碳边界调整机制（CBAM）

CBAM核查流程遵循一种结构化、基于风险的方法。下文摘要反映了《欧盟委员会授权条例（EU）2025/2551》附件二第2.2至2.20节中的核查活动，以及《欧盟委员会实施条例（EU）2025/2546》中的核查原则。

1. 合同签订前的审查与时间安排

   Before accepting an engagement, SCS Global Services Europe B.V. reviews the available information to understand the operator’s installation, determine the proposed verification scope, confirm that the engagement falls within the accredited scope, assess competence and resource availability, evaluate verification risks, and allocate sufficient time for the work. The contract must allow for additional time if needed for strategic analysis, risk analysis, or other verification activities.

2. 运营商的信息请求

   在进行战略分析之前及整个核查过程中，运营方必须提供规划和实施核查所需的信息。这些信息可能包括最新的监测计划、装置说明、工艺流程信息、变更记录、采样计划、运营方排放报告、以往的核查报告、未解决发现事项的相关信息、前体物质核查报告、生产期间证据、用电证据、数据库、数据来源以及其他相关记录。

3. 战略分析

   SCS Global Services Europe B.V. performs a strategic analysis to assess the likely nature, scale, and complexity of the verification. This includes reviewing the installation, goods produced, production processes and routes, source streams, emission sources, technical connections, monitoring methodology, measurement equipment, calculation factors, precursor inputs, electricity data, data flow activities, and the operator’s control system.

4. 风险分析

   SCS Global Services Europe B.V. identifies and analyses inherent risks, control activities, and control risks that may affect the reliability of the emissions report. The risk analysis considers the strategic analysis, operator information, relevant source streams and data flows, and applicable materiality levels. If new information becomes available during verification, the risk analysis and planned verification activities are updated.

5. 验证计划

   Based on the strategic and risk analyses, SCS Global Services Europe B.V. prepares a verification plan proportionate to the risks identified. The plan includes a verification programme, a test plan for control activities and procedures, and a data sampling plan. The plan is designed to reduce verification risk to an acceptable level and support a reasonable assurance opinion.

6. 核查活动

   SCS Global Services Europe B.V. implements the verification plan and checks whether the monitoring plan has been properly applied. Verification activities include substantive testing, analytical procedures, data verification, and checks on the correct application of the monitoring methodology. SCS Global Services Europe B.V. reviews data flow activities, IT systems, control activities, procedures, documentation, and implementation effectiveness.

7. 分析程序

   SCS Global Services Europe B.V. uses analytical procedures to assess plausibility and completeness of reported data. This includes assessing fluctuations and trends, identifying outliers, unexpected data and data gaps, performing preliminary and substantive analytical procedures, and carrying out final analytical procedures to confirm that identified errors have been resolved.

8. 数据验证

   SCS Global Services Europe B.V. performs detailed testing of the data in the operator’s emissions report. This includes tracing data back to primary source records, cross-checking with external or corroborating sources where available, performing reconciliations, checking thresholds, recalculating reported values, and verifying the boundaries of the installation, production processes, production routes, source streams, emission sources, technical connections, activity levels, and data reliability.

9. 监测方法的验证

   SCS Global Services Europe B.V. checks whether the monitoring methodology in the monitoring plan has been correctly applied. This includes evaluating completeness of data, data gaps, double counting, sampling plans, attribution of emissions and energy flows, activity-level definitions, energy consumption, precursor treatment, use of verified actual emissions for precursors where applicable, default-factor use, electricity emission factors, biomass sustainability evidence, and treatment of transferred CO2 or N2O, carbon capture and storage, and permanent carbon capture and use.

10. 对其他核查报告的依赖

    Where the operator relies on verified data from other installations, such as precursor-producing installations or electricity-producing installations, SCS Global Services Europe B.V. checks whether the related verification report was issued by an appropriately accredited verifier, whether the opinion was satisfactory, and whether the report covers the relevant production period.

