Complying with the European Union’s Carbon Border Adjustment Mechanism (CBAM) can be difficult, time-consuming, and costly for your business.

Whether you are a producer of a CBAM Good exporting to the EU, or an EU-based importer of a CBAM Good, understanding your obligations under CBAM is essential to avoid penalties for non-compliance or the application of punitive default values to your emission reports.

Here at ARTEM, we believe that choosing the right partner is critical for ensuring that your business seamlessly navigates the transition to the Definitive Period of the CBAM Regime in January 2026.

But when choosing a CBAM partner, what questions should you ask?

Here’s our step-by-step guide on how to choose the right CBAM compliance partner:

CBAM is the result of the EU Commission reaching a pragmatic compromise between its objective of combating carbon leakage and the realities of monitoring and enforcing a regulatory regime that involves companies from across the globe.

As a result, the legislative regime underpinning CBAM (Regulation (EU) 2023/956 and Implementing Regulation (EU) 2023/1773) is a framework filled with unique concepts that require careful consideration.

Concepts such as “Direct Emissions” and “Indirect Emissions” do not translate well to similar concepts used by other carbon footprint or product life cycle methodologies, e.g., “Scope 1” or “Scope 2” emissions under the Greenhouse Gas Protocol.

Your partner should have deep expertise, not just in carbon accounting methodologies generally, but specifically in advising clients on the application of CBAM.

• Do you have experience advising on CBAM compliance specifically?
• Can you provide case studies or references from clients?
• Are you familiar with the requirements for calculating specific embedded emissions under CBAM?

Complying with CBAM requires a deep knowledge of both the legal requirements under the regime and the application of those legal requirements to a real-life production. Your CBAM partner should have a deep understanding of your specific industry and the industry-specific challenges that CBAM poses.

As an example, if your business imports aluminum products into the EU, your CBAM partner should understand the regulatory implications of your supplier sourcing primary aluminum from a producer using older Søderberg electrolytic cells, rather than a producer using modern pre-baked, center-worked point feed technology.

Key Questions to Ask:

• Do your employees have a background in my industry?
• Have you had clients that produce the same goods that I produce / import?

As an importer of CBAM Goods into the EU, complying with CBAM means gathering reliable data from your producers, wherever they may be in the world.

As a declarant under CBAM, the importer bears responsibility for the submission of verified emission data; however, language barriers, lack of knowledge regarding CBAM, and an unwillingness to cooperate or disclose emission data are all issues that need to be addressed.

Your CBAM partner should have an established presence in the countries from which you import, be able to attend in person at your suppliers, and provide training and support in gathering reliable emissions data.

Key Questions to Ask:

• Do you have offices or a team in the countries I import from?
• What happens if my supplier has an issue or needs someone to attend in person?
• Does your team have members who are native speakers of the languages that my suppliers’ employees speak?

1. In the Definitive Period, your suppliers will need to ensure that their emission data passes verification from an independent third party. This requirement will not be taken lightly by the EU Commission, as it is a critical step to prevent fraud and circumvention of the Regulations.For your suppliers to pass verification, they will need a monitoring methodology plan that documents their processes for the measurement of their emissions data, as well as facilitating a third-party verifier to conduct a site visit.Your CBAM Partner should be aware of issues regarding verification in the definitive period and have a suitable plan for assisting your suppliers with compliance.Also, be careful of partners that offer to both advise you on how to comply with CBAM and offer to perform verification for you. This will almost certainly be prohibited under the CBAM Regulations in the Definitive Period (just as it is prohibited under the EU ETS Verification Regulations (see e.g. Article 43 of Regulation 2018/2067)).
   

   Key Questions to Ask:

   • What service can you provide to assist my suppliers with passing verification?
   • Do you have experience creating or reviewing monitoring plans?

Effective CBAM compliance relies on robust data collection, analysis, and reporting. Your CBAM partner should have the appropriate technology available to provide you with reliable data when you need it.

Look for partners who provide comprehensive digital solutions for CBAM emissions monitoring and automated reporting. These partners will usually be far more cost-effective than bespoke consulting solutions or Excel documents that require manual data entry.

Key Questions to Ask:

• What software or tools do you use to gather data from suppliers?
• Can your systems integrate with my supplier’s existing ERP or supply chain management tools?
• Do you offer real-time monitoring and analytics?

CBAM compliance is not a one-time task; it requires ongoing monitoring, reporting, and adaptation. Your CBAM partner should provide clear communication, responsive support, and a dedicated team to guide you through the process.

Key Questions to Ask:

• How do you handle client communication and support?
• Can you offer training for my team on CBAM compliance?
• What is your process for addressing changes in the CBAM regulation?

CBAM compliance is a significant challenge, but it also presents an opportunity to strengthen your sustainability practices and gain a competitive edge in the EU market. By choosing the right partner, you can navigate the complexities of CBAM with confidence, not only ensuring compliance but driving long-term value for your business.

Here at ARTEM, we can assist you as your trusted CBAM partner. To find out more, please don’t hesitate to contact us!