{"service":"RegRails","methodologyVersion":"rr-1.0.0","published":"2026-08-11T23:08:42.517Z","principle":"Check what can be checked deterministically from published legal text — code scope, thresholds, field structure, geometry, arithmetic — and refuse to guess at everything else. Where a number would require a reference value that can go stale, RegRails asks the caller for it rather than bundling a figure that may be wrong by the time it is used.","whatIsDeliberatelyNotDone":["No default emission factors are bundled. CBAM cost figures are arithmetic on caller-supplied intensities.","No satellite or deforestation data is consulted. EUDR checks are structural and geometric only.","No classification of goods. RegRails checks the code you give it; it does not tell you which code applies.","No filing. Nothing is transmitted to any authority.","No conformity assessment under the AI Act."],"evidenceModel":{"assurance":"Ordinal, not numeric. A number would imply a calibration RegRails has not performed.","calibration":"RegRails does not publish precision/recall against a labelled corpus and does not claim calibration.","integrityVsTruth":"Signing proves provenance and integrity, not correctness.","asymmetry":"A scope match is a strong signal. A non-match is weak and is never proof of exclusion."},"globalLimitations":["RegRails performs STRUCTURAL and ARITHMETIC checks against published legal texts. It is not legal advice, not customs advice, not a customs ruling, and not a submission to any authority.","RegRails does not file, lodge or transmit anything to the EU CBAM Registry, the EU Information System for EUDR, or any national authority. Producing a valid-looking result here does not discharge any obligation.","Reference data (CN and HS code scope, thresholds, dates) is bundled as of a stated date and can be amended by implementing or delegated act at any time. Always verify against the consolidated text and the relevant Annex before relying on any answer.","RegRails is operated by an independent professional, not an authorised customs representative, and carries no professional indemnity cover. Decisions with financial or legal consequence should be confirmed with a qualified adviser."],"semantics":{"structuralIsNotSubstantive":"A \"structurally valid\" result means the input is well-formed and internally consistent. It is NOT a statement that the underlying facts are true, that the emissions figures are correct, or that the land was deforestation-free.","inScopeIsAdvisory":"Scope answers match against bundled code entries derived from Annex I. Annex I uses \"ex\" entries that cover only PART of a heading; where one is matched, RegRails returns inScope: \"requires_verification\" rather than a yes, because a heading-level match cannot decide those. A clean match is a strong signal; a NON-match is weak and is never proof a good is outside scope. Annex I is the authority.","arithmeticNotEstimation":"Where a figure is returned, RegRails performed arithmetic on values YOU supplied. It does not supply default emission factors, benchmark values, or certificate prices, because a stale default produces a wrong liability.","signatureProvesIntegrityNotTruth":"The Ed25519 signature proves RegRails produced this exact response unaltered. It does not prove the conclusion is correct. A signed wrong answer is still wrong, and still signed.","absenceOfErrorIsNotApproval":"An empty errors[] means no configured check fired. It is not an approval, a clearance, or a defence against enforcement."},"endpoints":[{"decision":"cbam.scope","subject":"CN/CBAM code","checksPerformed":["CN digit normalisation","Longest-prefix match against bundled CBAM sector code list","De minimis applicability by sector"],"dataSources":[{"name":"Regulation (EU) 2023/956 Annex I (bundled prefixes)","refresh":"with releases; asOf published in response"}],"assurance":{"level":"structural","basis":"prefix match is deterministic; the underlying code list is bundled and can lag amendments"},"limitations":["A non-match does NOT establish that the good is outside CBAM. Composite and downstream goods are the usual failure case.","Where inScope is \"requires_verification\", Annex I lists the heading only partially and this service cannot decide it. Treat that as an instruction to check the subheading, not as a yes.","The bundled entries were corrected on 2026-08-11 against the consolidated text after external review. A pending proposal (COM(2025)0989) would extend CBAM to downstream steel and aluminium goods from 2028; it is not law and is not reflected here.","Does not determine the correct CN code for your goods — classification is a separate exercise and a customs matter.","Scope was proposed for expansion to further product categories; bundled lists may lag."]},{"decision":"cbam.threshold","subject":"annual import lines","checksPerformed":["Per-line scope determination","Cumulative net mass against the 50 t de minimis","Retroactivity flag on crossing","Exclusion of electricity and hydrogen from the de minimis"],"dataSources":[{"name":"Regulation (EU) 2023/956 as amended; 50 t de minimis","refresh":"with releases"}],"assurance":{"level":"deterministic","basis":"arithmetic on caller-supplied masses; no external data"},"limitations":["Only the lines you supply are counted. An incomplete list produces a falsely low total and a falsely reassuring result.","Net mass must be the customs net mass in tonnes. Unit errors are the most common cause of a wrong answer here."]