On 27 August 2026, the European Commission added a portal user manual for accredited verifiers and installation operators to its CBAM Registry page. The page explains that operators of non-EU installations can maintain installation and emissions data through Operators of Third-Country Installations (O3CI), which CBAM declarants can then retrieve in the Registry.
This moves the discussion beyond a general explanation of CBAM and into an operational workflow for registration, installation records, emissions data and verification. The Commission's timeline is close: accredited CBAM verifiers can register in the Registry and begin the first verification cycle from September 2026; the first verification reports can be issued from January 2027. For steel-product suppliers serving EU buyers, the practical questions will increasingly be who maintains the data, which installation it covers and whether it can enter the verification process.
The new manual connects four roles, not one universal form
The Registry data chain involves at least the non-EU installation operator, the accredited verifier, the authorised CBAM declarant and the supplier coordinating procurement documents. The operator maintains installation and emissions information in O3CI, the verifier collaborates with the operator and verifies the data, and the declarant uses available verified emissions information for CBAM reporting.
A trader, exporter and actual installation operator may be different legal entities. If a supplier does not control the production installation, company-level product documents cannot simply be treated as installation-level emissions data. A project should first identify the manufacturing site, the entity operating it and the person authorised to maintain its O3CI records.
Prepare account, entity and installation information first
Registry users need an EU Login with two-factor authentication. O3CI registration also covers company details, a corporate email and website, user roles, a company registration certificate, evidence of representation and identification for the representative. The operator workflow then separates company, installation and supporting-document records.
| Preparation layer | Information shown in the official material | What procurement should confirm |
|---|---|---|
| Account and access | EU Login, 2FA, Operator Admin, Operator User | Who administers records and who only reviews or exports data |
| Company entity | Registration number and name, address, contacts, registration and representation evidence | Whether the registered entity is the installation operator and Latin-character details are consistent |
| Production installation | Name, economic activity, full address, UNLOCODE, coordinates, authorised representative | Which physical site made the order and what evidence supports its location |
| Supporting documents | Installation registration, ownership or control, principal activity, operating permit, location evidence | Whether evidence relates to the actual installation rather than merely proving the company exists |
These documents do not necessarily have to accompany every quotation. However, where a buyer intends to use actual emissions data, leaving the entity-to-installation mapping until late can delay data entry and verification.
Emissions data is structured by installation, production year, goods and route
The manual shows emissions records being linked first to a production year and installation, then to goods and production routes. Goods fields include the HS subheading, CN code, TARIC code where applicable and a description. Route records can include specific direct emissions, electricity consumed, an emission factor, specific indirect emissions, relevant qualifying parameters and, where applicable, information on a carbon price paid in the country of origin.
A single company-wide annual average may therefore be insufficient for later system fields or verification questions. Order information should be traceable to the production installation, year, goods classification and route, using consistent units, reporting periods, sources and change records. Access is also divided: an Operator User may view and export emissions information, while an Operator Admin adds, changes or deletes records.
Fastener projects need three routing decisions
- Confirm product scope. CBAM has an iron and steel sector, but that does not mean every steel bolt, nut, screw or washer is automatically covered. Confirm the specific HS/CN classification, the practice of the importing country and the responsibility of the importer or indirect customs representative.
- Identify the installation operator. Where partner factories, coating plants or several sites take part, document the production chain and data boundary instead of merging the trader, exporter and installation operator by default.
- Choose the data path. Will the importer rely on default values or require actual verified emissions? For actual values, agree the year, installation, classification, units, template, verification timing and sharing method.
O3CI does not make every field indiscriminately public. The Commission describes protection for business-sensitive information; declarants can retrieve installation and emissions information and use an EORI number to establish data collaboration. Suppliers should clarify what is shared with the declarant and what evidence is reviewed only by the verifier or competent authority.
Turn the RFQ into an executable data checklist
Instead of asking only whether a supplier can “support CBAM”, an EU buyer can confirm the proposed HS/CN classification, production installation and year, default or actual-data route, O3CI record owner, verifier arrangements, and when the declarant will provide its EORI and field template.
After the customer defines applicability and responsibilities, Wohe can coordinate product descriptions, drawings or samples, material and grade, finish, batch, packaging, existing export documents and available production or quality information. This support does not replace the importer's CBAM applicability decision, the installation operator's emissions records or the accredited verifier's conclusion.
For an EU steel-fastener enquiry, send the drawing or sample, material, finish, destination EU country, proposed HS/CN code and the importer's required data fields. Matching the order to its production installation early makes quotation, verification and declaration coordination more consistent. Review the product range and submit the project through the contact page.
Official sources: European Commission CBAM Registry, Verification of CBAM emissions and CBAM sectors.
