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Independent regulatory evidence review

Regulatory data must be traceable, reviewable and supported by evidence.

WEETRA examines the documentary basis behind a regulatory figure, including the records, sources and calculations used to support it. The review identifies what does not hold. That may be an inconsistency, a missing critical document or a source that cannot support the position claimed. This work takes place before the file is finalised for reporting.

CBAM is our first operational use case. The same review approach is designed to extend to Digital Product Passport requirements and, subsequently, EUDR evidence chains.
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The premise

You may already have the CBAM figures. The harder question is whether the file can support them.

Reporting now runs on structured data, sources that can be traced, calculations that hold, and a documentary trail someone can actually review. WEETRA checks whether each material value ties back to a source, matches the documents, and, where the data allows, can be recomputed.

What WEETRA reviews

What WEETRA examines

01

Source Documents

Identification of the source documents that support the position being relied upon.

02

Declared, Extracted & Recalculated Values

Comparison of declared values with the values found in the record and, where possible, recalculated from the available inputs.

03

Critical Contradictions & Missing Critical Evidence

Identification of contradictions, missing evidence and source limitations that affect the file.

04

Evidence-Chain Integrity

Examination of whether the relevant evidence can be traced from source to the regulatory position it is used to support.

How a WEETRA review works

How a WEETRA review works

STEP 01

Scope and documentary corpus are agreed

The mandate identifies the goods, suppliers, installations, periods, questions and documentary population under review. Anything outside that boundary remains outside the conclusion.
STEP 02

Relevant documents and regulatory positions are identified

WEETRA identifies the records relied upon for the positions in the file and the regulatory questions those records are expected to support. The objective is to understand what the file is actually asserting before testing whether the documentary basis holds together.
STEP 03

Data are compared across sources

Quantities, installation identities, periods, supplier information, emissions data and supporting calculations are compared across the available records. Calculations are reproduced where the mandate, governing rule and necessary inputs allow it.
STEP 04

Missing evidence, contradictions and source limitations are documented

A missing document is not treated as the same thing as a contradiction, and a source limitation is not presented as a factual inconsistency. Each issue is described according to what the evidence actually shows.
STEP 05

Clarification and remediation take place where included

Where the mandate includes remediation, WEETRA identifies what requires clarification or correction. The client, supplier, adviser or relevant operational team produces the new material. WEETRA then examines the resulting versioned state.
STEP 06

WEETRA issues its Determination and preserves the reviewed basis

The Determination records what the reviewed file supports at the agreed cut-off, including any limitations or blocking conditions. Where the engagement provides for it, supporting review records preserve the evidentiary basis needed to understand that conclusion later.
CBAM review options

Review depth depends on the question being asked.

START HERE

CBAM Evidence Check

A focused first examination of the CBAM documents already available. It looks for visible gaps, inconsistencies and missing supplier evidence before a full review is considered.

LEVEL I

CBAM Documentary Review

Structured review of what the existing CBAM documentary record currently supports.

LEVEL II

CBAM Evidence Chain Review

Reconciles sources, facts, calculations and contradictions across the evidence chain, with remediation where included.

LEVEL III

CBAM Forensic Evidence Review

Link-by-link reconstruction and adversarial examination for complex or high-consequence CBAM files.

The review option determines how far the examination goes. It never predetermines the conclusion.

First operational use case

CBAM documentary and evidentiary review

CBAM is WEETRA's first operational use case. WEETRA reviews the coherence and traceability of supporting information relating to goods, installations, embedded emissions, calculation inputs and documentary evidence.

Accredited verification, where required, remains the independent statutory function of the verifier.
CBAM goods · installations · embedded emissions · calculation inputs

Verification Readiness →

Where evidentiary problems appear

When a CBAM file becomes difficult.

The problem is rarely the complete absence of data. More often, the documents available do not establish every relationship needed to support the position being relied upon. The situations below are illustrative, not automatic findings of failure.

01

Installation linkage

An emissions value is available, but the reviewed evidence does not clearly connect the relevant goods to the installation to which the value relates.

02

Period alignment

Supplier, production, commercial or emissions records refer to periods that do not align cleanly.

03

Precursor dependency

A precursor value is present, but its producer, installation, period or supporting evidence chain is incomplete.

04

Quantity reconciliation

Customs, commercial and emissions records use quantities that cannot immediately be reconciled.

