Confirm which goods and arrangements apply
The European Commission identifies 1 January 2026 as the start of the CBAM definitive period. Applicability still depends on the goods, commodity codes, import arrangements and current rules. A manufacturer supplying production data has a different role from the party responsible for an EU declaration.
Start with a product and reporting period
Identify the product, processes, installation and reporting period. Gather materials, energy, output and supplier data. Keep document identifiers, dates, units and owners, and list missing items. Estimates should be distinguishable from original measurements.
Version factors and allocation methods
AI can extract tables and locate documents; qualified reviewers confirm calculation boundaries and applicable factors. Record each factor’s source, year and conditions. Shared energy allocation also needs approval. CBAM and lifecycle carbon footprints should not automatically use the same method.
Prepare reviewable workpapers
Include a document index, activity data, missing-item list, approved calculations and supporting evidence. Completing a template does not establish acceptance by a verifier. Record changes when rules or templates are updated. This guide concerns data preparation, not tax, customs or legal advice.