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

Commissioned by the German Environment Agency (Umweltbundesamt, UBA), this study examines how importers and verifiers can reliably establish the origin of goods and their embedded emissions under the EU's Carbon Border Adjustment Mechanism (CBAM). Prepared by adelphi consult together with Deloitte Wirtschaftsprüfungsgesellschaft and aimplifin, the report addresses two central questions: which documents can credibly prove that a product originates from a specific installation, and how can verifiers overcome the additional challenges posed by complex goods.

The study assesses two categories of evidence: trade and customs documents (such as certificates of origin) and business records (such as production logs and delivery notes). As no single document type can fully verify an installation of origin, the report recommends combining several document types with system-based checks, including enterprise resource planning (ERP) system access, cross-referencing and virtual site visits.

The report further examines sector-specific verification challenges for four complex CBAM goods: cement, fertilisers, iron and steel, and aluminium. It sets out practical recommendations, including standardised documentation templates, harmonised system boundaries and closer collaboration between verifiers and manufacturers, to strengthen the accuracy and consistency of CBAM emissions verification.