Your embedded emissions figure only countsif a verifier can trace it.

Under the EU Carbon Border Adjustment Mechanism, actual embedded emissions for aluminium, iron and steel must be verified by an accredited verifier, or default values apply. INSUS assembles installation-level emissions from your own production, energy and precursor records into the methodology's structure, and keeps every figure traceable to its source. It assembles and evidences. It does not verify or declare.

  • 01

    Actual values need accredited verification.

  • 02

    Production records are the evidence for the declaration.

  • 03

    It assembles and evidences. It does not verify or declare.

The problem

A reporting obligation that is reallya data-provenance obligation.

CBAM does not mainly ask metals producers to calculate something difficult. It asks them to prove to an accredited third party that a number came from their own installation's records using a prescribed methodology. Where verified installation-level data is missing, default values apply. Precursor emissions count by default, so the declaration also depends on upstream data the producer may not own, and gaps created now cannot be filled retrospectively.

CBAM evidence timeline from production month through monitoring to verification
01
02
03
  • 01Production month: the records are created
  • 02Monitoring against the methodology
  • 03Verification: gaps can no longer be filled

The shift

From assembling a numberto maintaining an evidence base.

The declaration is an annual event. The evidence behind it is produced continuously, or it is not produced at all.

Today

Emissions data assembled as a project

  • Figures are reconstructed by hand from spreadsheets and plant records.
  • Traceability from declared figure to source is held informally.
  • Gaps are discovered during verification, when it is too late.

With INSUS

An evidence base that accrues with production

  • The evidence base is maintained as production data accrues.
  • Every declared number is traceable to the record behind it.
  • Regulation and official guidance are queryable, with citations.

How it works

From plant recordsto verifiable declaration inputs.

Delivered through ExpertFlow AI for the regulation, guidance and documentation layer, with tailored data assembly over plant systems where needed. Nothing here generates emissions values. It assembles and evidences what the plant already measures. Qualified people own every figure.

  1. Connect

    Gather production, energy and precursor records

    Connect read-only to production records by goods category, energy and metering data, fuel and electricity records with emission factors, precursor and input material records with supplier documentation, the existing monitoring plan and applicable CBAM texts.

  2. Understand

    Map your data onto the methodology's structure

    Map the installation's own data onto what the methodology requires: production by goods category, direct and indirect energy, fuels and factors, precursor quantities and their embedded emissions, and attribution across products.

  3. Detect

    Find gaps before a verifier does

    Check completeness and consistency across periods and sources, and track supplier-provided precursor data by documentation status. Nothing is predicted and no emissions values are modelled.

  4. Advise

    Compile figures and the documentation behind them

    Compile embedded emissions per goods category with each figure linked to its source records, and draft monitoring and calculation documentation for verification review. Where interpretation is open, the ambiguity is surfaced rather than resolved silently.

  5. Verify

    Carry verifier findings into the next cycle

    Track verifier findings and feed them back so the next cycle starts from corrections rather than from scratch. Progress is measured by traceability coverage, gaps closed before verification and preparation effort.

Document and data-assembly layers reading plant records, with compliance professionals and an accredited verifier as separate human steps

Getting started

Start with one installationand one goods category.

For producers exporting aluminium, iron or steel goods to the EU, and for importers who need installation-level data from them. Delivered through ExpertFlow AI for the regulation and documentation layer, with tailored assembly over plant systems where needed. Expert Services can help with discovery and gap assessment. Not a verification service, not accreditation, and not legal advice.

  • What we need. Read-only access to ERP and production reporting, MES, energy management, procurement records for fuels and precursors, document management and any existing carbon accounting tools, plus the monitoring plan and prior reporting.
  • What you see first. A gap assessment on one installation and one goods category: what the methodology requires, what your records actually support, and the distance between them.
  • Where the limits are. It works from the records you have. Where data was never captured, no system can evidence it retrospectively. Where metering granularity is missing, that is a plant gap to close, and naming it early is the point of the assessment.
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Questions carbon and compliance teams ask us

CBAM requires installation-level embedded emissions that an accredited verifier can trace to source. This use case assembles production, energy and precursor records into that structure and flags evidence gaps early.

If you export covered goods into the EU, your customers need installation-level embedded emissions data from you. That makes it your data problem regardless of where the installation sits.

Production records by goods category, energy and fuel data with emission factors, precursor documentation from suppliers, the monitoring plan and any prior reporting. No new hardware unless the methodology needs metering granularity your installation lacks.

No. It retrieves and cites regulation and official guidance, extracts structured data from plant and supplier records, checks completeness and consistency, and drafts monitoring and calculation documentation.

No to both. Submission stays with you, and verification is an accredited third party's judgement. It is not legal or regulatory advice.

Through ExpertFlow AI for the regulation and documentation layer, with tailored data assembly over plant systems where needed. Expert Services can support discovery, gap assessment and validation with your compliance team.

It works from the records you have. Missing historical data cannot be invented retrospectively. Precursor gaps from upstream suppliers often dominate, and closing them is a commercial and documentation task as much as a systems task.

CBAM and carbon data

This year's production is already the evidence.

Start with a gap assessment on one goods category. The useful answer is what your records cannot currently support, while there is still time to change that.