05

Verification relationship

A verification report exists, but its relationship to the installation, period or emissions information being relied upon must still be established.

06

Fragmented evidence

The organisation holds the information, but it is dispersed across PDFs, spreadsheets, supplier messages and later corrections, making the reviewed state difficult to reconstruct.

Explore CBAM

The conclusion

How WEETRA records the outcome of a review.

The status records what the examined evidence supports, what remains unresolved and what may prevent the file from progressing. It is a WEETRA review conclusion within the agreed mandate, not a regulatory decision, certification or accredited verification opinion.

Understand the Determination

What happens to the file

From a document set to a reviewable evidentiary state

01The organisation provides. The agreed file may include commercial and customs records, supplier and installation information, emissions documentation, verification material where relevant, carbon-price evidence where relevant and supporting correspondence.
02WEETRA examines. The review then examines how those documents relate to the positions they are meant to support, including quantities, periods, installations, calculations, source consistency, missing evidence and contradictions.
03The organisation receives. A clear account of what the reviewed file supports, what remains unresolved and what requires clarification or remediation. A Determination and supporting package are provided where included in the selected review.

The review record preserves the reviewed basis, unresolved conditions and the path to the final Determination so they can be reconstructed later.

Explore Documented Evidentiary Due Diligence

Documented Evidentiary Due Diligence

Preserve what was reviewed, and why the conclusion was reached.

A later reader should be able to understand which documents were examined, which facts and source relationships were relied upon, which contradictions remained open, what was corrected and what the evidence supported at the relevant cut-off.

The report communicates the Determination. Where included in the mandate, the underlying package preserves the reviewed basis needed to understand and reconstruct that conclusion later.

Explore Documented Evidentiary Due Diligence

Beyond the report

What you receive from a WEETRA review

The report records the Determination. The supporting review record preserves the basis that led to it.

Where the engagement provides for a structured package, the reviewed record is prepared for later professional use. Internal teams, legal or customs advisers and other reviewers can see which sources were examined, what remained limited, what was remediated and why the Determination was reached. Accredited verifiers and other receiving professionals remain responsible for their own procedures and conclusions.

What it changes

What structured evidentiary review can change.

A structured evidentiary review changes what an organisation knows about its own file, and how early it knows it. It separates supported positions, missing evidence, contradictions and remediation priorities before later professional scrutiny.

01

Supported claims

It can help an organisation identify which claims are actually supported by the current file, and which rest on material that has not been examined.

02

Missing against conflicting

It can help distinguish missing evidence from contradictory evidence, two conditions that call for different responses.

03

Targeted requests

It can help formulate targeted supplier requests instead of generic questionnaires that return generic answers.

04

Remediation priority

It can help an organisation understand which issue must be remediated, and why it matters to the position being relied upon.

05

Version preserved

It can help preserve which version of the file was actually reviewed, rather than reconstructing it later from uncontrolled emails and revisions.

06

Later scrutiny

It can help prepare structured information for an authorised declarant, an accredited verifier or later external scrutiny where relevant.

Where the approach can extend

CBAM today.
Other evidence-intensive regimes later.

NOW

CBAM

Current operational use case for embedded emissions traceability.

Operational
NEXT

Digital Product Passport

Research and planned extension around product-level identity, provenance and evidence relationships.

Research / planned extension
SUBSEQUENT

EUDR

Subsequent extension for origin, geolocation and due-diligence chains.

Planned extension
How WEETRA works

What the institute does

WEETRA brings regulatory analysis, file review and professional training back to the same question. What does the available evidence actually support?

The WEETRA principles
01.Evidence before assertion.
02.Reasoning before opinion.
03.Traceability before reporting.
04.Transparency before confidence.
05.Documentation before determination.
Where WEETRA sits

Four roles in one regulatory chain

01Importer / authorised declarant. Owns the regulatory declaration and the positions submitted.
02WEETRA. Examines, structures and tests the documentary and evidentiary basis supporting those positions.
03Accredited verifier. Performs independent regulated verification where the applicable framework requires it.
04Competent authority / customs. Exercises the powers assigned to it by law and may assess the submitted regulatory position.

The Determination documents the reviewed evidentiary state. Statutory responsibilities remain with the actors to whom the law assigns them.

Let's get to work

Prepare the evidence before the data is challenged.