This section provides an overview of the emerging use of carbon-intensity metrics in trade-related contexts at the global level. It situates recent developments within a broader ecosystem of public and private actors involved in the design, implementation and operationalisation of these metrics, with particular attention to their implications at the border. The analysis adopts a trade facilitation lens, focusing on how carbon-intensity metrics interact with trade-related procedures, information flows and institutional co-ordination, and on the practical considerations arising for their effective and coherent application in cross-border trade.
Trade facilitation implications of carbon‑intensity requirements
Carbon-intensity metrics are increasingly informing environment-related policy discussions worldwide. These metrics are defined as the ratio of GHG emissions (in tonnes of CO₂-equivalent) to total output produced (measured in physical or economic terms). They can be calculated at multiple levels of aggregation, including products, sectors, firms, asset classes, portfolios, and countries. These differing aggregation levels complicate the design and implementation of data collection systems. At the product level, carbon-intensity metrics capture emissions embedded in the production of goods, including both direct emissions and indirect emissions generated in upstream (and sometimes downstream) stages of value chains (OECD, 2024[2]).
From an international trade perspective, carbon-intensity metrics can therefore help with improving supply chain environment-related traceability, and supporting regulatory compliance with instruments such as carbon pricing, border carbon adjustments and carbon markets (OECD, 2024[2]). These metrics require accurate, timely and granular data, and discussion on the methodologies and complexity of measurement are ongoing (see Box 1).
Measuring embedded emissions is inherently complex, as it requires data on direct emissions from production processes (Scope 1), indirect emissions from purchased electricity (Scope 2), and upstream and downstream value-chain emissions (Scope 3). The collection and exchange of emissions data remain challenging due to limited data availability, confidentiality concerns, legal constraints, and contractual gaps along supply chains.
As a result, the practical implementation of regulations based on carbon-intensity metrics often relies, at least in part, on the use of default values or on systems for secure and standardised data collection supported by Monitoring, Reporting, Verification and Accreditation (MRV/MRVA) frameworks. Sector-specific research points in a similar direction. Focusing on food systems, (Deconinck, Jansen and Barisone, 2023[13]) highlight a “fast and furious” rise of environmental impact reporting.
In the absence of an internationally harmonised framework, firms are confronted with a fragmented regulatory landscape. This fragmentation can increase compliance costs and administrative burdens, with potentially disproportionate impacts on SMEs and on firms operating in developing economies. These challenges are the subject of ongoing international discussions in fora such as the OECD Inclusive Forum on Carbon Mitigation Approaches – notably through its Carbon Intensity Workstream (IFCMA(2024)6) – as well as within the World Trade Organization (WTO), including in the Committee on Trade and Environment and the Trade and Environmental Sustainability Structured Discussions (TESSD) (https://www.wto.org/english/tratop_e/tessd_e/tessd_e.htm).
Together, these discussions highlight the need to improve transparency, interoperability and coherence across carbon-intensity measurement approaches, while managing their implications for trade facilitation and border processes when carbon-intensity requirements are enforced also at the border.
Carbon-intensity metrics are found not only in voluntary initiatives but also increasingly in mandatory requirements (WEF, 2023[17]). While their early use focused largely on voluntary disclosure, product carbon footprint and corporate reporting, recent policy developments have introduced or are exploring the incorporation of these metrics into binding requirements that create enforceable obligations for firms or condition market access. This expansion into mandatory requirements has transformed carbon-intensity metrics into tools with direct implications for regulatory compliance, administrative processes and international trade.
Carbon-intensity requirements differ from several other NPR-PPM measures in their reliance on quantified and standardised metrics. Whereas other NPR-PPM requirements often involve binary compliance assessments (e.g. whether a prohibited practice occurred or not), carbon-intensity-related measures generally require the calculation and reporting of embedded emissions at product level, based on defined methodologies, default values, and verification rules (OECD, forthcoming[18]; OECD, forthcoming[19]). This can increase the volume, frequency, and granularity of data exchanged at the border and places greater emphasis on technical interoperability between customs systems, registries for carbon-intensity and trade data, and other administrative platforms.
