Direct answer: A product carbon footprint (PCF) / CBAM information page cannot stop at "we care about low carbon and can provide a footprint report." It should state the products and customers covered, the accounting boundary and functional unit, data sources and factors, verification and claims, what CBAM customers need, how upstream and transport data are collected, data quality and confidentiality, and how versions are updated. Otherwise, when a customer asks for embedded-emissions data, the company assembles a spreadsheet on the spot—with boundaries, units, and factors that do not match.
This guide is for export, EHS, energy, quality, legal, IT, and website teams at manufacturers in Changzhou and nearby industrial areas. It explains how to build and accept a product carbon footprint / CBAM information page. Information is current to 2026-11-01. It is a review of public rules, standards, and project practice, not carbon accounting, verification, legal, or customs advice; specific rules, boundaries, factors, verification, and CBAM obligations depend on the applicable standard, the official EU texts, the contract, and the verifier's opinion.
A carbon footprint is not "one total"; it is a combination of functional unit + boundary + data + factor + method. CBAM has no "certification"—do not present a verification statement as a certificate. What customers need is verifiable embedded-emissions data, not a slogan about being green.
How does the PCF/CBAM page relate to ESG, certification, and export-document pages?
The ESG page covers the company's overall environmental, social, and governance performance; the certification page covers which standards a product meets; the export-document page covers invoices, bills of lading, and certificates of origin; the PCF/CBAM page covers how much this product emits under this boundary, on what basis, who verified it, and how the customer can use it. The four can reference each other but cannot replace each other.
The EU CBAM entered its definitive period on 2026-01-01; importers of steel, aluminium, and other covered goods need embedded-emissions data, and brand customers and tenders increasingly ask for product carbon footprints. Many companies send the "reduction targets" from their ESG report as footprint data, only for the customer to find different functional units, boundaries, and factors. Stating the basis on the website lets customers judge whether and how they can use it.
| Page/document | Answers | Audience | Cannot replace |
|---|---|---|---|
| ESG page | Overall environmental, social, governance performance and targets | Customers, investors, public | Product-level footprint |
| Certification page | Which standards the product/system meets | Procurement, compliance | Footprint accounting and verification |
| Export documents | Invoice, bill of lading, certificate of origin | Export, freight forwarders | Embedded-emissions data |
| PCF/CBAM page | Functional unit, boundary, data, factors, verification | Customers, importers, verifiers | Formal reporting and verification conclusions |
This page map is editorial; the accounting standard is GB/T 24067-2024, and CBAM obligations follow the official EU texts.
Which products and customers ask for carbon-footprint data?
Screen by product and market first: CBAM-covered categories exported to the EU (cement, steel, aluminium, fertilisers, electricity, hydrogen); parts supplied to brand customers in automotive, electronics, and appliances; products in green procurement, tenders, or customer ESG audits. Not every product needs a full PCF, but you need to know who is asking and at what granularity.
The European Commission states that CBAM covers cement, steel, aluminium, fertilisers, electricity, hydrogen, and other categories; 2023–2025 was the transitional period, and the definitive period started on 2026-01-01, with importers as authorised declarants submitting embedded-emissions information. The exact product scope, reporting obligations, default values, and verification requirements follow the official EU texts and implementing regulations; do not expand or narrow the scope on your own website.
| Driver | Who asks | Granularity | Common mistake |
|---|---|---|---|
| CBAM | EU importers/declarants | Product embedded emissions, boundary, default/actual | Using company totals as product emissions |
| Brand customers | Automotive, electronics, appliances | Product PCF, upstream data, reduction plan | Only a single total |
| Tenders/green procurement | Government, SOEs, platforms | Accounting report, verification statement, carbon label | Using an ESG report |
| Export compliance | Destination customs/customers | Destination-specific basis | Applying domestic rules directly |
| Internal improvement | EHS/energy/production | Hotspot processes, energy, material substitution | External reporting only |
Scope and customer requirements follow the product and contract; CBAM information is on the European Commission CBAM page, with the official texts controlling.
