MRV Fundamentals: Monitoring, Reporting and Verification Under CBAM
Monitoring,Reporting and Verification — universally abbreviated to MRV — is the process bywhich embedded greenhouse gas emissions are measured, documented, andindependently confirmed. It is the technical foundation on which CBAMcertificate calculations rest. Importers who understand MRV are betterpositioned to manage their certificate costs and engage productively with theirsuppliers.
Why MRV matters: default values vs actual data
TheCBAM certificate obligation is determined by the quantity of embedded emissionsin imported goods. Those emissions can be established in one of two ways:
• Default values: published by the European Commission based on averageproduction emissions for each sector and country of origin. Intentionallyconservative — set at the upper range of typical production intensities, notthe average.
• Actual verified data: obtained directly from the goods' producer, confirmed byan independent accredited verifier.
Formost importers sourcing from producers with modern facilities or low-carbonenergy, actual verified emissions will be materially lower than the defaultvalues. The difference directly reduces the certificate obligation. In ourexperience, the savings typically range from 20% to 40% of the default-valuecertificate cost, depending on sector and supply chain.
The three components of MRV
1. Monitoring
Monitoringis the continuous or periodic measurement of greenhouse gas emissions at aproduction facility. Under the CBAM framework, producers monitor theiremissions in accordance with Commission Implementing Regulation (EU) 2023/1773.Key elements include:
• Identifying all emissionsources within the production boundary relevant to the exported goods
• Applying approvedmeasurement methodologies — calculation-based or direct measurement approaches
• Maintaining detailedrecords of production volumes, fuel consumption, process inputs, and emissionscalculations
• Allocating embeddedemissions to specific product types on a verifiable basis
2. Reporting
Reportingis the compilation of monitored data into a formal emissions report that can beprovided to the importing company and submitted to the CBAM Registry. Thereport must cover a defined period and must include:
• Total production volume andthe volume exported to EU markets
• Gross direct embeddedemissions and, where applicable, indirect embedded emissions
• The specific embeddedemissions per tonne of product — the figure that directly determinescertificate cost
• Details of the monitoringmethodology applied
• Any assumptions orsubstitute values used where direct measurement was not available
3. Verification
Verificationis the independent confirmation by an accredited third-party verifier that themonitoring and reporting has been carried out correctly and that the reportedemissions figures are accurate. The verifier must be accredited under therelevant national accreditation body and must be independent of the producer.
ForCBAM purposes, verifiers operating in third countries — outside the EU — mustmeet standards equivalent to the EU ETS Accreditation and VerificationRegulation. The Commission has published guidance on acceptable third-countryverification schemes.
What importers need from suppliers
Touse actual verified emissions data rather than default values, importers mustobtain:
1. A verified emissions reportcovering the relevant production period, prepared in accordance with CBAMmethodology.
2. Confirmation of theverifier's accreditation status and independence.
3. The specific embeddedemissions figure per tonne of product in the format required by the CBAMRegistry.
Securingthis documentation requires direct engagement with suppliers — ideallyestablished through a data-sharing agreement that sets out an ongoing annualobligation for the supplier to provide verified data. Suppliers who havepreviously engaged with the EU ETS or with other carbon reporting frameworkswill typically find this straightforward. Those doing it for the first time mayneed practical support.
MRV capability by region
MRVcapability varies significantly across the major exporting regions.Understanding this landscape helps importers prioritise their supplierengagement:
• European Economic Area: generally have established ETS-aligned MRV systems.Straightforward to obtain verified data.
• Turkey: many larger producers have invested in MRV systems inanticipation of CBAM. Capability varies by sector and company size — largersteel 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 variationbetween state-owned and private producers.
• India: MRV infrastructure is at an earlier stage. Many producerswill need practical support to meet CBAM verification requirements. Allowadditional lead time for Indian supplier engagement.
How we can help
CBAM-Assured's supplier engagement service supports importers in obtaining MRV-compliantemissions data from suppliers across all major exporting regions. This includessupplier communication templates, guidance on acceptable verification schemes,and review of emissions reports before submission to the CBAM Registry. Contactus to discuss your supply chain.