CBAM Monitoring Plan: What It Is and How to Submit One
A complete guide to the CBAM Monitoring Plan requirement — what it must contain, how to submit it to the EU competent authority, and what happens if you miss the deadline.
What is a CBAM Monitoring Plan?
A CBAM Monitoring Plan is a formal document submitted to the EU competent authority that describes how an installation will measure, calculate, and report its embedded emissions. It is a prerequisite for using actual (verified) embedded emissions data instead of EU default values.
Who Must Submit a Monitoring Plan?
The monitoring plan is submitted by the installation operator (the African exporter's production facility) to the EU competent authority of the importing EU Member State. The EU importer (Authorised CBAM Declarant) facilitates this process.
What Must a Monitoring Plan Contain?
| Section | Content | |---|---| | Installation description | Name, location, production processes, CBAM-covered goods produced | | Emission sources | All direct (Scope 1) and indirect (Scope 2) emission sources | | Monitoring methodology | Calculation approach (mass balance, emission factors, direct measurement) | | Data management | Data collection systems, quality control procedures, record-keeping | | Verification arrangements | Planned verifier, verification frequency, verification standard |
The Monitoring Plan Timeline
- ▸Submit before first export: The monitoring plan must be approved before the installation can use actual emission data
- ▸Annual review: The plan must be reviewed and updated annually
- ▸Significant changes: Any significant change to production processes requires a plan amendment
What Happens Without a Monitoring Plan?
Without an approved monitoring plan, the EU applies default emission values — which are set conservatively high to incentivise actual monitoring. For most African exporters, default values are 30-60% higher than actual emissions, resulting in significantly higher CBAM costs.
Register at the Digital Product Passport Registry to begin your CBAM Monitoring Plan preparation.
Frequently Asked Questions
Complete all three compliance gates — Gate 1 KYC identity verification, Gate 2 CBAM financial authorisation, and Gate 3 Digital Product Passport registration — in one place at the DPP Registry.
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