What does a CBAM verifier check at an Indian steel plant?

Beyond fuel and meter data, a CBAM verifier at a steel plant checks your production route and steel grade, how products are grouped into processes, the alloy and scrap figures sent to importers, the precursor mass balance with heat numbers, waste gases and the year-end cut-off. It must hold scope V, VIII or both.

At the weighbridge and stockyard

• Every delivery of coal, DRI, pig iron, scrap, ferro-alloys and bought billets in the reporting year, matched to invoices.
• Stock of coal and each precursor counted on 1 January, or as close as you can, with a firm cut-off. Verifiers may accept a cut-off one or two working days off 31 December if you fix the time, measure everything at that moment and use the same cut-off next year.
• Weighbridge calibration records.

In the melt shop and rolling mill

• Your route, which sets the benchmark for the free allocation figure: BF-BOF, DRI-EAF or scrap-EAF for carbon and low alloy steel, and EAF for high alloy steel. The benchmark table names only these routes, so if you melt in an induction furnace, agree in writing with your verifier which route indicator applies.
• Steel grade by the EU definitions: stainless means at least 10.5% chromium and at most 1.2% carbon; high alloy means at least 8% metallic alloying elements, or steel made for high surface quality and processability; low alloy is other alloy steel; carbon steel is the rest.
• Products grouped into one production process only where they differ just in size or shape and use the same precursors in the same types and proportions. Bars of different diameters rolled from the same billets are the typical case. A stainless line does not share a process with carbon steel, because the composition differs.
• Waste gases, where you have them, attributed correctly between the process that makes them and the one that burns them.
• Only goods that meet sale specifications, or go on to another process, counted as production. Off-spec material, scrap and packaging are excluded.

In the lab and dispatch office

• The figures your importer must declare: main reducing agent, mass % of manganese, chromium, nickel and other alloy elements, tonnes of scrap per tonne of steel, and the share of pre-consumer scrap.
• Alloy grade checked against your customers' purchase orders.
• Mill certificates with heat numbers, which also prove the production year of steel you sell to other plants.
• Lab analyses from an ISO/IEC 17025 accredited lab or one with equivalent competence.

What it does not check for steel

Grid electricity for steel goods is not counted in embedded emissions, except for sintered ore. The verifier still sees your power bills when checking the energy balance, but you will not be asked for a power emission factor for TMT bars or HR coil.

Worked example: the precursor mass balance a verifier reruns for bought sponge iron, 2027

• In: purchased 30,000 t + produced on site 0 t + stock from 2026 of 1,200 t = 31,200 t
• Out: consumed in the furnace 29,800 t + sold on 400 t + closing stock 1,000 t = 31,200 t
• Both sides match, so no sponge iron is missing or counted twice
• The 1,200 t opening stock keeps its 2026 figure per tonne (the supplier's 2026 verified value or the 2026 default), not a 2027 one

Example tonnages. A gap between the two sides is a finding the verifier will ask you to explain.

What Senseible does here

Senseible reads coal, power, fuel and freight invoices into dated, fingerprinted records, and its CBAM Suite carries them into production processes by CN code with your precursors, so the mass balance and the sector figures sit in one export for the verifier. Senseible checks that export in-house; the CBAM verification itself is done by an accredited verifier, either Senseible's partner or your own.

• What your EU declarant needs from you
• Proving a precursor's production year
• CBAM verifier scopes by sector
• Documents to give your verifier

Sources: European Commission, Guidance on CBAM verification and accreditation (24 August 2026), sections 2.4.2 (Table 4), 5.3, 7.2, 7.4.1, 7.7 and 9.2.4 (Table 11), European Commission, CBAM Guidance No. 5d, iron and steel (sections 3.1 and Table 3-1)

Last reviewed 2026-10-29.