[Briefing] CBAM verification accreditation can only be granted by national accreditation bodies (NABs) in the EU (and the EEA once incorporated). Asian accreditation systems, even where they already accredit local bodies for ISO 14065 GHG verification, cannot convert that into CBAM accreditation. That does not mean Asia must wait for European verifiers: bodies established outside the EU can apply directly to EU NABs that accept third-country applicants. The real threshold is not whether you can apply, but three things: the governance of a single legal entity, the impartiality look-through rule, and the outsourcing boundary. Using these three rules as the axis, this piece compares Mainland China, Taiwan and Vietnam and sets out three workable regional verification network models.
Adapted from a professional article by CPCD/SSBTi, with an added three-market cross-analysis.
1. CBAM accreditation is a signing right
On 24 August 2026 the European Commission published its Guidance on CBAM Verification and Accreditation for Verifiers and National Accreditation Bodies, finally making the accreditation path clear. The original article makes a key point: CBAM accreditation is in essence a signing right. Only reports signed by a body accredited by an EU NAB can be used by importers to declare actual emissions. Accreditation is just the entry ticket; whether EU importers accept your signature, and whether you keep passing NAB surveillance, is the real threshold of this business.
Why verification volumes will rise
Companies have two routes for CBAM declarations: use EU default values, which need no third-party verification but are usually high; or use actual emissions, which must be independently verified. Two forces will push companies toward actual values:
- Default values carry a punitive mark-up. Under Implementing Regulation (EU) 2025/2621, default values are marked up by 10% in 2026, 20% in 2027 and 30% from 2028 (fertilisers and some products are treated differently; check the text). As free allocation phases down between 2026 and 2034, the economic value of declaring actual emissions grows every year.
- Default values are set by country. Installations close to their country’s sector average gain little from verification. Installations clearly better than the country default, such as EAF steel mills or primary aluminium smelters with a high share of renewable power, have a strong incentive to verify.
A rough check: [default value × (1 + that year’s mark-up) − actual emissions] × export volume × CBAM certificate price, compared against the verification fee. Confirm with your EU importer in advance that they will accept actual values. CBAM verification is per installation, with one report per installation per reporting year, at a reasonable assurance level. Unlike the EU ETS, CBAM verification also assesses the compliance of the installation’s monitoring plan.
2. Three rules that decide everything
Rule 1: Accreditation attaches to a single legal entity and is granted by activity group
Delegated Regulation (EU) 2025/2551 uses EN ISO/IEC 17029 as the basis for accreditation and applies EN ISO 14065, with CBAM-specific requirements on top. ISO 14064-3 is not used as a basis for CBAM verification because it is not specific enough. A body accredited for ISO 14065 under a local accreditation system cannot convert that into CBAM accreditation; the value lies in reusing its management system and staff experience, not in skipping assessment.
Scope is not granted by the six CBAM sectors but by the activity groups defined in the regulation. The original article’s mapping is below (the regulation’s annex prevails):
| Activity group | Accreditation scope | Sector |
|---|---|---|
| I | Cement clinker, cements, hydraulic binders | Cement |
| II | Hydrogen, ammonia | Hydrogen, fertiliser precursors |
| III | Nitric acid | Fertiliser precursors |
| IV | Urea, mixed fertilisers | Fertilisers |
| V | Sintered ore, pig iron, DRI, crude steel | Basic iron and steel |
| VI | Ferro-alloys (FeMn, FeCr, FeNi, etc.) | Iron and steel ferro-alloys |
| VII | Unwrought primary aluminium | Basic aluminium |
| VIII | Iron or steel products, aluminium products | Downstream steel and aluminium |
| L | CO₂ capture, utilisation and storage (CCUS) | Specialist technology |
| LI | Electricity imported into the EU customs territory as a good | Electricity (import case) |
| LII | Verification of indirect emissions from production processes | General emissions accounting |
A verifier may only sign reports within the groups on its accreditation certificate. So when choosing a third party, don’t just ask “Do you have CBAM accreditation?” Ask: “Does your scope cover my products and processes?”
Rule 2: Impartiality looks through to related parties
A verifier must not verify an operator to which it has provided consultancy. Regulation 2025/2551 goes further: if a verifier and a consultancy share common ownership, common governance, common management or personnel, shared resources, common finances, common contracts or marketing, or the payment of commissions for client referrals, the verifier’s impartiality is deemed compromised. In other words, one group company consulting while another verifies the same client does not get around this red line.
Rule 3: Outsourcing has limits
An accredited body may use external individuals or organisations for parts of a verification, but it keeps full responsibility. Independent review, and the preparation and signing of the verification report, cannot be outsourced.
Hard constraints on people and capacity
- Team structure follows the EU ETS: lead verifier, verifier, technical expert, independent reviewer. The independent reviewer must be fully independent of the team; the lead verifier and verifier cannot be the same person; a verifier with sector competence may act as technical expert. The original article concludes that each CBAM verification needs at least three people.
