This webpage is also available in French.
This section provides a general overview of the nature of “Monitoring” in installations located outside Europe. As the official documents have not yet been published, we will probably not provide any concrete information before 2026. The Commission will soon publish useful resources that will explain in detail which principles must be applied to ensure that real values can be accepted.
Within the EU ETS, a rigorous methodology is applied to account for all emissions produced at an installation. This methodology has also been transposed to CBAM. Consequently, several obligations must be respected by installations wishing to have their emissions verified. These verified emissions are then considered real emission values that can be used to determine the number of CBAM certificates payable, replacing default values.
These rules generally include:
- Monitoring Plan: Each installation must prepare a Monitoring Plan. This plan contains the installation’s details, a description of the production process, clearly defines the system boundaries, and describes all elements included within those boundaries. A template for the Monitoring Plan will be provided.
- Monitoring Principles: Monitoring is governed by several principles relating to good practice and data collection, including:
- Completeness: Information must be complete and include combustion emissions, process emissions, indirect emissions from electricity use (fertilisers, cement, and hydrogen only), emissions linked to precursors, etc.
- Consistency and comparability: Information must be collected over a defined period and remain comparable within the installation.
- Transparency: Monitoring data including assumptions, references, activity data, emission factors, calculation factors, intrinsic emission data of purchased precursors, measurable heat and electricity, default intrinsic emission values, carbon price information, and any other relevant information must be obtained, recorded, compiled, analysed, and documented transparently. This must be done so that an accredited verifier, in accordance with Article 18 of Regulation (EU) 2023/956, can reasonably ensure that the data contains no material inaccuracies.
- Complete and transparent records: Verified data must be kept for up to six years.
- Accuracy: The monitoring methodology must ensure that emission determination is not systematically or knowingly inaccurate. Any potential source of inaccuracy must be identified and minimised as much as possible. Due diligence must be exercised to ensure the highest possible accuracy in emission calculation and measurement.
- Integrity of methodology: The chosen monitoring method must reasonably guarantee the integrity of the emissions data to be reported. Emissions must be determined using the appropriate monitoring methods described in the annex of the text.
- Data quality: A control system must be established to ensure the quality of the data to be reported.
- Cost-effectiveness: When choosing a monitoring method, improvements resulting from increased accuracy must be balanced against additional costs. Monitoring and reporting must aim for the highest possible accuracy unless this is technically unfeasible or leads to excessive costs.
- Continuous improvement: Operators must regularly assess whether the monitoring plan and its methodologies can be improved. If the verifier makes recommendations for improvement in the verification report, the operator must consider their implementation within a reasonable timeframe, unless these improvements would result in unreasonable costs or are technically unfeasible.
Use of EN or ISO Standard Methods:
- ISO 20181:2023: Stationary source emissions - Quality assurance of automated measuring systems
- ISO 14164:1999: Stationary source emissions - Determination of the volume flowrate of gas streams in ducts; Automated method
- Laboratories accredited under “ISO/IEC 17025” for relevant analytical or calibration activities
Practical Application: In practice, the installation is responsible for its own monitoring. Based on the official text and the Commission’s guidance, installations can already begin applying the CBAM methodology so that verifiers can subsequently assess compliance. This preparation can start immediately. At this stage, it is not yet known who will be responsible for providing support for the Monitoring Plan.
A webinar dedicated specifically to monitoring and verification will likely be organised in the future.
Please refer to the official text or Commission documents for more information:
European Commission Guidance: https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-legislation-and-guidance_en