},{"decision":"cbam.estimate","subject":"embedded emissions and indicative certificate cost","checksPerformed":["Per-line arithmetic: mass x intensity x (1 - free allocation share)","Aggregation","Optional cost multiplication by a caller-supplied certificate price"],"dataSources":[{"name":"Caller-supplied emission intensities and prices only","refresh":"n/a — nothing is bundled"}],"assurance":{"level":"deterministic","basis":"pure arithmetic on caller inputs; every step is echoed in the response"},"limitations":["RegRails supplies NO default emission factors. If your intensities are wrong, the output is wrong and the error is invisible here.","Does not apply the actual free-allocation phase-out schedule, carbon price paid in the country of origin, or any adjustment. It multiplies the share you give it.","Indicative only. It is not a liability calculation and must not be used as the basis for a declaration."]},{"decision":"cbam.declaration","subject":"draft CBAM annual declaration","checksPerformed":["Required top-level fields","Per-good required fields","CN scope consistency","ISO 3166-1 alpha-2 origin format","EU-origin contradiction","Reporting year plausibility","De minimis cross-check"],"dataSources":[{"name":"Structural expectations derived from the Regulation","refresh":"with releases"}],"assurance":{"level":"structural","basis":"field presence and internal consistency only"},"limitations":["Does not validate against the official CBAM Registry schema, which is authoritative and may require fields not checked here.","Does not verify any emissions figure, verifier accreditation, or supporting documentation.","A structurally complete declaration can still be substantively wrong and rejected."]},{"decision":"eudr.scope","subject":"HS code","checksPerformed":["HS digit normalisation","Longest-prefix match against bundled EUDR commodity list","Deadline tier lookup"],"dataSources":[{"name":"Regulation (EU) 2023/1115 Annex I (bundled prefixes)","refresh":"with releases"}],"assurance":{"level":"structural","basis":"prefix match is deterministic; bundled list can lag amendment"},"limitations":["A non-match is NOT proof the product is outside EUDR. Annex I is the authority.","Where inScope is \"requires_verification\", Annex I lists the heading only partially (\"ex\") and this service cannot decide it. Much of the cattle, rubber and wood scope is of this kind.","A Commission delegated act amending Annex I was adopted on 13 July 2026 and is NOT reflected in these entries. Verify against the consolidated text.","A simplification package was in trilogue as of the asOf date and was not binding. Deadlines and scope may change."]},{"decision":"eudr.geo","subject":"plot geolocation","checksPerformed":["GeoJSON type support","Coordinate bounds","Ring closure","Self-intersection","Approximate area","Point-vs-polygon rule above 4 ha","Declared-vs-computed area consistency"],"dataSources":[{"name":"Geometry supplied by the caller","refresh":"n/a"}],"assurance":{"level":"deterministic","basis":"computational geometry on caller-supplied coordinates"},"limitations":["Area is computed on a local equirectangular projection and is indicative, NOT survey-grade. Do not use it to determine the 4 ha threshold in a marginal case.","Does NOT check the plot against any satellite, forest-cover or deforestation dataset. Geometric validity says nothing about deforestation.","Does not verify the plot exists, is real, or is the plot your commodity came from."]},{"decision":"eudr.dds","subject":"draft Due Diligence Statement","checksPerformed":["Required fields","HS-to-commodity consistency","EORI format","ISO country format","Quantity plausibility and units","Per-plot geometry validation","Cut-off date assertion present"],"dataSources":[{"name":"Structural expectations derived from the Regulation","refresh":"with releases"}],"assurance":{"level":"structural","basis":"field presence, format and internal consistency only"},"limitations":["Does NOT check deforestation. Not against satellite data, not against any forest baseline, not at all.","Does NOT test the legality-of-production limb (Art. 3(b), Art. 2(40), Art. 9(1)(h)) at all — land use rights, environmental protection, forest rules, third-party rights, labour and human rights, FPIC, tax, anti-corruption, trade and customs. This is an independent limb of the obligation and a structurally valid DDS says nothing about it.","The Annex II field set is not the same thing as the Art. 8-9 due-diligence information set. Passing this check does not mean due diligence was performed.","Does not apply the Art. 4a simplified regime for micro and small primary operators, whose field expectations differ and where a postal address may replace geolocation.","Does not submit to the EU Information System and does not create a DDS reference number.","A structurally valid DDS containing false statements remains a false statement, with the operator liable."]},{"decision":"art50.check","subject":"AI Act Article 50 transparency controls","checksPerformed":["Obligation-category mapping","Declared control coverage"],"dataSources":[{"name":"Regulation (EU) 2024/1689 Article 50; AI Omnibus in force 2026-07-27","refresh":"with releases"}],"assurance":{"level":"structural","basis":"coverage check against a bundled category-to-control map"},"limitations":["Does not inspect your system. It checks only the controls you assert.","Not a conformity assessment and not a classification of your system under the Act.","Article 50 exemptions are fact-specific and are surfaced as notes, not applied."]},{"decision":"c2pa.check","subject":"content-credential manifest","checksPerformed":["Claim generator presence","Assertions array","c2pa.actions presence","digitalSourceType indicating trained-algorithmic media","Signature presence"],"dataSources":[{"name":"Manifest supplied by the caller","refresh":"n/a"}],"assurance":{"level":"structural","basis":"shape inspection only"},"limitations":["Does NOT verify the cryptographic signature or validate any certificate chain.","Does not confirm the manifest is bound to any particular asset, nor that the asset is unmodified.","Structural validity does not establish that a marking obligation is satisfied."]}],"corrections":"Errors, false positives and false negatives can be reported to contact@chainverdict.xyz. Material changes increment methodologyVersion."}