What if your supplier cannot provide CBAM emissions data?

This guide concerns the UK Carbon Border Adjustment Mechanism, due to start on 1 January 2027, not the EU scheme. HMRC’s policy summary was updated on 9 September 2026 following the laying of the emissions and verification regulations. Follow the current notices and guidance for the transaction and reporting period.

1. Work out what is actually missing

A supplier may mean “we do not have the number”, “we have it but it is not verified”, or “we buy this product from someone else”. Each needs a different follow-up.

• No producer identified: ask the distributor who manufactured the goods and which production installation supplied them.
• A number without context: request the product, installation, monitoring period, units and calculation boundary it describes.
• No verification evidence: request the verification report or good-specific verification summary showing the relevant data was verified as satisfactory.
• Confidential information: ask whether the producer can supply a suitable good-specific summary through an agreed secure channel, rather than circulating its entire commercial file.

A company-wide footprint, an environmental product declaration or an EU CBAM file can be useful background, but none automatically proves that the UK CBAM actual-emissions requirements are met.

2. Send a specific follow-up

Include your item references and the imports concerned so the supplier can route the request to the right production or sustainability contact. For example:

Agree a response date and name someone in your own business to follow up. Keep the original request and reply. “Supplier contacted” is progress, but it is not the same as “actual emissions verified”.

3. Understand what a default value is

A default is an official value for the relevant CBAM good, not a number you choose. HMRC’s current policy summary provides for one default emissions value per CBAM good from 1 January 2027, to be published in a GOV.UK notice before implementation. Use the applicable official notice and retain its reference and version; do not assume a supplier average or an EU default can be substituted.

Where verified actual data is available, it still needs to cover the appropriate product and permitted monitoring period. A producer’s newest file is not automatically the right file for every import. Cement and fertiliser data can also require composition-related conversions; ask a specialist rather than multiplying incompatible units.

The default route can enable reporting when actual data is unavailable, but it does not fill gaps in importer identity, classification, origin, customs value or goods weight. Nor does it establish eligibility for Carbon Price Relief. Keep those questions separate.

4. Keep useful records while you wait

• Legal importer, declaration and invoice references.
• Product description, confirmed commodity code and origin.
• Import date, relevant customs value and goods weight, with source records.
• Producer, installation and supplier contact, where known.
• Emissions-data status, the evidence received and what still needs checking.
• Request date, response date, follow-up owner and next review date.

Describe the gap in ordinary language: “2026 producer intensity supplied; verification summary still requested” is more useful than “data incomplete”. Retain the original file if a supplier later sends a correction, and note which version your reviewer accepted.

Example: the distributor sends a sustainability brochure

Fictional example. A distributor replies to a request about an imported steel product with a brochure saying that its business is carbon neutral. The importer keeps the brochure as correspondence, but does not enter zero emissions or mark the goods’ actual intensity as verified.

The next request identifies the specific goods and asks for producer-level evidence. The importer continues collecting weight and customs records and flags the official default route for review if acceptable actual data remains unavailable. No tax amount is invented while the necessary values are unresolved.

When to get help

Ask a customs or CBAM adviser if classification, special customs procedures, production boundaries, verifier eligibility or the applicable monitoring year is uncertain. If a reporting deadline approaches, do not assume supplier silence extends it.