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Simplification · CBAMB-VER-02

Use a verifier accredited by a Member State national accreditation body, there being no route to recognition of a third-country accreditation body.

Authorised CBAM declarants and third-country operators procuring verification must comply, and it sits in an act that is partly law and partly a proposal.

Why it matters

The act this comes from is partly law in force and partly a proposal that can still change.

  • It is Art. 1(1)(e), replacing Art. 2(12) of Regulation (EU) 2023/956, in the CBAM extension — downstream goods and anti-circumvention. as of 2026-08-14
  • The act gives its timing as: from entry into force (third day after publication), Art. 2. as of 2026-08-14
  • It names 4 industries by name: Steel, Aluminium, Cement and Chemicals. as of 2026-08-14
  • Compliance is checked by accredited third party, if it happens. as of 2026-08-14
Addressee Authorised CBAM declarants and third-country operators procuring verificationAct COM(2025) 989 final, 2025/0419 (COD)Article Art. 1(1)(e), replacing Art. 2(12) of Regulation (EU) 2023/956Class Governments

Prior rule vs new rule

Prior rule
Trigger

Union concluding an agreement with a third country on carbon pricing

Obligation

The prior Art. 2(12) allowed agreements 'with a view to taking into account carbon pricing mechanisms in such countries or territories for the purposes of the application of Article 9', and stopped there.

New rule
Trigger

Union concludes an agreement with a third country covering mutual recognition of accreditation bodies

Obligation

Use a verifier accredited by a Member State national accreditation body, there being no route to recognition of a third-country accreditation body.

Who is affected

Addressee
Authorised CBAM declarants and third-country operators procuring verification
Class
Governments
Sectors
Names Steel, Aluminium and metals, Cement and concrete, Chemicals and refining
Applies
from entry into force (third day after publication), Art. 2

Burden drivers

No burden drivers recorded on this provision.

Source text

Verbatim

The Union may conclude agreements with third countries or territories with a view to taking into account carbon pricing mechanisms in such countries or territories for the purposes of the application of Article 9 as well as the mutual recognition of third-country accreditation bodies for the accreditation of a legal person to be a verifier pursuant to Article 18.

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Settled later in secondary legislation. No such agreement exists. The provision is an enabling power, and until one is concluded nothing changes for a declarant.