Identification of possibilities to prove the origin of a product from a specific installation

The Carbon Border Adjustment Mechanism places new demands on the monitoring, reporting and verification of emissions from imported goods. A central challenge is proving not only the country of origin, but the specific installation where a product was manufactured. This is particularly complex for goods such as cement, fertilisers, steel and aluminium, where production often involves several facilities, precursors and supply chain steps across borders.

This report, prepared for the German Environment Agency with contributions from adelphi, examines which documents and verification methods can support reliable proof of origin under CBAM. It finds that no single document is sufficient on its own. Instead, robust verification requires the combined use of customs records, delivery notes, production documents, ERP system checks and sector specific approaches.

Key findings include:

• Certificates of origin and customs documents can help establish the country of production, but usually cannot prove the specific installation.
• Delivery notes, production records and ERP system extracts can support tracing at installation level when they are cross checked and verified.
• Complex goods require sector specific verification approaches to avoid data gaps, double counting and inconsistent allocation of emissions.