I’m an Indian exporter, not the EU importer. Why am I doing this?

The EU importer is the legal CBAM declarant — but they need embedded-emissions data per shipment to file their declaration. The data has to come from you. Most EU importers now require CBAM-compliant emissions data as a contractual condition for new POs in covered sectors. Providing it proactively (with a verifier-ready report) keeps you on the supplier list and avoids the importer applying punitive default values.

Can’t we just use EU default values instead of calculating actual emissions?

You can during the transitional phase (until end of 2025) — but default values are deliberately set higher than typical actual emissions, so using them inflates the importer’s CBAM cost from 2026 onwards (when the financial obligation begins). Most EU importers explicitly require actuals to keep their cost competitive. Verified actuals also become mandatory during the definitive phase from 2026.

Does the CBAM report need to be verified by an EU-accredited verifier?

During the transitional phase (Oct 2023 – Dec 2025), no verifier accreditation requirement. From 2026 onwards, embedded-emissions data must be verified by an accredited verifier. BatchWise’s 2026 partner-firm assignments include EU-accredited verifiers for CBAM engagements; for current quarters we deliver a verifier-ready report that an accredited verifier can sign off without re-doing the calculation.

My EU customer is asking for an XML file — is that what you deliver?

Yes. The deliverable is a CBAM Transitional Registry-compatible XML file matching the EU template, plus a PDF verification report explaining the methodology applied. Your EU importer customer uploads the XML to their CBAM Registry account directly.

Which products are in scope for CBAM?

The current CBAM-covered sectors are cement, iron and steel, aluminium, fertilisers, hydrogen, and electricity. The EU has signalled progressive scope expansion (downstream products, organic chemicals, polymers under discussion for post-2026). If you’re unsure whether a specific HS code is in scope, the consultation form is the fastest way to confirm — we run the HS-code check during onboarding regardless.

EU CBAM Declaration — coordinated through BatchWise

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What is the EU CBAM?

The Carbon Border Adjustment Mechanism (CBAM) is the European Union's carbon-leakage prevention mechanism. It puts a price on the embedded greenhouse-gas emissions of certain goods imported into the EU, equivalent to what would have been paid had those goods been produced under the EU Emissions Trading System (ETS).

CBAM is rolling out in two phases:

Transitional phase (1 October 2023 – 31 December 2025) — quarterly reporting of embedded emissions only. No financial obligation. Default values permitted as a fallback.
Definitive phase (from 1 January 2026) — embedded emissions must be verified by an EU-accredited verifier. Importers must surrender CBAM certificates to cover the embedded emissions, priced at the weekly EU ETS auction average.

The legal declarant is the EU importer. But the data on embedded emissions must come from the upstream producer — i.e., from you, the Indian exporter. Most EU importers in CBAM-covered sectors now require a verifier-ready embedded-emissions report from their non-EU suppliers as a condition for purchase.

Sectors and products covered

The current CBAM scope (Annex I goods):

Cement — clinker, Portland cement, aluminous cement, other hydraulic cements
Iron and steel — pig iron, ferro-alloys, steel products (HS 72), some downstream articles (HS 73 — bolts, screws, structural steel)
Aluminium — unwrought aluminium and certain articles
Fertilisers — nitric acid, ammonia, urea, mixed fertilisers
Hydrogen — H2 produced via various pathways
Electricity — limited cross-border supply situations

The EU has signalled progressive scope expansion. Downstream products in steel and aluminium, organic chemicals, and polymers are on the post-2026 review list. If your HS code is borderline, we confirm scope during onboarding.

How BatchWise coordinates the engagement

BatchWise itself is not a Chartered Accountancy firm or an EU-accredited verifier. We do not sign verification reports. Every signed CBAM verification is issued by an ICAI-registered partner CA firm (transitional phase) or an EU-accredited verifier (definitive phase, from 2026) that BatchWise assigns to your engagement.

What BatchWise does:

Provides the document workspace and CBAM-specific evidence checklist (production records, fuel registers, electricity bills, precursor-input data)
Runs the embedded-emissions calculation per the EU CBAM methodology — direct emissions, indirect emissions from electricity, and emissions from precursor inputs
Generates the XML file in the CBAM Transitional Registry format your EU importer will upload
Picks the right partner verifier based on your sector (cement vs steel vs aluminium have different methodology nuances) and the EU importer's accreditation requirements
Coordinates the 72-hour SLA from upload to verifier-ready output

What the assigned partner firm does:

Reviews the embedded-emissions calculation against the underlying production data
Issues the verification opinion (transitional phase: review-level confidence; definitive phase: reasonable assurance per EU verifier accreditation rules)
Signs the verification report under the firm's Certificate of Practice and DSC

What the calculation actually involves

The EU CBAM methodology distinguishes direct embedded emissions (from your production process) from indirect embedded emissions (from the electricity you consumed). For some goods (cement clinker, basic chemicals), embedded emissions of precursor inputs also flow through.