How should the accounting boundary and functional unit be set?
First set the functional unit (e.g. 1 tonne of conforming product, 1 piece, 1 kg of material) and declared unit, then the boundary (cradle-to-gate, cradle-to-grave, partial footprint), stating which life-cycle stages are included, what is excluded, allocation rules, and cut-off. When the boundary changes, the numbers are no longer directly comparable.
GB/T 24067-2024, Greenhouse gases—Carbon footprint of products—Requirements and guidelines for quantification, was published on 2024-08-23 and took effect on 2024-10-01; it is current and adopts ISO 14067:2018 with modifications. It follows the life-cycle assessment method consistent with GB/T 24040 and GB/T 24044, specifies principles, requirements, and guidance for quantifying and reporting product carbon footprints and partial product carbon footprints, addresses only climate change, and excludes carbon offsets and product footprint communication. When the website says "carbon footprint," state whether it is a full or partial product footprint and which stages are covered.
| Element | What to state | Evidence | Common gap |
|---|---|---|---|
| Functional unit | 1 tonne/1 piece/1 kg, mass or function basis | Accounting report | Only "per batch" |
| Declared unit | Matches the delivery unit | Spec sheet | Differs from invoice unit |
| Boundary | Cradle-to-gate/full life cycle/partial | Boundary diagram | Vague boundary |
| Stages | Materials, transport, production, packaging, use, disposal | Process list | Missing upstream |
| Allocation | Rules for multi-product/shared lines/by-products | Allocation note | Arbitrary allocation |
| Exclusions | Cut-off rules, excluded items and rationale | List | Undisclosed exclusions |
Method and boundary follow the GB/T 24067-2024 standard page and ISO 14067:2018; the specific boundary follows the product, customer requirements, and verifier opinion.
How should data sources and emission factors be accepted?
Separate primary data (measured energy, materials, output) from secondary data (database factors, industry averages, supplier-provided); state the data year, geography, technology, source, and uncertainty. Prefer traceable measured data and official/authoritative factor databases; label default values with source and applicability, and never present a default as measured.
The Implementation Plan for Establishing a Carbon Footprint Management System (Huan Qihou [2024] No. 30, 2024-05-22) targets an initial system by 2027, with around 100 key-product accounting rule standards and an initial product carbon-footprint factor database; by 2030, around 200 rule standards and a basically complete factor database. It prioritises steel, electrolytic aluminium, cement, fertilisers, hydrogen, lithium batteries, new-energy vehicles, photovoltaics, and electronics, and emphasises data quality, traceability, and data security.
| Data | What to state | Evidence | Common gap |
|---|---|---|---|
| Energy | Electricity, gas, fuel metering and year | Bills/metering | Estimates unlabelled |
| Materials | Main inputs, quantities, sources | BOM/procurement | Main material only |
| Output | Conforming output, allocation basis | Production reports | Mismatch with finance |
| Factors | Source, year, geography, technology | Factor database/report | Unknown source |
| Defaults | Source, applicability, substitution rules | Rule document | Used as measured |
| Uncertainty | Data-quality rating, sensitivity | Assessment record | Only one number |
Data and factor requirements follow the Implementation Plan and GB/T 24067-2024; specific factor databases and defaults follow the applicable rules.
How do verification, claims, and "certification" differ?
Verification is a third party checking the accounting report and data against a standard and issuing a verification statement; certification usually means system or product conformity certification; CBAM itself has no "CBAM certificate." The page should state the verifier, scope, standard, report number, and validity, and should not present a verification statement as a certificate or "carbon neutrality" as a selling point.