- Site visits are physical by default. Virtual visits or waivers are allowed only under the conditions in Implementing Regulation (EU) 2025/2546, with reasons stated in the report.
- Lead verifier rotation is mandatory. A lead verifier who has led the annual verification of the same installation for five consecutive years with no other lead verifier involved must step away for three years.
- Language and travel. The guidance requires verifiers to assess, before accepting a job, whether they can verify in the installation’s country, including whether they have qualified staff who can communicate in the local language and whether visas and travel are feasible.
3. How Asian bodies obtain accreditation
Only EU NABs can grant CBAM accreditation, and not every NAB accepts applicants from outside the EU. According to the Commission’s state-of-play table dated 1 September 2026 (as cited in the original article), five NABs were then accepting third-country applications: COFRAC (France), Accredia (Italy), RvA (Netherlands), PCA (Poland) and Swedac (Sweden); SNAS (Slovakia) and ESYD (Greece) had agreed to accept them. The Commission keeps updating this table, so check the latest official version before applying. The original article also notes that once accredited by any NAB, a verifier can take on verification work in other countries.
The process has six steps: build the system (ISO 14065, technical procedures, sector competence) → choose a NAB → document review → witness assessment (NAB assessors observe an actual verification) → accreditation → registration in the CBAM Registry. Based on existing accreditation experience, the original article estimates 6 to 12 months overall, longer for bodies without EU ETS experience. Many bodies assume the witness assessment is the hardest part, but the article finds document review just as demanding; once it is passed, the witness assessment may go smoothly, provided English communication is fluent.
There is no standard fee for CBAM accreditation yet. Typical components are an application fee, document and on-site assessment fees by assessor-day, assessor travel (third-country applicants pay for visits), annual surveillance, and reassessment roughly every five years. The only clearly published price so far is Swedac’s application fee of SEK 4,000, which is just the basic administrative charge. As the article puts it: the NAB fee is the ticket; maintaining the team is the ongoing cost.
4. Cross-analysis: Mainland China, Taiwan, Vietnam
None of the three can obtain CBAM accreditation from its local accreditation system, so they start from the same place. The differences are in sector exposure, carbon pricing and language.
| Dimension | Mainland China | Taiwan | Vietnam |
|---|---|---|---|
| Main CBAM exposure | Steel, aluminium, cement and fertilisers; the broadest sector coverage | Mostly steel (about 96% of CBAM goods to the EU); the EU’s second-largest source of fasteners | Mostly steel, about 2.94 Mt to the EU; the EU’s eighth-largest source |
| Most relevant activity groups | Multiple: V, VI, VII, VIII, I, IV | V, VIII (incl. downstream products such as fasteners) | V, VIII (mainly coated flat steel) |
| Local carbon pricing | National ETS expanded to steel, cement and aluminium smelting | Carbon fee standard rate NT$300/t; not yet recognised for deduction under CBAM Art. 9 | ETS pilot since 2025 covering steel, thermal power and cement |
| Verification language | Chinese; largest case volume, greatest need for Chinese-speaking verifiers | Chinese + English; more mature English capability for working with European NABs | Vietnamese; qualified Vietnamese-speaking verifiers are scarce |
| Existing verification base | Many locally ISO 14065-accredited bodies; experience reusable but no exemption from assessment | Limited local ISO 14065 and ETS experience, but strong links with international certification | Local verification capacity still being built |
Taiwan and Vietnam trade figures are from a third-party compilation of Eurostat 2025 data and are for order-of-magnitude reference only; check the original data before any engagement or investment decision.
Three observations from the cross-analysis:
- Demand overlaps heavily in Groups V and VIII. CBAM exports from all three are dominated by steel, and Taiwan and Vietnam are concentrated in downstream steel products. One verification team that knows steel processes can serve the whole region.
- Language is a regional bottleneck. The guidance explicitly requires qualified staff who can communicate in the local language. Even an accredited European body will face high cost, scheduling and communication burdens without a team that can enter Asian factories and understands their underlying data and processes. That is exactly where Asian verification staff are most valuable.
- The supply chain is already cross-border. Many Taiwanese- and Mainland-invested factories operate in Vietnam, and materials and data flow among the three. Verification capacity confined to one market cannot keep up with where clients actually operate.
5. Four entry modes
The original article identifies four ways for Asian bodies to enter the CBAM verification market:
- Apply directly to an EU NAB as a local legal entity. Full control of brand and business, and the signature is your own; but the highest demands on English system documents, staff competence, sector experience and readiness for cross-border assessment. The guidance states that an office in the installation’s country is not mandatory. Being in Asia is not a disadvantage in itself; the disadvantage is in track record and reputation.
- Set up a legal entity in an EU member state and apply from there. European client contracts, the regulatory interface and report responsibility can sit with the European entity. But a new EU entity brings no extra access rights and loses the freedom to choose among NABs; if it still relies on the Asian team, the NAB will assess those people and premises anyway. What is worth doing is acquiring a real body with staff and a track record, not registering a shell.
