring methodology document and every version of it. Emission calculations with the factors and their sources. The verification report and the verifier's findings, plus any corrections made. GST law requires books and records to be kept for 72 months from the due date of the annual return, and the Companies Act asks for books of account for eight years. The same fuel and electricity invoices serve all three purposes, so keep them for the longest period that applies to you. Your EU buyer carries the legal duty but depends on your data. Agree in writing how long you will keep the evidence, how fast you will produce it if an authority asks, and who pays for a re-verification. A clause that matches the four-year review window protects both sides.