The CBAM Monitoring Plan: What Non-EU Manufacturers Need to Know

With the EU Carbon Border Adjustment Mechanism (CBAM) definitive phase now underway, one requirement that is catching many non-EU manufacturers off guard is the monitoring plan. While the concept is borrowed from the EU Emissions Trading Scheme (ETS), it is new territory for most manufacturers outside the EU. This post explains what a monitoring plan is, who needs one, what it must contain, and why it matters for your CBAM compliance.

What Is a Monitoring Plan?

A monitoring plan is a formal document that describes how a manufacturing installation tracks and calculates its embedded emissions throughout the year. Think of it as the rulebook your facility follows when collecting the data that ultimately feeds into your CBAM emissions report.

The monitoring plan is not submitted to the EU Commission directly. Rather, it is an internal document made available to your accredited verifier, who will review it as part of the verification process to confirm that your emissions data has been collected in a consistent, accurate, and auditable way.

The requirement is established in Commission Implementing Regulation (EU) 2025/2547, which lays down the detailed calculation methodology for the CBAM definitive phase.

Who Needs a Monitoring Plan?

Any non-EU manufacturer that wants to report actual emissions — rather than fall back on default values — needs a monitoring plan in place for the reporting period in question.

If you are content to use default values, a monitoring plan is not required. However, as we have explained in previous posts, default values tend to be conservative and will in most cases result in higher CBAM costs for your EU clients, which puts you at a commercial disadvantage compared to competitors who can provide verified actual data.

What Must a Monitoring Plan Include?

The regulation sets out a minimum list of elements that every monitoring plan must cover. In plain terms, these are:

1. Installation and process description

A clear description of the installation and its production processes, including a list of all CBAM goods produced by CN code and their functional units (e.g., tonnes of goods, kg of nitrogen, tonnes of clinker).

2. Production routes

A list of all production routes used at the installation and which goods are produced through each one.

3. Source streams and emission sources

An inventory of all fuels and raw materials that give rise to emissions, and all the points in the installation where greenhouse gases are released.

4. Monitoring methodology

A detailed description of how emissions are calculated for each source stream and emission source — whether through calculation-based methods (using activity data and emission factors), a mass balance approach, or continuous measurement systems (CEMS). The formulae and data sources used must be specified.

5. Calculation factors and sampling plan

How parameters such as emission factors, net calorific values, carbon content, and biomass fractions are determined — including the frequency of laboratory analyses and the standards applied.

6. Heat, electricity, and waste gas flows

Whether measurable heat or waste gases are exchanged between production processes or with other installations, and how electricity consumption is monitored, including whether a power purchase agreement or direct technical link to a specific generator is in place.

7. Precursors

Which CBAM precursor materials (inputs that are themselves CBAM goods) are used in each production process, where they come from, and how their embedded emissions are determined.

8. Control system

A description of the quality assurance and control measures in place to ensure data integrity — covering equipment calibration, IT system controls, segregation of duties, internal reviews, and document management. All records must be retained for at least six years.

A Few Practical Points

The monitoring plan must be written in English. This is an explicit requirement under the regulation, regardless of the country in which the installation is located.

It must be in place before the reporting period begins — or at least before data collection starts. Retrofitting a monitoring plan at the end of the year to describe what you did is not the same as following a pre-defined methodology from day one, and verifiers will scrutinize this.

It is a living document. If your production processes, input materials, or monitoring methods change, the monitoring plan should be updated accordingly. Any changes and the reasons for them must be documented.

It must be consistent year over year unless there is a justified reason to change methodology. Verifiers look for consistency and comparability over time as one of the core monitoring principles.

Why Does It Matter?

The monitoring plan is the foundation of the entire emissions calculation process. Without a robust monitoring plan, even well-intentioned data collection can fall apart under verifier scrutiny — leading to material non-conformities, corrections, and delays that create headaches for you and your EU clients.

Beyond verification, a well-structured monitoring plan also makes your own life easier. It codifies your data collection processes, reduces the risk of errors and gaps, and gives you a clear framework to follow year after year.

How Carbon Glance Can Help

At Carbon Glance, our software for non-EU manufacturers is built around the EU CBAM methodology laid out in Implementing Regulation (EU) 2025/2547. We guide manufacturers through the full process — from setting up their monitoring methodology and documenting their production processes, to calculating specific embedded emissions and preparing data for verification.

You can get started for free by clicking Try Now on the landing page and creating your Operator account in minutes.