Border carbon adjustments (BCAs) provide one relevant example of trade-related environmental policy instruments requiring enforcement of carbon-intensity requirements at the border. In most cases, under such regulations, charges would be levied on the emissions embedded in imported products at a level equivalent to the carbon price that would have applied had those goods been produced under the importing jurisdiction’s carbon pricing policies. BCAs can take different forms, including border taxes linked to domestic carbon taxes or certificate-based systems aligned with emissions trading schemes (ETS) (WEF, 2025[20]). A growing number of jurisdictions are exploring or developing BCA-type instruments, often alongside broader carbon-pricing initiatives. The European Union’s Carbon Border Adjustment Mechanism (CBAM), the first operational BCA globally, requires since 2026 to present certificates priced in line with the EU Emissions Trading System. Serbia has adopted a Law on Tax on the Import of Carbon-Intensive Products, also in force since 2026, alongside a domestic emissions tax, as part of a broader effort to align notably with the EU CBAM. The United Kingdom plans to implement a CBAM from 2027, while economies such as Canada and Australia are examining border-related or carbon-leakage measures. Other economies such as Türkiye and Japan have included import-related carbon provisions into environmental legislation or announced plans for carbon levies (see mapping in Section 3).
Beyond BCAs, mandatory product labelling and sustainable production schemes may constitute market access requirements. In this context, carbon-intensity metrics serve as measurement tools for implementing and enforcing those requirements. Economic operators must provide carbon-intensity metrics, alongside other environmental attributes, as part of the information required to place products on the market. In contrast to BCAs, these labelling or sustainable production schemes do not attach a price or charge to embedded emissions. Instead, carbon-intensity metrics function as informational or compliance parameters, for example to support traceability, comparability, or eligibility under regulatory standards. Carbon-intensity requirements for market access are implemented and enforced through different processes involving a range of different actors. The next section examines who those actors are and the roles they play.
Building on a broader assessment of the practical implementation of NPR-PPMs regulations in trade, as reflected in existing practices and ongoing policy discussions, this section identifies common implementation and enforcement features of product-level carbon-intensity requirements at the border (Pauwelyn, 2024[5]). By focusing on functional implications for border processes, the analysis brings to the fore a set of distinct challenges. First, compliance cannot be verified through physical inspection at the border, as is also the case for other non-observable product attributes and enforcement relies on access to the information on embedded emissions. Second, such quantification of emissions is both technically complex and novel and goes beyond binary yes-or-no compliance checks. As a result, effective enforcement depends on systems of trust built around data verification, certification and declaration processes, as well as secure data movement mechanisms involving multiple public and private actors along supply chains operating within a broader compliance ecosystem.
In practice, this means that the implementation of regulations based on carbon-intensity metrics relies on an ecosystem of key actors operating both behind and at the border, and combining regulatory, operational, and technical functions. Although legal obligations are typically defined at the central or national level, their application at the border depends on coordinated action across a range of public and private actors who together support the generation, transmission, verification, and enforcement of compliance-related information throughout the trade transaction. These actors can be grouped according to the functions they perform within the compliance ecosystem (Figure 1):
Producers of goods, such as operators of installations involved in the production process in various countries, responsible to provide (verified) emissions data.
Other economic operators, such as importers, exporters, direct and indirect customs representatives (e.g. customs brokers), responsible for identifying applicable obligations and submitting required carbon-intensity or product-related data.
Customs authorities, acting as the primary interface at the border, responsible for determining applicability of regulations at importation, verifying authorisations, carrying out clearance-related checks, and exchanging related trade transactions data.
Other border agencies and competent authorities, such as environmental, tax, energy, or market surveillance authorities, responsible for authorisations, registries, compliance assessments, and enforcement actions.
Accreditation bodies and third-party verifiers, supporting the credibility of reported data through accreditation and verification processes.
Central or supranational authorities, where applicable, responsible for coordination, oversight, and the management of shared registries or information systems.
Notes: The categories presented are illustrative rather than exhaustive. They are based on the review of measures in this report and reflect the actors most commonly referenced in the measures examined. The specific actors involved may vary across measures, sectors and jurisdictions.
Customs administrations and other border agencies already operate at the intersection of multiple regulatory regimes, enforcing a wide range of product-related and process-related requirements at the border. Clearance processes routinely involve the exchange of numerous documents and data elements among economic operators, customs authorities and other competent agencies, reflecting obligations related to safety, security, taxation, environment and market surveillance. The introduction of product-level carbon-intensity requirements therefore adds to an already complex operational environment at the border. It also raises important questions regarding the volume and nature of additional data and documentation to be exchanged, the allocation of responsibilities among customs and other border agencies, and the extent to which existing facilitation tools such as risk management, pre-arrival processing and border agency co-operation can accommodate these new obligations without undermining efficiency or predictability.
