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Simplification · DECL-06

Keep the full underlying records required to calculate embedded emissions, rather than the information actually disclosed to the declarant under Art. 10(7).

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(6)(b), replacing Art. 7(5) 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 competent authority, annual. as of 2026-08-14
Addressee Authorised CBAM declarantsAct COM(2025) 989 final, 2025/0419 (COD)Article Art. 1(6)(b), replacing Art. 7(5) of Regulation (EU) 2023/956Class Businesses

The rule

New — no predecessor
Trigger

determination of embedded emissions for the CBAM declaration

Obligation

Keep the full underlying records required to calculate embedded emissions, rather than the information actually disclosed to the declarant under Art. 10(7).

Who is affected

Addressee
Authorised CBAM declarants
Class
Businesses
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

‘5. The authorised CBAM declarant shall keep records of the information disclosed in accordance with Article 10(7) that is required to calculate the embedded emissions in accordance with the requirements laid down in Annex V. Those records shall be sufficiently detailed to enable the Commission and the competent authority to review the CBAM declaration in accordance with Article 19(2).

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