Customers and importers need verifiable data and evidence, not a label. Common errors include: treating an ISO 14001 certificate as footprint verification; treating an ESG reduction pledge as product data; and calling purchased offsets a "zero-carbon product." GB/T 24067-2024 explicitly excludes carbon offsets, so website wording should avoid such claims.
| Document | What it proves | Issued by | Common misuse |
|---|---|---|---|
| Accounting report | Method, boundary, data, results | Company/consultant | No boundary statement |
| Verification statement | Third-party conclusion on report and data | Verifier | Called a "certificate" |
| System certification | ISO 14001 and similar conformity | Certification body | Used as product footprint proof |
| Carbon label | Footprint information per a scheme | Certification/authorised body | Self-made label |
| CBAM declaration | Importer reports embedded emissions to the EU | Authorised declarant | Supplier claims "CBAM certified" |
The boundary between verification and certification follows the applicable standard and the body's statement; the CBAM reporting obligation sits with the importer, per the official EU texts.
How should CBAM customer data requests be handled?
Confirm the customer's identity and purpose (importer declaration, brand PCF, tender), then provide against their template: product and CN/HS code, plant, boundary, embedded emissions, default or actual values, data year, verification status, and contact. Do not make the declaration conclusion for the importer, and do not put commercially sensitive data on a public page.
Under the CBAM definitive period, importers must submit embedded-emissions information under the rules, and suppliers are their data source. The website can publish "what document types, basis, and request process are available," while specific data go through an NDA or customer portal; the public page should not carry customer-specific plant energy, cost, or undisclosed process data. Where the basis is uncertain, state that the official EU texts and the customer's reporting requirements control.
| Customer asks | You provide | Evidence | Common gap |
|---|---|---|---|
| Product identity | Name, model, CN/HS, plant | Spec/customs | Codes inconsistent |
| Embedded emissions | Value by boundary and functional unit | Accounting sheet | Company total only |
| Default/actual | Which was used, source and conditions | Rules/report | Mixed without note |
| Data year | Period and representativeness | Ledger | Old data |
| Verification | Whether verified, body, scope | Statement | Called certification |
| Contact | Data owner/email | Contact page | Sales only |
CBAM data requests follow the customer template and EU rules; the public page states document types and process only, with details through authorised channels.
How should upstream and transport data be collected?
Upstream materials are the largest part of most product footprints. Build a supplier data-request template: material type, quantity, factor source, transport mode and distance, and whether verified; grade suppliers by data quality, and use conservative defaults with a label where data are missing. Transport should distinguish inbound/outbound, mode, distance, and load factor.
Many companies count only their own electricity and gas, missing the emissions in steel, aluminium ingots, or plastic pellets, and the customer's calculation comes out very different. Upstream data collection can be combined with supplier onboarding and codes of conduct: add "can you provide a footprint/factor/verification statement" to the onboarding questionnaire, and write the data-provision and confidentiality obligation into the purchase contract. Carbon data then becomes part of supply-chain management rather than an emergency request.
| Step | What to collect | Evidence | Common gap |
|---|---|---|---|
| Raw materials | Type, quantity, factor, source | Procurement/BOM | Industry average unlabelled |
| Suppliers | PCF/verification, data year | Questionnaire/statement | No data |
| Transport | Mode, distance, load, return trips | Logistics documents | One-way only |
| Packaging | Material, weight, recycled content | BOM | Packaging omitted |
| Energy | Electricity, fuel, green certificates | Bills/certificates | Double-counted green power |
| Data quality | Measured/calculated/default, rating | Assessment sheet | Not distinguished |
Upstream and transport requirements are editorial; the specific basis follows GB/T 24067-2024, customer requirements, and verifier opinion.
How should data quality, confidentiality, and updates be accepted?
State the data year, quality rating, uncertainty, verification status, and update frequency; the public page carries only method, scope, and contact, while customer-specific data go through an NDA or portal; when factors, processes, or suppliers change, update the report and keep versions. Do not put customer names, prices, or detailed energy data in a public download.
