CBAM Supplier Emissions Data: How to Collect It

UK CBAM requires importers to report the embedded emissions of every covered shipment. Embedded emissions are the greenhouse gases released during the production of the goods — the carbon emitted by your supplier's manufacturing process.

The gold standard is verified supplier data: actual emissions figures provided by your supplier, preferably verified by a third party. If you cannot obtain verified data, you can use unverified supplier data or, failing that, HMRC's default values.

The incentive to use supplier data is financial. HMRC sets default values deliberately high to remove any advantage from failing to collect real data. Using actual supplier emissions typically results in a lower CBAM liability.

For each product you import, you need the following data from your supplier:

• Embedded emissions per tonne of product (kg CO₂e per tonne)
• Production method and energy sources used
• Electricity consumption during production (MWh per tonne)
• Scope 1 emissions (direct emissions from owned sources)
• Scope 2 emissions (indirect emissions from purchased electricity)
• Any carbon price paid in the country of production
• Verification status of the emissions data

HMRC provides a recommended data request template. You can send this to your suppliers as a starting point. The template asks for the minimum data required for CBAM compliance, avoiding unnecessary detail that may confuse suppliers.

Below is a template you can adapt and send to your suppliers. The goal is to make the request as simple as possible while collecting everything needed for CBAM compliance.

Oremly automates this process — we send the request on your behalf, provide a no-login portal for suppliers to upload their data, and AI-extract the relevant fields from whatever format they return. But if you are collecting data manually, use this template:

Subject: UK Carbon Border Adjustment — emissions data request for [product name / part number]

Your supplier has no legal obligation to respond. Many suppliers — particularly smaller manufacturers — may not have measured their emissions. In practice, importers encounter several common scenarios:

• Supplier provides verified data: Ideal. Use the certified emissions figure.
• Supplier provides unverified data: Use it, but note it as unverified in your CBAM return. You may want to request third-party verification in future.
• Supplier provides partial data: Fill gaps using HMRC's default values for the missing fields.
• Supplier provides no data: You must use HMRC default values for the entire product.

The key principle is that you must document your efforts. HMRC expects you to demonstrate that you have made reasonable attempts to obtain supplier data before falling back to defaults. Keep copies of your data requests and any responses.

Supplier data arrives in many formats: emails with numbers embedded in the text, PDF certificates, spreadsheets in various layouts, scanned documents, and sometimes no response at all.

If you are processing data manually, create a standard template and transfer supplier figures into it consistently. Keep the original source document as evidence. If the supplier's figures are in a unit you do not recognise (e.g., kg CO₂ per kg instead of per tonne), convert them carefully and double-check the math.

Oremly's AI extraction handles this automatically — it reads PDFs, spreadsheets, and scanned documents, extracts the relevant emissions data, and presents it for your review alongside the original source.

CBAM data collection is not a one-off exercise. You need fresh data for each reporting period. HMRC requires emissions data that reflects the actual production conditions during the period.

Establish an annual cycle: request data from suppliers at least 60 days before your return is due, chase non-respondents after 30 days, and have a default fallback plan ready. Oremly's automated data requests run this cycle for you, with reminders and escalation.