CBAM documentary and evidentiary review.

CBAM is WEETRA's first operational use case. The regulatory environment associated with the Carbon Border Adjustment Mechanism places growing emphasis on the robustness of the evidence underpinning a declared position.

Why CBAM first

As reporting matures from a transitional exercise toward a more rigorously scrutinised obligation, the reliability and traceability of supporting information are becoming as consequential as the reported values themselves. CBAM therefore presents, in concentrated form, the evidentiary problem the Framework was built to address.

What is reviewed

A CBAM review assesses the coherence and traceability of the supporting information relating to:

• goods and their classification;
• installations and facility-level production records;
• embedded emissions documentation;
• calculation inputs and their reproducibility;
• carbon price evidence and adjustment claims;
• the documentary evidence supporting each of the above.

Where exposure arises

Exposure rarely originates in the emissions calculation itself. It originates in the surrounding record: supplier information that is incomplete, calculation files that cannot be traced back to their inputs, assumptions that were never documented, and documents that are not linked to the values they are supposed to support.

A file in this condition can produce an arithmetically correct declaration and still be unable to answer a request for justification.

Relationship to verification

WEETRA does not replace verification by an accredited verifier where such verification is legally required. The review is methodological and precedes, rather than substitutes for, the formal steps that follow.