The Implementation Plan emphasises data quality, traceability, data security, and IP protection; when publishing footprint information, separate "public method and results" from "confidential detail." A practical approach is a public summary (method, boundary, result range, verification status) and an authorised detail pack (for customers/verifiers on request), both on the same version.
| Item | Requirement | Evidence | Common gap |
|---|---|---|---|
| Data year | Reporting period, representativeness, update frequency | Version page | Not updated for years |
| Quality rating | Measured/calculated/default, uncertainty | Assessment sheet | Results only |
| Confidentiality | Public summary vs authorised detail | NDA/permissions | Detail made public |
| Version | Number, reason for change, effective date | Version log | Overwrites old version |
| Verification | Body, scope, statement number | Statement | None |
| Update trigger | Process/material/factor/customer change | Change log | Never updated |
Data quality and confidentiality follow the Implementation Plan; the disclosure scope follows company policy and customer agreements.
What should the page say, and how should it link?
Include products and markets covered, functional unit and boundary, data sources and factors, verification and claims, CBAM document types, request process and confidentiality, version and update, and a contact; link to the ESG page, certification page, export-document page, and supplier-onboarding page. The public page gives method and summary; detail goes through authorised channels.
Make it a "carbon footprint information" page: first answer which products are covered, under which standard, and to which boundary; then what customers can request and how; finally verification status and version. Do not treat one PDF as the whole answer, and do not turn "low carbon/zero carbon" into a slogan without evidence.
| Module | What to write | Evidence/asset | Common gap |
|---|---|---|---|
| Products covered | Categories, markets, customer types | List | No scope stated |
| Method/boundary | Standard, functional unit, stages, exclusions | Accounting report | Only "accounted" |
| Data/factors | Data year, source, defaults | Data sheet | Unknown source |
| Verification/claims | Body, scope, number, validity | Statement | Called certification |
| CBAM documents | Fields available, request process, confidentiality | Template/NDA | Detail public |
| Version/contact | Version, update date, data owner | Version page | No contact |
| Links | ESG, certification, export documents, supplier onboarding | Page test | Broken links |
These modules are editorial; public scope, data authorisation, and wording follow company policy, customer agreements, and verifier opinion.
Go-live acceptance checklist
Ten checks: products covered, functional unit and boundary, data and factors, verification statement, CBAM document types, upstream and transport data, data quality, confidentiality and authorisation, version and update, and links/contact. Each needs an owner, evidence, and review date.
Export, EHS, energy, quality, legal, IT, and the website vendor can share this list. The pass condition is not "the page mentions a carbon footprint"; it is that a customer can tell whether the data covers their product, under which boundary, whether it can support their reporting, and whom to ask for detail.
| Check | Pass condition | Evidence | If it fails |
|---|---|---|---|
| Products | Categories, markets, customer types stated | List | Add scope |
| Functional unit/boundary | Unit, stages, exclusions, allocation | Accounting report | Add notes |
| Data/factors | Year, source, defaults, uncertainty | Data sheet | Add sources |
| Verification | Body, scope, number, validity | Statement | Add verification |
| CBAM documents | Fields, process, confidentiality, contact | Template/NDA | Add process |
| Upstream/transport | Materials, suppliers, mode and distance | Questionnaire/logistics | Add data |
| Data quality | Measured/calculated/default graded | Assessment sheet | Add rating |
| Confidentiality | Public summary vs authorised detail | Permissions/NDA | Tighten access |
| Version | Number, update date, change log | Version page | Add log |
| Links/contact | ESG/certification/export/onboarding reachable; data owner named | Page test | Fix links |
This checklist is editorial; specific accounting, verification, CBAM, and disclosure requirements follow the standards, EU rules, customer contracts, and verifier opinion.
Who should read this, who should not, and what decisions does it support?
It suits manufacturers in Changzhou and nearby areas that export to the EU or supply brand customers and are asked for product footprint/CBAM data; it does not suit teams with no product or energy data and no accounting capability that want to hang a "zero carbon" label first.
Read it if you are in export, EHS, energy, quality, legal, IT, or a website vendor; you are building a PCF/CBAM page, a customer carbon-data questionnaire, verification preparation, or supplier carbon-data collection; or you need to decide which products to cover, how to set the boundary, which factors to use, whether to verify, what to give CBAM customers, and how to keep data confidential. Skip it if you treat an ESG report as a product footprint; you present a verification statement as a certificate; or you want one page to replace accounting, verification, EU reporting, or legal advice. It supports self-review of products covered, functional unit and boundary, data and factors, verification claims, CBAM documents, upstream data, confidentiality, and page acceptance.
