CBAM Readiness and Verification Services

Prepare for EU CBAM requirements with readiness assessments, emissions reviews and pre-verification support.
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CBAM Overview

The EU Carbon Border Adjustment Mechanism (CBAM) is now active and reshaping the requirements for companies importing carbon-intensive goods into the European Union. CBAM is designed to help ensure that imported goods bear a carbon price equivalent to that paid by EU producers under the EU Emissions Trading System (EU ETS). It aims to prevent carbon leakage and promote global emissions reductions.  

UL Solutions helps organizations prepare for CBAM obligations today and is actively pursuing CBAM verifier accreditation through applicable EU National Accreditation Bodies so we can offer accredited CBAM verification services once accreditation is granted. In the meantime, UL Solutions currently provides CBAM readiness, gap assessment and pre-verification services to help organizations prepare for definitive compliance.  

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Why CBAM matters

  • It prevents “carbon leakage,” where companies move production to countries with weaker climate policies, undermining EU climate goals. 
  • It aligns imports with the EU ETS carbon price, promoting fair competition and encouraging cleaner production globally. 

Timeline

  • Definitive phase: Jan. 1, 2026 
  • Only authorized CBAM declarants may import goods above the 50‑tonne threshold. 
  • Importers must report verified embedded emissions annually 
  • Major deadline: Sept. 30, 2027 
  • First annual CBAM declaration and certificate for 2026 imports 

Following the adoption of the EU CBAM simplification package, importers below the 50-tonne annual threshold are generally exempt from CBAM obligations (except certain hydrogen and electricity imports).  

What products are within the scope of CBAM?

CBAM currently applies to carbon-intensive sectors considered at highest risk of carbon leakage:

  • Iron and steel
  • Aluminum
  • Cement
  • Fertilizers
  • Hydrogen
  • Electricity
  • Certain downstream products manufactured from covered materials

Covered products are identified through specific EU Customs CN codes and may include both raw materials and selected processed products. Companies should assess their imported products carefully to determine whether they fall within CBAM scope.

How CBAM works

  • Authorization

    Importers exceeding the 50‑tonne threshold must apply to become authorized CBAM declarants in the EU’s CBAM Registry (Authorization Management Module). 

  • Emissions reporting and verification

    Actual emissions data must be verified by an accredited CBAM verifier. 

  • Certificates and deductions

    Importers must purchase CBAM certificates based on the emissions of their imported goods. 

Who is Impacted by CBAM?

Although CBAM compliance obligations apply directly to EU importers, the effects extend throughout global supply chains. 

EU Importers

 

  1. Organizations importing CBAM-covered products into the European Union must: 
  2. Become an Authorized CBAM Declarant (where applicable) 
  3. Collect emissions data from suppliers 
  4. Maintain supporting documentation 
  5. Submit annual CBAM declarations 
  6. Purchase and surrender CBAM certificates

Manufacturers Outside the EU

  1. Producers exporting CBAM-covered products into Europe increasingly need to provide: 
  2. Precursor emissions information 
  3. Installation (facility) emissions data 
  4. Monitoring methodologies 
  5. Supporting evidence for emissions calculations 

Supply Chain Partners

Intermediate suppliers, processors, and traders may also be required to support emissions data collection and traceability as customers seek more reliable carbon information. 

Why UL Solutions is well positioned for CBAM

UL Solutions is a globally recognized safety science leader with deep expertise in third‑party verification and validation across sustainability, environmental performance and regulatory compliance. These capabilities position the organization to support importers and manufacturers preparing for CBAM’s definitive phase. Key strengths include: 

Global footprint and experience supporting multinational supply chains

Technical depth across carbon accounting, emissions modeling and data integrity

Robust verification infrastructure, aligned with international standards

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Preparing for CBAM requires more than annual verification. Organizations must establish robust emissions accounting systems, engage suppliers, validate embedded emissions data, and develop governance processes capable of withstanding regulatory scrutiny. UL Solutions combines: 

Global verification and validation expertise

Carbon accounting and greenhouse gas (GHG) verification capabilities

Supply-chain assessment experience

Industrial sector expertise across steel, aluminum, cement, chemicals and manufacturing

Accreditation experience across ISO 17029, ISO 14064, ISO 14065 and related conformity assessment frameworks

This enables UL Solutions to support organizations throughout their entire CBAM compliance journey from readiness through accredited verification. 

UL Solutions’ CBAM Service Offerings

CBAM pre-verification — A process for evaluating the verification readiness of a GHG information management system. The outcome of CBAM pre-verification is structured feedback for strengthening the GHG information management system. This feedback extends to aspects such as documentation templates, calculation standards and guidance, conversion factor sources, quality control procedures. Two main activities are performed:

Qualitative — Review of non-numerical aspects of management system such as boundary selection, method selection and more  

Quantitative — Review of numerical aspects of management system such as calculation logic and conversion factors 

CBAM verification — A process for evaluating a statement of GHG information to determine if the statement is materially correct and conforms to criteria. The outcome of CBAM verification is a GHG verification report prepared in accordance with ISO 14064-3: 2019 that can be used to comply with CBAM requirements. Two main activities are performed:

Materially correct — The GHG statement is free from individual misstatements or aggregate misstatements that could influence the intended user’s decisions.

Conforms to criteria — The policy, procedure or requirement used as a reference against which the GHG statement is compared.

Frequently Asked Questions

Yes, if you import more than 50 tonnes of CBAM goods per year into the EU. Authorization must be obtained through the CBAM Registry.

Yes. Although CBAM obligations apply to EU importers, manufacturers outside the EU increasingly need to provide verified emissions information to their customers to maintain market access and reduce CBAM costs.

Certificates apply in the definitive regime (2026 onward) and are surrendered in the annual CBAM declaration. Pricing follows the EU ETS.

Not yet. Verification can only be performed by accredited CBAM verifiers. UL Solutions intends to offer verification services once EU accreditation opens. Until then, UL Solutions provides readiness and pre‑assessment support.

Importers may need to rely on default values established by the European Commission, which may result in higher CBAM certificate obligations than using verified actual emissions.

Yes, verified carbon prices paid abroad can be credited against certificate obligations.

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