An increasing number of companies from Republika Srpska and Bosnia and Herzegovina exporting cement, iron and steel, aluminium, fertilisers, and other CBAM goods are already preparing greenhouse gas emissions reports. However, preparing emissions data is only the first step in the process of complying with the European Union’s Carbon Border Adjustment Mechanism (CBAM) requirements.

As of 2026, with CBAM entering its definitive phase, the emissions data used to calculate CBAM obligations must be prepared in a manner that allows for independent verification by accredited CBAM verifiers. Therefore, it is essential that companies establish a reliable system for emissions monitoring, record-keeping of energy sources and raw materials, emissions calculations, and the maintenance of supporting documentation that can demonstrate the accuracy of the reported data.

To support companies throughout this process, the Chamber of Commerce of Republika Srpska, through the project “Digital Sustainable Green Transition of SMEs in Republika Srpska – DiGreenSMEs,” provides expert assistance in understanding and implementing these complex requirements.

Registration of Non-EU Operators – O3CI Module

The European Commission has established a dedicated module for operators in third countries (O3CI – Third Country Installation Operators), enabling manufacturers outside the European Union to register their production installations and share emissions data with customers in the EU. Registration is not mandatory; however, it represents an important step towards the use of actual emissions data and the future verification of such data.

Although registration is currently not mandatory for manufacturers from Bosnia and Herzegovina, it can significantly facilitate the exchange of emissions data with customers in the European Union, enhance the credibility of the reported information, and simplify the future emissions verification process.

It is important to emphasise that companies from Bosnia and Herzegovina are not CBAM declarants and are not required to register as authorised CBAM declarants or submit CBAM declarations to the European Commission. These obligations apply to importers established in the European Union. Nevertheless, the emissions data provided by manufacturers form the basis for the CBAM declarations submitted by their EU customers.

What Should Companies in Republika Srpska and Bosnia and Herzegovina Do Now?

To maintain their competitiveness in the European Union market and meet the expectations of their customers, companies should:

• establish a greenhouse gas emissions monitoring and record-keeping system;
• ensure data traceability and maintain supporting documentation;
• apply emissions calculation methodologies that comply with CBAM requirements;
• familiarise themselves with the registration options available through the CBAM Portal;
• prepare data and documentation for the future independent verification process.

Data Verification – The Next Phase of the CBAM System

Although companies from Bosnia and Herzegovina do not submit CBAM declarations to the European Commission, the emissions data they provide to their European customers will need to be prepared in a manner that enables successful independent verification.

According to the information currently available, the European Commission plans to publish the first list of accredited CBAM verifiers in September 2026, while the first verified CBAM reports are expected in early 2027.

This means that the quality, accuracy, traceability, documentation, and verifiability of emissions data will become just as important as the emissions calculations themselves.

Companies that establish robust systems for emissions monitoring, data management, and verification preparedness in a timely manner will be in a significantly stronger position than producers without such systems. They will enable their EU customers to fulfil CBAM obligations more efficiently while reducing the risk of additional costs or trade barriers in doing business with the European Union.

Useful Links

• European Commission – Information on the Registration of Non-EU Operators (O3CI):
  CBAM Registry and Reporting – Taxation and Customs Union
• Guide for Non-EU Operators – Registration and Access to the CBAM Portal
  (link to PDF document)
• Guide for Companies on the Carbon Border Adjustment Mechanism (CBAM):
  CBAM InfoBiz – Chamber of Commerce of Republika Srpska

The project “Digital Sustainable Green Transition of SMEs in Republika Srpska – DiGreenSMEs” is implemented by the Chamber of Commerce of Republika Srpska with financial support from the European Union (EU) and the Government of the Federal Republic of Germany through the Private Sector Development Initiative in Bosnia and Herzegovina, which forms part of GIZ’s broader programme “Sustainable Economic Development and Employment Promotion (SEDEP) in Bosnia and Herzegovina.”

This translation uses the official CBAM terminology adopted by the European Commission (e.g. CBAM declarants, greenhouse gas emissions, third-country operators, production installations, independent verification, traceability, supporting documentation) and is suitable for publication on a chamber of commerce or institutional website.