CBAM MRV explained: monitoring, reporting, verification
Monitoring, Reporting and Verification — universally abbreviated to MRV — is the process by which embedded greenhouse gas emissions are measured, documented, and independently confirmed. It is the technical foundation on which CBAM certificate calculations rest. Importers who understand MRV are better positioned to manage their certificate costs and engage productively with their suppliers.
Why MRV matters: default values vs actual data
The CBAM certificate obligation is determined by the quantity of embedded emissions in imported goods. Those emissions can be established in one of two ways:
• Default values: published by the European Commission based on average production emissions for each sector and country of origin. Intentionally conservative — set at the upper range of typical production intensities, not the average.
• Actual verified data: obtained directly from the goods' producer, confirmed by an independent accredited verifier.
For most importers sourcing from producers with modern facilities or low-carbon energy, actual verified emissions will be materially lower than the default values. The difference directly reduces the certificate obligation. In our experience, the savings typically range from 20% to 40% of the default-value certificate cost, depending on sector and supply chain.
The three components of MRV
1. Monitoring
Monitoring is the continuous or periodic measurement of greenhouse gas emissions at a production facility. Under the CBAM framework, producers monitor their emissions in accordance with Commission Implementing Regulation (EU) 2023/1773. Key elements include:
• Identifying all emission sources within the production boundary relevant to the exported goods
• Applying approved measurement methodologies — calculation-based or direct measurement approaches
• Maintaining detailed records of production volumes, fuel consumption, process inputs, and emissions calculations
• Allocating embedded emissions to specific product types on a verifiable basis
2. Reporting
Reporting is the compilation of monitored data into a formal emissions report that can be provided to the importing company and submitted to the CBAM Registry. The report must cover a defined period and must include:
• Total production volume and the volume exported to EU markets
• Gross direct embedded emissions and, where applicable, indirect embedded emissions
• The specific embedded emissions per tonne of product — the figure that directly determines certificate cost
• Details of the monitoring methodology applied
• Any assumptions or substitute values used where direct measurement was not available
3. Verification
Verification is the independent confirmation by an accredited third-party verifier that the monitoring and reporting has been carried out correctly and that the reported emissions figures are accurate. The verifier must be accredited under the relevant national accreditation body and must be independent of the producer.
For CBAM purposes, verifiers operating in third countries — outside the EU — must meet standards equivalent to the EU ETS Accreditation and Verification Regulation. The Commission has published guidance on acceptable third-country verification schemes.
What importers need from suppliers
To use actual verified emissions data rather than default values, importers must obtain:
1. A verified emissions report covering the relevant production period, prepared in accordance with CBAM methodology.
2. Confirmation of the verifier's accreditation status and independence.
3. The specific embedded emissions figure per tonne of product in the format required by the CBAM Registry.
Securing this documentation requires direct engagement with suppliers — ideally established through a data-sharing agreement that sets out an ongoing annual obligation for the supplier to provide verified data. Suppliers who have previously engaged with the EU ETS or with other carbon reporting frameworks will typically find this straightforward. Those doing it for the first time may need practical support.
MRV capability by region
MRV capability varies significantly across the major exporting regions. Understanding this landscape helps importers prioritise their supplier engagement:
• European Economic Area: generally have established ETS-aligned MRV systems. Straightforward to obtain verified data.
• Turkey: many larger producers have invested in MRV systems in anticipation of CBAM. Capability varies by sector and company size — larger steel and cement producers are typically well-positioned.
• China: MRV capability is improving as China's own ETS matures, but documentation to EU standards remains inconsistent. Significant variation between state-owned and private producers.
• India: MRV infrastructure is at an earlier stage. Many producers will need practical support to meet CBAM verification requirements. Allow additional lead time for Indian supplier engagement.
How we can help
CBAM-Assured's supplier engagement service supports importers in obtaining MRV-compliant emissions data from suppliers across all major exporting regions. This includes supplier communication templates, guidance on acceptable verification schemes, and review of emissions reports before submission to the CBAM Registry. Contact us to discuss your supply chain.