Component	What we measure	Source documents
Direct emissions	Process and combustion emissions from on-site fuel + raw material consumption	Fuel registers, raw material inventory, production logs
Indirect emissions (electricity)	kWh consumed × CEA grid emission factor (or contracted PPA factor for renewable)	Utility bills, renewable PPAs, generation logs for self-generation
Precursor inputs	Embedded emissions of upstream inputs (e.g., for cement: clinker; for steel: hot-metal / pig iron)	Supplier-provided embedded-emissions data, or default values where unavailable

The output is an embedded-emissions value per tonne of finished product, attributable to each shipment line in your EU importer's customs declaration. We use the CEA grid emission factor for indirect emissions when applicable.

The 72-hour engagement flow

Onboarding (Day 0). You upload production records, fuel registers, utility bills, and precursor-input data for the relevant quarter to your secure workspace
Mapping & calculation (Day 0–1). BatchWise applies the EU CBAM methodology to compute direct, indirect, and precursor embedded emissions. Items needing entity-specific judgement are flagged for your operations / EHS lead
Verification procedures (Day 1–2). The assigned partner firm reviews the calculation against the source data — recalculation, vouching, sample testing of fuel and production records
Report drafting (Day 2–3). Verification opinion drafted alongside the XML output. Material findings discussed with your team before signing
Signature & XML delivery (Day 3). Partner firm signs the verification report under DSC. The CBAM Transitional Registry XML and the signed PDF are delivered to your dashboard for forwarding to your EU importer

End-to-end target: 72 hours from complete document upload to verifier-ready XML + signed PDF.

Deliverables

Deliverable	Format	Issued by
Verification Report	PDF (DSC-signed)	Assigned partner firm
CBAM Transitional Registry XML	XML matching EU template	BatchWise (compiled), validated by partner firm
Embedded-emissions workings	Excel	BatchWise
Precursor-input traceability	PDF + Excel	BatchWise
Methodology Note	PDF	BatchWise (versioned to engagement quarter)

Your EU importer customer uploads the XML directly to their CBAM Registry account. The signed PDF supports their declaration if the EU competent authority queries the embedded-emissions value.

Pricing

₹65,000 per CBAM Declaration engagement (single legal entity, single calendar quarter, single CBAM-covered installation). Exclusive of GST.

This is the BatchWise coordinated price. It covers:

Embedded-emissions calculation per the EU CBAM methodology
Quarterly CBAM Transitional Registry XML output
DSC-signed verification report
Precursor-input traceability documentation
One round of clarifications during the engagement
BatchWise dashboard, document workspace, methodology, and coordination

Multi-quarter contracts (annual subscription covering all four quarters of a CBAM reporting year) are quoted on request — contact us via the consultation form for pricing. Multi-installation engagements (e.g., a steel producer with multiple plants in scope) are scoped per-installation.

What "complete" means for upload

Complete uploads include, at minimum, for the relevant quarter:

Production records by product type (tonnes produced, by HS code)
Fuel registers — quantity and type of fuels combusted on site
Electricity bills covering the quarter, plus PPA documentation if you sourced renewable
Raw material consumption registers
Precursor-input emissions data from your upstream suppliers (or confirmation that default values will be applied)
EU importer's contact + EORI number (so the XML is correctly addressed)

The Document Evidence Requirements page lists the full per-sector requirement set.

How a CBAM engagement actually starts

Sign up — Google sign-in or magic-link email
Pick EU CBAM Declaration from the services list
Pay ₹65,000 via Razorpay
BatchWise reviews your scope (HS codes, EU importer details, quarter), assigns a partner firm, and confirms the engagement structure
Upload your production records, fuel register, utility bills, and precursor data. The system tells you what's missing
The 72-hour clock starts when your upload is marked complete

If you'd rather talk first, book a free 30-minute consultation — particularly useful if your scope coverage is uncertain or you have multiple installations or HS codes in play.