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Who monitors emissions from a steel mill in Wuhan on behalf of Europe when we import materials? And what about a Turkish cement plant? In what language, under what rules, and with what legitimacy? The CBAM, the European Carbon Border Adjustment Mechanism, is coming into operation, but the accreditation system for emission verifiers of foreign producers is still under development. We need to move faster if we really want to get the most out of CBAM. We had a chat with Carla Sanz, verification and validation lead at Accredia, the Italian accreditation body.
New CBAM verifiers are currently being accredited: what are the specific requirements, and how do they compare to the ETS?
The expertise of verifiers is always a crucial factor, as it guarantees the reliability of the work carried out. From a technical perspective, the ETS focuses on the direct emissions of a facility; the CBAM, on the other hand, refers to the emissions embedded in a product, in some cases including indirect emissions as well. However, the regulation provides a fast track for ETS verifiers: anyone already operating within the European emissions trading system possesses equivalent expertise in specific sectoral areas. This translates, in the table of Delegated Regulation (EU) 2025/2551, into an easier accreditation process. The main challenge is the introduction of an international dimension. Verifications are carried out in non-EU countries, with varying contexts and operational practices, starting with the language: no longer Italian, but English or the local language, possibly with the aid of a translator. China, for example, has very stringent national regulations on the operation of foreign accreditation bodies. CBAM verifiers are required to demonstrate a level of flexibility and adaptability that was less critical under the ETS, as audits were conducted within Europe.
How are you going about resolving this issue?
Accredia is well aware of this challenge: we have initiated training programmes to strengthen expertise and are exploring the possibility of collaborating with accreditation bodies in non-EU countries, establishing joint assessment teams to ensure that all the required expertise is covered.
With the deadline set for the end of 2026, will there be enough auditors ready?
We just opened up the possibility for Italian ETS verifiers to submit accreditation applications and are now receiving the first submissions. The main problem is that we are missing a key piece of information that not even the European Commission, despite repeated requests, has provided: we have no idea how many operators will actually request a verification, as they have the option of either using default data or requesting a verification. This uncertainty makes it difficult to predict the demand for accredited verifiers. As far as accreditation bodies are concerned, the picture is clearer: 21 bodies across the EU will issue CBAM accreditations, and of these, seven have declared their intention to accredit bodies in non-EU countries. The deadline is tight, however: we have already made it clear in our documents that Accredia may not be able to process all applications and may have to draw up a shortlist. The third phase – verifiers based in non-member countries – is the one causing the most concern. The pressure is coming from all sides: organisations are asking us to accredit them in time, and their clients urgently require the service for exports to Europe. We are signing a cooperation agreement with China, as we have already done with South Korea, but this bottleneck involves seven European accreditation bodies, including Accredia.
How do you ensure the quality of accredited verifiers in non-EU countries, and how do you prevent forum shopping, i.e., selecting the least rigorous verifier?
The accreditation process is identical for both European and non-European organisations. It begins with a document review, which examines the organisation’s operational processes, including the qualification process and the monitoring of verifiers. If this documentation is deemed satisfactory, the process moves on to an on-site audit at the organisation’s offices in the host country, where direct checks are carried out to ascertain the verifier’s operational capability. The final stage involves direct observation in the field: the accreditation body works alongside the verifier during the emissions verification at the plant in a purely observational role: no interaction with the plant operator, only an assessment of correctness and professional conduct. Accreditation is valid for a maximum of five years, but the process does not end with its achievement: annual surveillance is carried out, involving on-site audits or on-site monitoring. As for forum shopping: the risk is limited, as Regulation 2.551 defines a single accreditation process, which is valid for all bodies. European accreditation bodies operate within the EA (European Cooperation for Accreditation), which sets common rules. A specific EA working group has been set up for CBAM, coordinated by Accredia, to ensure consistency in approach across bodies. There is also peer evaluation: each accreditation body is evaluated on a regular basis by the others, with the participation of European Commission delegates via the MAC committee, to verify that the peer assessment process is carried out correctly.
Another issue is the shortage of qualified professionals.
This is a problem affecting the entire sector. Those working in the ETS operate in concentrated, highly intense periods, with a heavy technical workload and growing discomfort with this type of activity. Every year, the European Commission tightens the requirements without taking into account the time needed to acquire the necessary skills. We have not yet gained the necessary skills for the CBAM, and by January 2027 we will all have to be up and running. Those who already have a full agenda for the ETS are struggling with the prospect of audits in China.
How does the Carbon Removal Certification Framework (CRCF) change the approach to verification?
A terminological clarification is required: in the CRCF, the term used is not “verification” but “validation”. Verification concerns the past and is based on actual and historical data: it ensures the reliability of the data. Validation, on the other hand, concerns future estimates and provides a warranty of plausibility: not regarding the value itself, but regarding the assumptions, criteria and methods used to construct the estimate. It is a more complex activity, as the assumptions behind a projection must be assessed. To reduce the risk of greenwashing, the European Commission has introduced a recognition requirement into the CRCF: those who wish to operate in the carbon credit market must undergo an assessment process by the Commission, after which the relevant bodies must be accredited. Accredia has not yet issued any accreditations in this area, as there are still aspects to be clarified at the European level; the Commission is expected to publish new legislative acts shortly.
Cover: Carla Sanz