CBAM Maturity · Carbon Border Adjustment Mechanism (Regulation (EU) 2023/956)
Your imported embedded emissions, measured against CBAM and turned into a costed action plan.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
CBAM Maturity · Carbon Border Adjustment Mechanism (Regulation (EU) 2023/956)
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One Regulation (EU) 2023/956 (CBAM) assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
This mechanism (one level, the level above, and the action linking the two) is what turns an observation into a trajectory.
Does the embedded emissions data used in your declarations come from the production installations?
- N1
No producer data is collected. Declarations rely entirely on default values.
- N2
A few producers have supplied data, following ad hoc requests. The format varies and mapping to imported flows is reconstructed manually.
- N3
A standardised data request is sent to all relevant producers. Real data covers most imported volumes and is mapped to CN codes.
- N4
Obtaining data is contractualised, gaps are chased on a set schedule, and received values undergo a documented plausibility check before integration.
- N5
Data is verified by an accredited third party, compared period on period, and results feed sourcing decisions with a documented follow-up.
Action to move from L2 to L3
Roll out a single emissions questionnaire to all relevant producers, indexed to imported CN codes, and set its collection as a standing item on the quarterly supplier review.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurementon CBAM.
What this framework covers
CBAM has applied since 1 October 2023 as a reporting obligation, ahead of the financial regime coming into force. It covers six groups of goods: iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. The importer, or its authorised customs representative, must determine direct embedded emissions and, for certain goods, indirect emissions, link them to the imported CN codes, and document the method used. The regulation also governs deduction of any carbon price already paid in the country of origin and its interaction with Directive 2003/87/EC.
In practice, the difficulty is not legal, it is industrial and informational. Emissions data does not sit in the ERP: it sits with the producer, often outside the European Union, sometimes behind several intermediaries. Do you know what share of your imported volumes is covered by real producer data rather than default values? Who in the organisation owns the declaration: procurement, customs, finance, or no one in particular? What happens when a supplier fails to respond before the reporting period closes?
One confusion is worth clearing up: CBAM is not an extension of the emissions trading scheme to your own installations. It concerns the goods you import, and therefore the emissions of a third party that you nonetheless have to justify. Another point often underestimated: the mechanism reshapes purchasing policy, since two suppliers at the same ex-works price no longer have the same landed cost once the carbon intensity of their process is factored in. The subject moves out of the environment team and into sourcing.
A compliance check ends in a yes or no: the declaration was filed, the data is acceptable or it is not. The maturity assessment answers a different question. What level of control does your collection, calculation, verification and reporting chain actually have, and what precise action moves each theme up a level. The result is not an opinion, it is a costed trajectory, comparable across business units and over time.
Within Datamensio, the CBAM framework is ready to use and adaptable. The AI adjusts the themes, questions and levels to your goods scope, or builds a custom version from your own documents: purchasing procedures, supplier specifications, CN code matrices.
Reference standard: Regulation (EU) 2023/956 (CBAM)
The themes assessed
Scope and identification of goods
Mapping of imported flows, mapping to covered CN codes, identification of composite goods, updates when sourcing changes.
Governance and reporting responsibilities
Declarant status or use of a customs representative, appointment of an owner, alignment across procurement, customs, finance and sustainability, sign-off before filing.
Data collection from producers
Contractual clauses for obtaining data, response rate from installations, handling of intermediaries and traders, procedure for non-response.
Method for calculating embedded emissions
System boundaries, direct and indirect emissions, precursors, choice between actual data and default values, traceability of assumptions.
Quality, verification and evidence
Internal checks on received data, use of an accredited verifier, retention of supporting evidence, audit trail from calculation to declaration.
Carbon price paid in the country of origin
Identification of applicable schemes, justification of amounts paid, calculation of deductions, documentation of rebates and offsets.
Certificates and financial exposure
Estimation of certificate volumes, provisioning, tracking of the reference price, integration into budgets and cost of goods.
Information systems and tooling
Data sources, interfacing between ERP and customs declarations, automation of calculations, reliability of exports to the transitional registry.
Procurement and sourcing strategy
Carbon criteria in tenders, trade-offs between suppliers, material substitution, dialogue with producers on their processes.
Regulatory monitoring and improvement
Tracking of implementing acts and scope extension, lessons learned by reporting period, updating of procedures.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Can CBAM be certified?
No. It is a directly applicable EU regulation, with reporting obligations and data verification by an accredited verifier. The assessment measures the maturity of your set-up and prepares you for these deadlines, it does not issue any certificate.
How does this differ from a reporting compliance check?
A compliance check verifies that a declaration was filed and that its data is acceptable. The maturity assessment places your collection, calculation and verification practices on a progressive scale, then indicates the action that moves you up a level. The two are complementary.
Who should complete the assessment?
The questions cover organisation, data and methods, not process chemistry. A customs manager, a buyer and a carbon lead cover the essentials. Collaborative mode lets technical questions be assigned to the right contributor.
How long does the assessment take?
The short version can be completed in a single working session. The full version, in collaborative mode with several contributors, spans one to two weeks, most of the time going into consolidating information held by procurement and customs.
Can the framework be adapted to our goods scope?
Yes. The themes, questions and levels can all be modified, and the AI can produce a version tailored to steel, aluminium or cement based on your internal documents. The framework stays under your control.
How does CBAM relate to the emissions trading scheme?
CBAM concerns the emissions of imported goods, Directive 2003/87/EC concerns those of your own installations. Monitoring data, calculation methods and system boundaries are largely transferable. A cross-cutting roadmap allows both assessments to be cross-referenced without duplicating actions.
Does the assessment help quantify financial exposure?
It measures the maturity of the set-up, in particular the ability to estimate certificate volumes and provision for them. Each gap identified opens an action plan item with an associated cost, timeline and impact on the score.
Where is the data hosted?
In France, with OVH, backed up at Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.