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Requirement · DECL-03

Report total embedded emissions per tonne of goods (or per MWh for electricity), and have them verified where actual emissions are supplied by the operator through the CBAM registry.

Authorised CBAM declarants 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(5)(a)(1), replacing point (b) of Art. 6(2) 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 5 industries by name: Steel, Aluminium, Cement, Chemicals and Power. as of 2026-08-14
  • Compliance is checked by accredited third party, annual. as of 2026-08-14
Addressee Authorised CBAM declarantsAct COM(2025) 989 final, 2025/0419 (COD)Article Art. 1(5)(a)(1), replacing point (b) of Art. 6(2) of Regulation (EU) 2023/956Class Businesses

The rule

New — no predecessor
Trigger

submission of the annual CBAM declaration

Obligation

Report total embedded emissions per tonne of goods (or per MWh for electricity), and have them verified where actual emissions are supplied by the operator through the CBAM registry.

Who is affected

Addressee
Authorised CBAM declarants
Class
Businesses
Sectors
Names Steel, Aluminium and metals, Cement and concrete, Chemicals and refining, Power and heat
Applies
from entry into force (third day after publication), Art. 2

Burden drivers

D1 · D2 · D4 · D5 — 4 of 7 marks fire on this provision.

Source text

Verbatim

‘(b) the total embedded emissions in the goods referred to in point (a) of this paragraph, expressed in tonnes of CO2e emissions per megawatt-hour of electricity or, for other goods, in tonnes of CO2e emissions per tonne of each type of goods, calculated in accordance with Article 7 and, where the embedded emissions are determined on the basis of actual emissions provided by the operator via the CBAM registry in accordance with Article 10, verified in accordance with Article 8;

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