Lingyi Information is a website development and enterprise AI project provider, not a carbon accounting body, verifier, certification body, or legal/customs adviser. This article is not a substitute for carbon accounting, verification, CBAM reporting, or legal advice. Changzhou projects are delivered remotely or on site as confirmed per project; Lingyi is one candidate, does not claim a local office or team, and does not promise verification outcomes, customer orders, or inquiries.
FAQ
Can the website say "carbon neutral/zero-carbon product"?
Be very cautious. GB/T 24067-2024 explicitly excludes carbon offsets, and a product carbon footprint is an accounting result, not "zero carbon." Unless there are clear accounting, reduction, and offset rules plus third-party evidence, do not use "carbon neutral/zero carbon" as a selling point—it can mislead.
Does an ISO 14001 certificate mean we have a product carbon footprint?
No. ISO 14001 is an environmental management system certification; a product footprint must be calculated for a specific product under GB/T 24067-2024/ISO 14067 and may need third-party verification. They prove different things, so state them separately.
Is there a "CBAM certification"?
CBAM is the EU's carbon border adjustment mechanism; the reporting obligation sits with the importer (authorised declarant), and there is no supplier "CBAM certificate." Suppliers provide embedded-emissions data and evidence; do not claim to be "CBAM certified."
What if the customer's carbon data basis differs from our report?
Confirm the functional unit, boundary, data year, and factor source, then judge whether a mapping is possible; if not, explain the difference and ask the customer to confirm an acceptable alternative. Do not apply one product's data to another, and do not allocate company totals by output arbitrarily.
What if upstream suppliers will not provide data?
Use secondary data from authoritative factor databases or conservative defaults, but label the source, applicability, and uncertainty; at the same time, add carbon-data requirements to supplier questionnaires/contracts and replace with measured data over time. Do not pretend a default is measured.
How often should a footprint report be updated?
It depends on customer requirements, rule changes, and data changes. Update when processes, materials, energy mix, factor databases, or customer requirements change materially; even without changes, set an annual or biennial review. The page should state the version, data year, and next review date.
One-sentence takeaway
A Changzhou export manufacturer's product carbon footprint / CBAM page should not say "we are low carbon." It should turn products covered, functional unit and boundary, data and factors, verification claims, CBAM customer documents, upstream data, confidentiality, and versions into a verifiable checklist—so a customer can judge whether the data applies and whom to ask for detail.
Method and limitations
This is a review of public rules, standards, and project practice, not a compliance certification or legal opinion on any company, product, accounting, verification, or CBAM declaration. No undisclosed customer carbon, energy, or supplier data were used. Page structure, boundary fields, data lists, and the acceptance checklist are editorial suggestions, not accounting, verification, or reporting conclusions. Actual rules, boundaries, factors, verification, CBAM obligations, and disclosure requirements depend on the applicable standards, official EU texts, customer contracts, and verifier opinion.
Sources and scope
Information is current to 2026-11-01. The following are public official/primary pages; their scope, version, and wording control.
- GB/T 24067-2024, Greenhouse gases—Carbon footprint of products—Requirements and guidelines for quantification (published 2024-08-23, effective 2024-10-01, current; adopts ISO 14067:2018 with modifications): National Standards Full-Text Public System.
- Implementation Plan for Establishing a Carbon Footprint Management System (Huan Qihou [2024] No. 30, MEE and 14 other departments, 2024-05-22): gov.cn.
- ISO 14067:2018, Greenhouse gases — Carbon footprint of products — Requirements and guidelines for quantification: International Organization for Standardization.
- European Commission, Carbon Border Adjustment Mechanism: European Commission. Transitional period 2023–2025, definitive period from 2026-01-01, covered categories, and reporting framework; specific obligations follow the EU regulations and implementing acts.