CBAM Shipment-Evidence Architecture Director

The mandate

The CBAM definitive regime has applied since 1 January 2026, yet the distributor still receives mill emissions files by quarter while customs entries identify product, origin and consignment. Material may pass through service centres that split coils, combine heats or alter tariff classification, and procurement cannot tell which supplier evidence survives that transformation. The defined problem is a reproducible shipment evidence architecture for imported steel, not calculation advocacy, certificate trading or legal interpretation.

The deliverable is a controlled CBAM shipment book containing product-scope rules owned by authorised specialists, producing-installation identity, production-route and precursor links, embedded-emissions evidence states, service-centre transformations, consignment allocation, import-entry reconciliation, default-data triggers, correction control and certificate-exposure inputs. Twenty representative imports and six supplier archetypes form the case library. Filing, assurance opinion, customs representation, tax advice and supplier contracting are excluded.

Milestone one, at the end of week two, reconciles the supplier, product, installation and entry populations. Milestone two, at week four, provides evidence states and transformation rules. Milestone three, at week six, traces ten imports and resolves source breaks. Milestone four, at week eight, completes ten further cases and a supplier-correction exercise. Milestone five, at week ten, submits the accepted control book, ownership model and 120-day closure backlog.

Acceptance requires Procurement, Customs, Finance and Sustainability to reproduce all twenty cases from entry line to producing installation, route, quantity and authorised emissions input, including split coils and combined service-centre output. Each use of default or estimated data must carry trigger, approver, exposure, supplier action and correction deadline. The council accepts when two independent teams reach the same allocation, authorised counsel confirms decision boundaries and no severity-one break remains hidden by quarterly aggregation.

The client will provide supplier declarations, installation and production-route files, purchase orders, mill certificates, processor records, product master, customs entries, quantities, corrections, contracts and current authorised interpretations. It will nominate functional owners, secure five supplier or processor reviews and obtain legal or verifier decisions when required. Management retains filing, certificate purchase, customs, contract, pricing and disclosure authority; the consultant delivers operating evidence only.

Why this is external work

Procurement sees mills, Customs sees entry lines, Sustainability sees emissions reports and Finance sees certificate exposure, but none owns material identity through service-centre transformation. Existing advisers answer regulatory questions without reconstructing physical consignments. An independent director with steel and import-control depth can establish the operating join while remaining outside filing and assurance.

What you will own

• Reconcile 38 supplier and processor populations across installations, production routes, products, precursors, consignments and import entries.
• Define evidence states for supplier-specific, estimated, default, corrected and expired inputs with authorised decision ownership.
• Trace twenty imports through coil split, processing, aggregation, storage and entry without inventing shipment-to-installation relationships.
• Design allocation rules for transformations and mixed receipts, exposing uncertainty, quantity loss and unsupported emissions inheritance.
• Run one supplier-correction exercise from revised source evidence through affected entries and certificate-exposure inputs.
• Separate operating control from legal scope, customs classification, verification, filing and certificate-purchase decisions throughout.
• Deliver the accepted shipment book, case library, owner training, controlled rules and funded 120-day backlog.

Candidate qualifications

• Designed CBAM, carbon-accounting or equivalent regulated import evidence for steel, aluminium or other transformed industrial materials.
• Has traced mill or installation data through processors and consignments where quarterly supplier totals could not support entries.
• Understands steel heats, coils, service-centre conversion, purchase orders, customs lines and emissions inputs as linked evidence.
• Can work within authorised regulatory interpretations without giving tax, customs, assurance, verification or legal advice.
• Has rejected a supplier-specific claim when quantity, route, installation or transformation evidence could not be reproduced.
• Delivered shipment controls that procurement and import teams operated after specialist consultants and spreadsheets were withdrawn.

Non-negotiables

• Can complete five mill, processor or import-control reviews and twenty traced cases within ten weeks.
• Will not sell emissions verification, certificate trading, customs representation, legal or tax services into the engagement.
• Accepts management and authorised-specialist authority over scope, entries, filings, certificates, contracts and disclosure.
• Brings physical steel or metals traceability; sustainability reporting experience alone is insufficient.

1. 49 words maximum. Describe an import case where processor transformation broke the link to producing-installation data.
2. 49 words maximum. How would you allocate source evidence when one coil is split across several customs consignments?
3. 49 words maximum. Which default-data trigger must remain visible after a supplier submits a late correction?