Generating a valid CBAM XML report requires clean, complete, correctly structured emissions data. CBAM HUB helps you build and validate that data foundation — reducing errors before you reach the EU CBAM Registry submission step.
The EU CBAM Registry requires quarterly reports to be submitted in a specific XML format defined by the European Commission. Generating a valid, complete XML file requires structured, consistent data from across your supplier base and import portfolio.
The CBAM XML schema maps directly to the data requirements of the CBAM Implementing Regulation — each goods entry must include the correct CN code, country of origin, installation identifiers, production route, embedded emissions figures (direct and indirect where applicable), and the carbon price paid in the country of origin.
A single missing or incorrectly formatted data field can cause a submission error. With imports from multiple suppliers across multiple product categories, manually assembling and validating this data is error-prone — especially under quarterly deadline pressure.
| Data Field | Description | Status |
|---|---|---|
| CN code | Combined Nomenclature code for each imported good within CBAM scope | Required |
| Country of origin | ISO country code of the non-EU country where the goods were produced | Required |
| Installation identifier | Unique identifier for each production installation supplying the goods | Required |
| Production route | The specific production method used (e.g. BF-BOF, EAF for steel) | Required |
| Direct embedded emissions | tCO₂e per tonne of goods from direct combustion and process emissions | Required |
| Indirect embedded emissions | tCO₂e per tonne of goods from electricity consumption at production | Conditional |
| Carbon price paid | Carbon cost paid in the country of production (EUR per tonne CO₂e) | Required |
| Quantity imported | Net mass or applicable quantity unit for each import declaration | Required |
| Source of emissions data | Whether actual data, accredited verifier data, or default values were used | Required |
CBAM HUB focuses on the hard part of XML generation: getting the underlying data structured, complete, and correctly mapped before it reaches the submission stage.
CBAM HUB provides structured data collection templates that capture the exact fields required for XML generation — CN codes, installation identifiers, production routes, and emissions figures — so there are no gaps or misaligned formats when you assemble the report.
Track data completeness at the supplier and goods-entry level. CBAM HUB flags missing or incomplete fields — installation data, emissions figures, carbon price information — before they reach the XML generation step and cause a submission error.
Each data point in CBAM HUB is mapped to the corresponding field in the CBAM reporting structure — ensuring that CN codes, emission calculation approaches, and installation-level data are consistently applied across all goods entries in your quarterly report.
Supporting documentation — supplier declarations, production data, methodology notes — is attached directly to each data record. This means every figure in your XML report can be traced back to its source document in an audit context.
Once all required fields are complete and validated, CBAM HUB provides structured data export in a format aligned with CBAM XML requirements — reducing the manual work of translating raw data into the submission format required by the EU CBAM Registry.
Most CBAM XML generation problems originate upstream in the data collection process, not in the XML file itself. Here are the most common issues compliance teams encounter.
Non-EU suppliers often don't spontaneously provide installation-level identifiers. Without a structured data collection process, this critical field — required for every goods entry — is frequently missing or incomplete.
CBAM covers specific CN codes within broader product categories. Mapping imports to the correct CN code, and confirming CBAM coverage applies, requires careful verification — mistakes result in incomplete or inaccurate XML entries.
For categories like aluminium, indirect emissions from electricity use must be included. Many companies lack the supplier data needed to calculate indirect emissions correctly — falling back on defaults that may carry regulatory risk.
The carbon price paid in the country of origin must be documented for each installation. Obtaining and validating this information from non-EU suppliers — especially where carbon pricing schemes are partial or complex — is frequently underestimated.
Quarterly deadlines create pressure to submit with incomplete data. Using default values as a fallback when actual data is unavailable is permitted in some cases, but carries regulatory risk if not properly documented and justified.
Applying different calculation approaches across quarterly periods — without documentation of the methodology — creates inconsistencies that can be questioned in a regulatory review or audit.
Speak with our team about how CBAM HUB can help you collect, validate, and structure the emissions data needed for accurate CBAM XML report preparation — before your next quarterly deadline.
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