- Acquire a European body with EU ETS or CBAM verification capability. Possibly the fastest, but accreditation attaches to the entity and its competence: a change of control usually must be notified to the NAB and may trigger an extraordinary assessment, and if key staff leave, the accreditation is hollowed out. If the acquirer’s group provides CBAM consultancy locally, the impartiality look-through rule means the acquired verifier cannot verify those consultancy clients.
- Don’t hold accreditation; partner long-term with an accredited European verifier. The Asian team handles factory sites, local-language source data, sector expertise and upfront data preparation, while the accredited entity carries final verification responsibility. This may be the most practical route for many Asian technical organisations, but the partnership boundary must be designed around the independence and outsourcing rules.
6. Three regional verification network models
Placing the four modes in a three-market context gives three possible regional networks:
Model A | One legal entity, staff deployed across borders
One Asian entity obtains CBAM accreditation and deploys verifiers in several markets. Governance is most centralised, but the NAB will assess staff and premises in every location; cross-border data flows need legal assessment in each jurisdiction beforehand; and where the accredited entity sits shapes both its regulatory exposure and its brand story. Suited to bodies with mature international business and simple governance.
Model B | A regional core entity plus MOU partners
Two markets with similar sector exposure form the core, for example Taiwan and Vietnam, both focused on downstream steel products and linked by heavy cross-border investment, with one entity holding accreditation; a partner in a third market collaborates under an MOU. The MOU design is what makes this work:
- The partner handles only outsourceable work: on-site support and local-language data preparation.
- Independent review and report signing always stay with the accredited entity.
- Fees are paid by workload, never by client referral; no joint marketing and no shared staff.
- If the partner also provides CBAM consultancy, impartiality must be checked case by case so neither side is blocked from serving its clients.
Model C | No accreditation; long-term partnership with an accredited European body
The Asian team focuses on data readiness, monitoring system set-up, sector technical review and on-site support, while the accredited European body carries verification responsibility. Lowest cost and fastest start, and with enough clients possibly the most profitable; the risk is that, holding no accreditation, the team is more replaceable, and stability depends on the long-term relationship with the accredited body.
The original article’s practical advice is a calculation every prospective applicant should run first: How many CBAM verification clients can you expect in the next three to five years? In which activity groups? Do you already have qualified verifiers and real witness cases? Do the fixed costs of obtaining and keeping accreditation match expected revenue? If the answers are not encouraging, you don’t have to hold accreditation yourself. Getting accredited is not the only way to make money in the CBAM third-party market; the real choice is which part of the value chain you intend to control.
7. SSBTi view: we chose the data-readiness end
The impartiality look-through rule forces every participant to answer one question: will you verify, or will you consult? The two cannot coexist in the same web of relationships.
SSBTi positions itself in supplier data readiness, methodology mapping and a traceable evidence chain, which is the Model C position: helping Asian suppliers bring their data to a verifiable state, with verification then carried out by an independent verifier with the applicable accreditation scope. We do not hold CBAM verification accreditation ourselves. This is not a question of capability but of system design: keeping data preparation separate from independent verification is what allows actual CBAM emissions data to be trusted.
For Asian supply chains, where a verifier is established is not the point. The point is: can your data stand up in front of any accredited verifier?
Four things to check when choosing a verifier
- The legal entity that actually takes the engagement and signs the report.
- Which EU NAB accredited it, and the accreditation number.
- Which activity groups the scope covers, and whether it covers your products and processes.
- Whether it has completed CBAM Registry registration and has the staff and resources to verify on site where your factory is.
Claims such as “ISO 14065 accredited”, “long experience in carbon verification” or “applying for CBAM accreditation” are no substitute for formal CBAM accreditation. Cross-check against the Commission’s published verifier information, the relevant NAB’s accreditation database, and the body’s formal accreditation certificate.
Commentary
The commentary on the original article notes that it is practical and grounded, addressing a pain point common to EU exporters: where to find a third party, whether to invest in one, or whether to become one. Because CBAM has not truly started, no valuable local experience has accumulated yet, so the picture can only be assembled from documents and public reports by EU verifiers. This first-hand information is valuable but should be taken as reference only: third parties have a lot of flexibility, including on price, and the differences can be very large.
Attribution and references
Adapted from a professional article by our partner CPCD/SSBTi, with an added three-market cross-analysis and regional network models.
- European Commission: Verification of CBAM emissions (including the 24 August 2026 Guidance on CBAM Verification and Accreditation and the state-of-play table).
- Commission Implementing Regulation (EU) 2025/2546: verification principles.
- Commission Delegated Regulation (EU) 2025/2551: accreditation conditions, supervision and mutual recognition.
- Commission Implementing Regulation (EU) 2025/2621: default value rules.
- Taiwan and Vietnam trade figures: third-party compilation of Eurostat Comext 2025 data (Taiwan, Vietnam), for order-of-magnitude reference only.
This article analyses rules and markets. It is not legal advice and does not endorse any body’s qualifications. Accreditation fees, timelines and NAB acceptance status may change; refer to the latest notices from the European Commission and each NAB.
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