- Before
- Owns the authorisation, the declaration and the certificate account, and has to answer for every tonne from spreadsheets and email.
- Now
- Opens a line with the agents' work already done, asks why, opens the source, and approves each value with a reason before he signs.
One line of steel, from default to verified actual
Kestrel & Vane Europe B.V. in Rotterdam is the group's authorised CBAM declarant. In 2026 it has imported 19,910 tonnes of CBAM goods in 214 customs entries, from 11 supplier installations in 6 countries. Here is how its declarant works with the agents, screen by screen, in the working solution.
- 01Morning
The agents worked overnight; four things need him
Henrik Olsen · CBAM DeclarantHenrik's home shows 19,910 t in scope, 18,574 certificates projected (≈ €1.46M at €78.40) and €475K of saving waiting on checks or on him. The declaration is due 30 Sep 2027, 351 days away. Overnight the import reconciler read 6 new customs entries, and the declaration assembler greets him in the conversation panel with what is ready.
“Karadeniz Çelik's verification came in on 9 Oct, so the CN 7208 line is ready for you — €224K.”
- 02Default vs actual
Every line priced twice, ranked by money at stake
Henrik Olsen · CBAM DeclarantEach import line shows two bars: the certificate cost at the EU default and with the supplier's actual embedded emissions. All on defaults the year would cost €1,687,403; with approved actuals it is €1,456,202, €231,202 saved so far and €475,418 still in reach. At the top: hot-rolled flat steel from Karadeniz Çelik, €347,155 at the default of 2.39, €123,245 at the actual 1.71.
- 03The line
The mill was asked in Turkish, and the reply was tested
Supplier requester · Plausibility checkerThe line opens as a conversation. On 4 Aug the supplier requester sent the EU template in Turkish, pre-filled from 44 customs entries, 5,350 t of CN 7208 and 7209. Emre Aydın replied on 2 Sep: 1.71 tCO2e/t, direct 0.59 and precursors 1.12, for 1 Jul 2025 to 30 Jun 2026. The plausibility checker found it inside the range for an EAF mill charging 38% pig iron and DRI, and within 4% of the mill's 2025 reports.
Every statement in the thread carries a numbered citation to the record it came from.
- 04He asks
“Why 1.71 and not the default?”
Henrik Olsen · CBAM DeclarantHenrik types the question under the thread. The plausibility checker answers in place: 1.71 is the mill's own verified figure; the EU default for CN 7208 from Türkiye is 2.39 and includes the 2026 mark-up; 1.71 fits the expected range of 0.9 to 2.1 for the route and matches the 2025 reports of 1.76 and 1.73. Each point is cited.
The declaration assembler: “This saving is above the 1,000-certificate rule, so it needs your approval.”
- 05One click
The verifier's own words, highlighted
Verification trackerA citation opens Northgate Verification's statement NV-26-0918 for installation TR-ISK-0042: the site visit on 24 September 2026, the reasonable-assurance opinion and CN 7208 at 1.71 tCO2e/t, with the passage the agents read highlighted. The tracker has checked that the statement names the installation, covers the full 12-month period and that the verifier's accreditation is current.
“The highlighted passage is what the agents read. Opened from the record — the source file is kept with the declaration evidence.”
- 06Approved
He approves with a reason code and signs
Henrik Olsen · CBAM DeclarantHenrik approves the actual value with the reason code “Verified actual — accredited verifier statement”. The line saves 2,856 certificates, €223,910, and the projected certificates for 2026 fall from 18,574 to 15,718 — about €1.46M to €1.23M. The certificate calculator confirms the new projection in the thread, and the line goes on the declaration with his reason and the verifier's statement.
“Your approval needs a reason code. It is signed with your name and goes on the declaration's evidence.”
- 07A number too good
Aluminium at 1.12 is queried, not used
Plausibility checkerAnhui Tiancheng Aluminium reports 1.12 tCO2e/t for bars and profiles, claiming 62% post-consumer scrap. For extrusion from mainly primary billet the expected range is 1.6 to 2.4, and a high scrap share needs purchase records or a mass balance. None were sent, so the checker queried the plant in Chinese; the €172,637 saving waits until both checks pass.
“I will not use it until the plausibility and verification checks both pass.”
- 08A statement short
Six months of verification is not twelve
Verification trackerKaveri Steel Tubes sent 2.71 for seamless tubes, and Meridian Assurance Services issued a reasonable-assurance statement — but it covers 1 January to 30 June 2026 only. The tracker will not pass a partial period, so the line stays on the default and it has asked Meridian for the full-period statement, due 31 Oct.
“The statement covers six months. A full 12-month reporting period is needed before I can pass it.”
- 09Customs
A wrong CN code, caught with three records
Amara Diallo · Trade Compliance ManagerOf 214 entries from Harbourline and Danube Gate, 209 match entry, receipt and line; 5 are exceptions. One Harbourline entry declared 86.4 t as CN 7211, but the goods receipt shows 1,250 mm hot-rolled coil, which belongs in 7208. The import reconciler shows the entry, the receipt and what it should be, and drafts the amendment from Amara's mailbox for her to approve.
“Nothing changes without a person.”
- 10Signed by two
The quarter's draft, signed and countersigned
Henrik Olsen and Amara DialloThe declaration assembler builds the 2026 declaration in seven steps and says which are still open. Henrik signs the Q3 draft with the reason “Quarterly review — draft correct as at today”, confirming his identity; Amara countersigns as Trade Compliance. Submission to the CBAM registry opens only when every step is complete, and the evidence pack is built from the record.
“The declaration is signed by the declarant and countersigned by Trade Compliance.”