The EU Carbon Border Adjustment Mechanism (CBAM) has entered its full implementation phase. For Chinese enterprises exporting products in six major categories—including iron and steel, aluminum—to the EU, compliance no longer depends merely on understanding the rules, but on the ability to provide a complete, verifiable, and traceable set of carbon emission data. Data has become the cornerstone of CBAM reporting, and a systematic data management tool—the carbon emission MRV compliance platform—is increasingly a necessity for enterprises responding to green trade barriers. This article offers practical guidance, breaking down the data list enterprises need to collect, proper collection methods, and demonstrating the full data collection workflow using a stainless steel screw exporter as an example, teaching step-by-step how to achieve efficient compliance with an MRV platform.

CBAM requires that embodied carbon emissions of declared products be based on authentic, accurate, and verifiable data. Enterprises must first establish a complete data ledger covering four core modules: basic enterprise information, energy use data, production information, and industry-specific supplementary information. Basic enterprise information includes both Chinese and English company name, address, postal code, export port name, factory longitude and latitude, and report contact information. Key details such as company name and address must be consistent with export declarations; longitude and latitude can be obtained through online tools, and contact information is used for subsequent verification communications.

As the core emission source, energy use data must fully cover indirect emissions, direct emissions (fuel combustion and process emissions), and purchased heat. Indirect emissions should be separately recorded as purchased electricity excluding green power and renewable electricity such as solar and wind power. Fuel combustion emissions cover consumption of natural gas, diesel, gasoline, molding oil, hydraulic oil, and other fuels. Process emissions should report topup quantities of refrigerants, fluxes, electrodes, carboncontaining raw materials, and welding shielding gas (CO₂). Purchased heat requires calorific values or physical parameters such as temperature, pressure, and consumption for steam and hot water. Importantly, only fixed sources in production workshops are counted; energy consumption of mobile sources such as forklifts and transport vehicles is excluded. Unused items must be filled in as “0”, and all data must retain original supporting documents such as electricity bills, gas invoices, and purchase receipts for verification.

Production information is divided into raw material information and export product information. Raw material information requires Chinese and English names, total procurement volume in the reporting period, consumption per export product, direct carbon emission intensity (supplier-measured values preferred; default values used if unavailable), and electricity consumption per ton of raw material. Export product information must specify product names in Chinese and English, HS Code, CN Code, brief process description, total output, and total export volume to the EU. Enterprises using precursor products should supplement precursor names, procurement volume, and whether measured carbon emission intensity is applied. Iron and steel and aluminum enterprises must prepare additional industry-specific information: steel enterprises need plant identification codes and alloy contents including manganese, chromium, and nickel; aluminum enterprises need to report scrap ratio, scrap consumption per ton of aluminum, and non-aluminum element content.

Take Xiao Z (Jiangsu) Fastener Co., Ltd. as an example. The company exports two products: self-tapping screws and machine screws, mainly using stainless steel wire rod (304) as raw material, with production processes including cold heading, thread rolling, and cleaning. Its data collection workflow for Q1 2026 clearly demonstrates the logic of organizing CBAM-compliant data. The first step is to collect factory-wide energy consumption data, tallying total purchased electricity, natural gas, molding oil, and hydraulic oil for the quarter, with source documents obtained from electricity bills, gas invoices, and purchase receipts. The second step is to allocate energy consumption to each product: based on total Q1 output (400 tons of self-tapping screws, 300 tons of machine screws), allocation is by output proportion—57% for self-tapping screws and 43% for machine screws—to calculate respective electricity, natural gas, and molding oil consumption per product.

The third step is to count raw material consumption, recording total procurement of stainless steel wire rod and consumption by the two products; since the supplier did not provide carbon intensity data, default values are used. The fourth step is to organize export product information, clarifying total output, EU export volume, and brief process flow for both products. Finally, the enterprise must compile a verification-ready package including electricity bills, gas invoices, raw material purchase contracts and material certificates, daily production reports, export declarations, and energy allocation sheets (with allocation logic noted) to ensure full traceability and verifiability.

Through this systematic data collection and management process, enterprises can not only meet CBAM’s carbon data requirements but also use MRV platforms to achieve standardized and automated data management, lower compliance costs, reduce carbon tariff risks caused by data issues, and lay a solid foundation for long-term low-carbon transformation and competition in green trade.