What Is an Embedded Carbon Record?
The definitive product-specific guide: what the document is, what it contains, who needs one, and how to create yours under EU CBAM Regulation 2023/956.
What is an embedded carbon record?
The four things every embedded carbon record contains
Each verified record on this platform contains four components:
- A SHA-256 cryptographic hash — a 256-bit fingerprint of the source verification document, computed in the user's browser before upload. This is what makes the record tamper-evident: any future modification produces a different hash, so EU buyers and customs auditors can confirm the document they're looking at is the document the verifier signed.
- The verified embedded emissions value — tonnes of CO₂ equivalent per tonne of product (tCO₂e/t), broken into direct and (where applicable) indirect components per Annex IV of EU Regulation 2023/956. For steel, this is typically in the range 0.4–2.4 tCO₂e/t depending on production route; for aluminium, 2.0–20.0 tCO₂e/t depending on grid mix.
- The ISO 14065 verifier statement — the formal attestation by an accredited verification body that the emissions calculation conforms to CBAM methodology. The verifier's name, accreditation number, and accreditation body (DAkkS, UKAS, ACCREDIA, ANAB, SANAS, etc.) are stored alongside the value.
- A permanent verification URL — the unique, resolvable web address at which the EU buyer (and, if requested, EU customs authorities) can confirm the record exists and matches what the manufacturer reported. The URL is designed to resolve for the full three-year audit retention window required under CBAM.
Who needs an embedded carbon record?
You need an embedded carbon record if all three are true:
- You are a manufacturer located outside the European Union, the European Economic Area, or Switzerland.
- You produce or process goods classified under one of the six CBAM commodity codes — steel (CN chapters 72, 73), aluminium (chapter 76), cement (2523), fertilisers (2814, 2834, 3102, 3105), hydrogen (280410), or electricity (2716).
- Your annual exports to the EU exceed 50 tonnes by mass across the relevant commodity code (the de minimis exemption threshold per Article 2(3) of Regulation 2023/956).
Below the 50-tonne threshold, the documentation obligation falls on the EU importer rather than mandating embedded carbon records — but EU buyers may still request the record to demonstrate due diligence under broader sustainability reporting frameworks.
Record vs declaration — what's the difference?
The embedded carbon record is the evidence. The CBAM declaration is the filing.
- The record lives at a permanent URL controlled by the manufacturer (or their delegated platform), contains the verified emissions value, and is referenced by ID or URL in the EU buyer's CBAM paperwork.
- The declaration is the annual regulatory submission filed by the EU-established authorised declarant via the CBAM Registry, typically by 30 September each year for the prior calendar year's imports.
The first annual CBAM declaration is due 30 September 2027, covering 2026 imports. Without a verified embedded carbon record, the declaration must use EU default values — typically two to three times higher than verified actuals. See Embedded Carbon Record vs CBAM Declaration vs O3CI for the full three-way comparison.
What an embedded carbon record looks like in practice
When you store a verified calculation on this platform, your EU buyer receives a single URL like https://embeddedcarbonrecord.com/vault/[unique-id]. Visiting that URL shows:
- The product (CN code, sector, country of production)
- The reporting year
- The verified embedded carbon value (direct and indirect components)
- The ISO 14065 verifier and their accreditation body
- The SHA-256 hash of the supporting document
- The original verification date and the verifier's contact information
Nothing else. Your source verification document — with all the proprietary process detail, supplier data, and operational specifics — stays in your possession. The platform only ever sees the hash and the headline figures.
Country examples
- South Africa. Producers exporting steel, aluminium, or cement to the EU work with SANAS-accredited or internationally-accredited ISO 14065 verifiers. SANS standards apply to in-country measurement methodology. See the South Africa CBAM guide.
- China. Verifications typically performed by Bureau Veritas China, SGS China, TÜV Rheinland China, or DNV China — all CNAS-accredited. China ETS price may be partly deductible under Article 9. See the China CBAM guide.
- India. Verifications by NABCB-accredited or international firms. India introduced GHG Emission Intensity Targets in January 2026, partly as a CBAM-resilience measure. See the India CBAM guide.
- Türkiye. Geographic proximity makes Türkiye Europe's second-largest steel supplier. TÜRKAK-accredited verifiers offer strong local capacity, and high EAF-route share gives Turkish producers a structural CBAM advantage. See the Türkiye CBAM guide.
How to create yours
Three steps:
- Find an ISO 14065 verifier in your country via the global verification directory, or work with the verifier your EU buyer specifies.
- Get the calculation verified — supply your activity data (fuel, electricity, raw materials, production volumes), and the verifier produces the formal statement per CBAM Annex IV methodology.
- Store the verified record at our vault — the SHA-256 hash is computed in your browser, the permanent URL is generated, and you supply that URL to your EU buyer for their CBAM declaration.
Pricing starts at contact us for pricing for a single commodity line. See vault pricing for full tier details.
Frequently asked questions
How long does an embedded carbon record need to be accessible?
CBAM Implementing Regulation 2023/1773 requires records and supporting documentation to be accessible for at least three years from the date of the relevant annual CBAM declaration. Practical implementations target longer retention windows to accommodate audit complexity and potential disputes over historical declarations.
Can I create an embedded carbon record without a verifier?
During the CBAM transitional period (October 2023 to December 2025), self-declared estimates were permitted in quarterly reports. From January 2026 onward (the definitive period), embedded emissions must be verified by an ISO 14065 accredited body to qualify for actual values rather than EU defaults. Self-declared estimates are no longer accepted for the annual CBAM declaration.
Who pays for the embedded carbon verification?
The non-EU manufacturer typically pays the verifier directly. Verification costs range from approximately $5,000 to $50,000 per installation per year, depending on sector, complexity, and the chosen verifier. For most exposed producers, the verification cost is recovered many times over within a single year by avoiding EU default values.
Is the embedded carbon record the same as O3CI?
No. O3CI is the EU's official Operator Portal where non-EU producers can submit data directly into the CBAM Registry. The embedded carbon record is the underlying verified evidence document that supports whatever is submitted via O3CI or via the EU authorised declarant. See the full comparison: O3CI vs Private Vault.
What happens if my embedded carbon record URL stops working?
A broken record URL referenced in a CBAM declaration creates a regulatory audit liability — both for the non-EU manufacturer and the EU buyer who relied on that URL in their declaration. This is why permanent vault platforms specify multi-year retention guarantees. Avoid hosting embedded carbon records on URLs you control directly unless you can guarantee uptime through the full three-year audit window.
Can one embedded carbon record cover multiple shipments?
Yes. An embedded carbon record represents the embedded emissions per unit produced for a given installation, reporting period, and product specification. A single record can cover all shipments of that product from that installation throughout the reporting year. Different installations, different product specifications, or different reporting years require separate records.
Related pages
- What Is Embedded Carbon? — the broader concept guide explaining how embedded carbon is calculated and why CBAM requires it
- Embedded vs Embodied Carbon — disambiguation of the CBAM term from the construction-industry term
- Store Your Embedded Carbon Record — pricing tiers and the upload flow
- Global Verifier Directory — ISO 14065 verifiers by country
- CBAM Authorised Declarant — the EU-side party who files the declaration