Your line about the verification attaching to the installation and not the importer made me read twice: at my end that installation is somebody's workshop. I ship homeware out of Taipei and I do not know whether my aluminium lamp parts are in scope or nowhere near it. I do know that in two years of European orders, no buyer has asked me for an emissions figure. That may answer your question from the other side.
So who books the physical visit, and who pays for it? If that cost lands on the supplier, workshops my size will stop quoting to Europe, and the declarant will find out late.
Strictly speaking, the visit is not an obligation on your workshop. It is the price of an actual figure. The Commission's Q&A leaves verification to the operator's choice, and if you decline, your buyer declares on default values, mark-up and all.
If you do verify, the booking is yours: the Commission's verifier guidance has operators contracting verifiers, and lists the operator paying as a risk to impartiality, which tells you whose invoice they pictured. No rule I have read allocates that invoice, though. It belongs in your price.
On scope, check the eight-digit CN code your buyer declares at import against Annex I of the CBAM Regulation. I will not guess yours from the word lamp. Your quiet buyers may also simply import under the 50-tonne yearly threshold.
And you are right that the declarant finds out late. He alone answers for the declaration.
Your impartiality line is the one that changed something for me. I had assumed the buyer would absorb that invoice; now it goes in my price.
I read the aluminium part of Annex I myself. Kitchen and table articles fall outside, the catch-all for other articles of aluminium falls inside, and my range straddles that line.
Two questions for my buyer, neither about carbon. The last two digits of the code they declare, since the first six sit on my export paperwork. And whether they stay under the threshold across everything they import all year, not just my pallets. That exemption is theirs to claim on their own declaration, so I would never see it. Would they know in January?
Strictly speaking they cannot know in January, and the rule does not ask them to. The amendment that created that threshold runs on expectation: an importer who expects to exceed applies before it crosses, not after. Your buyer holds a forecast, not a fact. So ask for notice rather than a promise: tell me when you apply.
As for standing, you have none. No rule I have read lets a supplier ask, so it is a contract term or nothing.
One thing should change your filing regardless. Once that threshold goes, every tonne that importer brought in that calendar year goes with it, your January pallets included. Keep the emissions paper on goods you shipped under an exemption that may not survive the year. You were right that you would never see the claim, which is exactly why the file must be yours.