Trade facilitation tools and systems play a central role in enabling trade-related procedures to be conducted efficiently, transparently and securely. They encompass measures aimed at simplifying and streamlining the legal, administrative, and technical procedures applied to goods at the border. Trade facilitation frameworks thus provide a useful lens for examining how new product-level requirements, including carbon-intensity metrics, can be implemented in a manner that ensures compliance while minimising unnecessary frictions for traders and authorities alike (OECD, 2025[11]).
The OECD’s Trade Facilitation Indicators (TFIs)1 provide a structured way of documenting how economies perform across a set of core procedural and institutional areas, based on information collected since 2012 and aligned with the key provisions of the WTO Trade Facilitation Agreement (TFA)2. Several facilitation areas are particularly relevant for understanding how border systems may accommodate additional product-level requirements – such as carbon-intensity metrics. Specifically, TFIs covering information availability to traders, automation, streamlined procedures, and internal and external border agency co-operation offer insights into the capacity of customs and other authorities to integrate new data-intensive and process-based obligations without generating unnecessary frictions at the border:
Transparency on processes and procedures (as measured by TFI A on information availability) is a precondition for predictable and proportionate enforcement. In the context of carbon-intensity requirements, this includes the clear publication of information on the scope of covered products, applicable thresholds or exemptions, required documentation, authorisation or registration procedures, and the role of customs and other authorities at importation.
The ability to manage additional data and documentation electronically (as measured by TFI G on automation) is critical to avoiding delays and congestion at the border. Automation enables the electronic submission, processing and validation of customs declarations and supporting information, as well as the integration of new regulatory data, such as authorisation identifiers, benchmark references or default values, into existing IT systems.
Where new requirements introduce additional steps into the importation process, streamlined and risk-based procedures help ensure that controls remain proportionate. Pre-arrival processing and clearly sequenced formalities (as measured together with other areas in TFI H on procedures) can help limit duplication between customs processes and parallel regulatory requirements across authorities.
Internal border agency co-operation (as measured by TFI I on domestic border agency co-operation) is particularly important where carbon-intensity requirements involve multiple authorities with distinct mandates. While customs administrations act as the operational entry point at the border, policy oversight and verification functions may rest with environmental or tax authorities. Effective internal co‑operation, supported by shared systems, coordinated controls, or formal information-sharing arrangements, can help ensure that responsibilities are clearly allocated, that data are used consistently, and that traders are not subject to overlapping or contradictory requirements.
External border agency co-operation (as measured by indicator TFI J on cross-border agency co-operation) becomes increasingly relevant where carbon-intensity requirements rely on information generated outside the importing jurisdiction. In the context of carbon-intensity requirements, this may include recognition of emissions-related data verified by accredited bodies abroad, certification or documentation issued in exporting economies, or co-operation mechanisms related to risk analysis and fraud detection. Effective external co-operation can support the credibility of compliance information while reducing uncertainty and administrative burden at the border.
Recent evidence compiled through the TFIs indicates that economies across all regions have made progress in strengthening these facilitation areas, particularly with respect to border agency co-operation and the streamlining of trade-related procedures over the period 2022‑24 (OECD, 2025[21]). These reforms contribute to a trade facilitation environment that is better equipped to handle more complex and data-intensive regulatory requirements. At the same time, they underscore the importance of designing and implementing carbon-intensity requirements in a manner that builds on, rather than disrupts, ongoing trade facilitation reforms. While the TFIs provide an aggregate view of implementation conditions, more granular analysis is needed to assess how these facilitation capacities translate into practice for specific regulatory obligations – such as those stemming from carbon-intensity requirements – at the border.
← 1. Each TFI indicator is scored on a scale from 0 (lowest performance) to 2 (highest performance), reflecting both the regulatory framework and its practical application. The TFIs provide a systematic tool to benchmark performance, identify implementation gaps, and inform policy reforms across 163 economies. The TFIs cover four policy areas: 1) Transparency and predictability (information availability, involvement of the trade community, advance rulings, appeal procedures, fees and charges), 2) Automating and streamlining procedures (formalities related to documents, automation, and procedures), 3) Border agency co-operation (internal and external border agency co‑operation), 4) Governance and impartiality.
← 2. The TFA entered into force in 2017.