Validation and verification

CBAM, accreditation of bodies for the verification of embedded emissions

 

 

In 2026, the European Carbon Border Adjustment Mechanism regulation became operational, requiring the involvement of accredited bodies for carbon-intensive products: Accredia’s provisions regarding accreditation and verification.

EU Regulation 2023/956 (CBAM – Carbon Border Adjustment Mechanism) enhances the transparency and reliability of information regarding emissions embedded in products imported into the European Union.The sectors currently covered include cement, cast iron, iron, steel, aluminium, fertilizers, electricity, and hydrogen.

The accreditation of verification and validation bodies, in accordance with ISO/IEC 17029 and ISO 14065 standards, is essential to ensure data comparability and the credibility of the mechanism, even when verifications take place in complex international contexts.

To define the timelines and rules for the accreditation of bodies and the verification of emissions under the CBAM scheme, Accredia has issued the new Technical circular DC N. 19/2026, which supplements Information circular DC N. 07/2026.

The role and European harmonization

The implementation of CBAM, involving the use of actual values ​​in declarations starting in 2027, is a priority for the European Union and the European Commission’s Directorate-General for Taxation and Customs Union (DG TAXUD).The emissions covered include both direct and indirect emissions, with the exception of products listed in Annex II to EU Regulation 2023/956, for which only direct emissions must be reported.

The EU Delegated Regulation 2025/2551, in particular, defines common rules applicable to both European verifiers and those established in third countries who turn to the national bodies of EU members to obtain accreditation in the CBAM scheme.

To support this objective, the European co-operation for Accreditation (EA) has established a working group dedicated to CBAM, coordinated by Accredia, to foster a shared approach to accreditation activities.

The periodic peer evaluation, with the involvement of the European Commission through the EA Multilateral Agreement Council (MAC), verifies the correct application of the common rules guaranteeing uniformity of the verification procedures and comparability of the data at an international level.

Furthermore, this check limits the risk of forum shopping—that is, the possibility that operators might turn to the body or accreditation pathway perceived as less stringent.

The international dimension of the system

CBAM extends the scope of verification beyond the ETS framework by including emissions embedded in products from facilities located in third countries. Verification bodies must adapt to complex operational environments, complying with local regulations and ensuring data accuracy—including through the use of qualified translators.

Furthermore, accredited international verification entails managing various time zones, differing documentation systems, and diverse operational practices, requiring advanced organizational skills and the ability to coordinate with importers’ headquarters.

Accreditation process for bodies

With Technical circular DC N. 19/2026, Accredia clarifies the accreditation standards and assessment requirements for bodies operating under the CBAM scheme. This information supplements Information circular DC N. 07/2026, which outlines the timelines and procedures for submitting accreditation applications.

Verification and validation bodies intending to seek accreditation for the verification of emissions embedded in goods imported into the Union’s customs territory under the CBAM mechanism must:

– specify the CBAM activity group—as listed in Annex I of EU Delegated Regulation 2025/2551—for which they are seeking accreditation

– be accredited in accordance with ISO/IEC 17029:2022 and ISO 14065:2022 standards

– undergo a program involving a specific number of assessment days, depending on their specific circumstances

Body accredited for ISO/IEC 17029, ISO 14065, and EU ETS

  • 1 day for document review
  • 1 assessment day for extension
  • 1 witnessed assessment for extension

Body accredited for ISO/IEC 17029 and ISO 14065

  • 1 day for document review
  • 2 assessment days for extension
  • 1 witnessed assessment for extension for each requested CBAM activity group

Body accredited for ISO/IEC 17029 and ISO 14065 by a signatory to the IAF MLA for verification and validation

  • 1 day for document review
  • 4 assessment days for accreditation
  • witnessed assessment for accreditation for each requested CBAM activity group