Embedded Carbon Record vs CBAM Declaration vs O3CI
CBAM compliance involves three distinct components operated by different parties. Understanding the difference between the manufacturer's record, the importer's declaration, and the government portal is critical for compliance.
1. The Embedded Carbon Record (Non-EU Manufacturer)
The Embedded Carbon Record is the verified calculation of greenhouse gas emissions generated during the production of a specific good. This document is produced by the non-EU manufacturer and verified by an ISO 14065 accredited body. It states the embedded emissions in tonnes of CO2e per tonne of product.
This is the foundational data source. Without it, the EU importer is forced to use punitive EU default values.
2. The CBAM Declaration (EU Importer)
The CBAM Declaration is the legal filing submitted by the EU importer (the "Authorised CBAM Declarant"). It aggregates all imports made during the calendar year, multiplies the imported volumes by the embedded carbon figures provided by the manufacturers, and calculates the total CBAM certificates owed.
The declaration is an annual legal obligation due by 31 May of the following year.
3. The O3CI Portal (EU Commission)
The O3CI (CBAM Transitional Registry) is the IT system operated by the European Commission. It is the platform where EU importers submit their declarations and where non-EU installation operators can optionally register to share their emissions data securely with importers.
| Component | Who is responsible? | What is it? | When is it needed? |
|---|---|---|---|
| Embedded Carbon Record | Non-EU Manufacturer | Verified calculation of tCO2e/tonne | Before export / at time of contract |
| CBAM Declaration | EU Importer | Annual legal filing of total emissions | By 31 May annually (from 2027) |
| O3CI Portal | EU Commission | Government IT infrastructure | Ongoing platform access |