The mapping of policy proposals and regulations reveals1 a diversity of approaches to carbon-intensity requirements, differences in product and emissions coverage, and varying guidance on border procedures and further trade facilitation aspects. Moreover, it also suggests that the practical implementation of carbon-intensity requirements relies on a sequence of operational steps at the border (see Figure 3), along with several aspects of technical interoperability (integration of both existing and new documents and data elements; and mechanisms underpinning data movement).
Trade facilitation implications of carbon‑intensity requirements
Furthermore, enforcement of carbon-intensity requirements relies on a combination of existing trade documents and data elements and new regulation-specific information. Core information and documentation already collected through customs declarations include shipment details, product description and classification, quantities, origin and the declared customs procedure. These elements enable authorities to identify goods subject to the requirement and determine the applicability of the regulation. In addition, carbon-intensity regimes require new data elements, including authorisation or account identifiers for importers, indicators of regulatory scope, and information needed to apply benchmarks, default values or thresholds (Table 2). The integration of these new elements into customs processes is a key determinant of the feasibility and proportionality of enforcement at the border.
In addition to trade data elements submitted through customs declarations, the enforcement of carbon-intensity regulations at the border may require customs and other authorities to assess a broader set of supporting documents. These include clearance certificates or confirmations issued by tax or environmental authorities, documentation of financial guarantees, confirmation of AEO status, and information on accredited verifiers, such as accreditation certificates. In some cases, authorities may also rely on commercial documentation, including contracts or confirmations (e.g. order, booking), and financial statements to support compliance assessments.
Notes: The table provides an illustrative overview of the types of data elements, documents and data analysis systems that may be relevant for implementing carbon-intensity requirements, based on the mapping of regulatory approaches presented in Table 1. It is not intended to provide an exhaustive inventory of all requirements across all measures considered. The distinction between “existing” and “new” refers to whether the information, document or system is generally already used in trade and customs processes or whether it may need to be newly created, collected or adapted by the relevant authorities and/or stakeholders for the implementation of carbon-intensity requirements.
Finally, effective enforcement depends on data movement mechanisms and digital platforms that allow information to flow efficiently between customs and other authorities. Some of these platforms already exist, such as customs risk management systems, classification systems, surveillance tools and single windows for trade, which support automated checks and risk-based controls. Carbon-intensity requirements, however, may necessitate the update or the development of new digital systems, including platforms for managing carbon-intensity data, registries for accredited or pre-authorised importers and operators, benchmark databases, and systems of rules for assessing carbon price adjustments (Table 2). Technical interoperability between existing and new systems appears necessary to avoid reliance on manual or ad hoc data transmission, which can increase administrative burdens, delay clearance and undermine enforcement effectiveness. More broadly, the availability and maturity of these digital systems are closely linked to institutional and technical capacity at the border, shaping authorities’ ability to implement carbon-intensity requirements in an effective, proportionate and consistent manner.
← 1. The analysis also draws on a series of stakeholder interviews conducted between November 2025 and January 2026 with representatives from the private sector (operating across diverse markets), public authorities and international organisations. Interviews complement the desk-based research and provide practical insights into implementation experiences. Findings are reflected in aggregated and anonymised form.