11. 抽样

    SCS Global Services Europe B.V. may use sampling methods where justified by the risk analysis. If a misstatement or non-conformity is identified through sampling, SCS Global Services Europe B.V. requests the operator to explain the cause, assesses the impact on reported data, determines whether additional verification work is needed, and decides whether the sample size or corrected data population must be expanded.

12. 实地考察

    SCS Global Services Europe B.V. conducts a physical site visit at the installation where the goods are produced, unless a virtual site visit or waiver is permitted under the applicable CBAM verification rules. The site visit is used to assess measuring devices and monitoring systems, interview personnel, assess installation and production-process boundaries, confirm the completeness of source streams and emission sources, review technical connections, and gather sufficient evidence for the verification conclusion.

13. 处理错报、不符合项和违规情况

    Where SCS Global Services Europe B.V. identifies misstatements, non-conformities, or non-compliance during verification, SCS Global Services Europe B.V. informs the operator without delay and requests correction. Corrected issues are documented as resolved. For uncorrected issues, SCS Global Services Europe B.V. requests explanations, assesses materiality, evaluates impacts on reported embedded emissions and free allocation adjustment information where relevant, and determines the effect on the verification opinion.

14. 独立技术审查

    在发布核查报告之前，由一名未参与核查团队的独立审阅人审查内部核查文件和核查报告草案。该审查涵盖整个核查过程，确认相关程序是否得到正确遵循，评估是否已运用应有的专业谨慎和判断，并评估证据是否足以支持形成合理保证意见。

15. 核查报告的认证

    核查报告根据独立审查员的结论以及内部核查文件中的证据进行认证。认证工作由核查机构正式授权的人员负责。

16. 内部核查文件

    SCS Global Services Europe B.V. compiles internal verification documentation sufficient to demonstrate that the verification was performed in accordance with the applicable CBAM requirements. The documentation includes the results of verification activities, information received from the operator, strategic analysis, risk analysis, verification plan, justification for any site-visit waiver or virtual site visit, evidence supporting the verification opinion, and the results of the independent review.

17. 核查报告和意见书

    SCS Global Services Europe B.V. issues the verification report only for activity groups within its accredited scope. The verification report includes a verification opinion. The report may be verified as satisfactory only where the operator’s emissions report is free from material misstatements. The report is verified as unsatisfactory where material misstatements, material non-conformities, insufficient clarity, or limitations of scope prevent a satisfactory reasonable assurance conclusion.

18. 范围限制

    SCS Global Services Europe B.V. may conclude that the scope of verification is too limited where data are missing, the monitoring plan does not provide sufficient scope or clarity, or the operator has not made sufficient information available. A limitation of scope may prevent SCS Global Services Europe B.V. from obtaining sufficient evidence to issue a reasonable assurance opinion.

19. 未解决的非重大不符合项

    SCS Global Services Europe B.V. assesses whether non-material non-conformities identified in the previous reporting period have been corrected. If they have not been corrected, SCS Global Services Europe B.V. assesses whether the failure increases, or may increase, the risk of misstatements and documents the status and resolution of findings.

20. 改进建议——无需咨询服务

    Where SCS Global Services Europe B.V. identifies areas for improvement, the verification report may include recommendations related to the operator’s risk assessment, data flow activities, control activities, procedures, and monitoring and reporting process. These recommendations are limited to verification findings and do not constitute consultancy. SCS Global Services Europe B.V. remains impartial and does not advise on, design, or develop the operator’s monitoring and reporting process.

21. 核证声明签发后发现的事实

    If SCS Global Services Europe B.V. becomes aware of facts after issuance of the verification statement that could have materially affected the verification opinion, SCS Global Services Europe B.V. assesses the significance of the information, determines whether additional verification activities are required, and takes appropriate action. Depending on the circumstances, this may include communication with the client, amendment, withdrawal or reissuance of the verification statement, and notification of relevant authorities or intended users where required.