The EU's Carbon Border Adjustment Mechanism (CBAM) puts a carbon price on imports of cement, iron and steel, aluminium, fertilisers, hydrogen and electricity. Its definitive regime began on 1 January 2026. EU importers of these goods now need authorisation as CBAM declarants, declare the embedded emissions of their imports each year, and buy and surrender CBAM certificates priced on the EU Emissions Trading System.
The obligation sits with the EU importer, but the data comes from you, the producer. Exporters who can supply accurate, verified emissions data make their EU customers' compliance easier, help them avoid default values and stand out with buyers. Because CBAM certificate prices follow EU ETS allowance prices, the embedded emissions in your products become part of the cost your EU customers weigh up when they choose suppliers.
Embedded emissions per product. The direct emissions from producing the goods and, for some goods, the indirect emissions from the electricity used, calculated for each installation and product.
Actual data or default values. Where actual data is not available, default values set by the European Commission are used.
Verification. Actual emissions data is checked by accredited verifiers.
Annual timing. Authorised declarants submit a CBAM declaration by 30 September for the previous year's imports, so data for 2026 imports is needed in 2027.
Small importers. EU importers bringing in no more than 50 tonnes of CBAM goods a year are exempt; the threshold does not apply to hydrogen or electricity.
CBAM screening. Confirm which of your products fall under CBAM by customs (CN) code, and which EU customers are affected.
Embedded-emissions calculation. Set installation boundaries, production processes and monitoring methods, and calculate the specific embedded emissions of each product, following the CBAM calculation rules for each production route.
Supplier data. Collect emissions data for precursor materials from your own suppliers where it is needed, and explain to them what to measure.
Data for EU importers. Prepare the emissions data in the form your EU customers need for their declarations, in a consistent format each period, so that their declarations and your records match.
Verification readiness. Prepare your monitoring documentation and evidence for the accredited verifier, including the site records a verifier will ask to see.
Reduction and cost planning. Show where lower emissions reduce your customers' CBAM costs, and how that can support your pricing and market position.
Screen. List your CBAM products, customers and installations.
Map. Define installation boundaries, production routes and the data each one needs.
Measure and calculate. Collect the data and calculate embedded emissions per product.
Share and verify. Provide the data to your EU customers, prepare for verification and update the data each year.
Start with a screening of your products and customers, then collect one year's production and energy data for each installation. Your EU customers will need data for their 2026 imports, so 2026 is the year to begin with.
A CBAM applicability note by product and customer
A monitoring methodology document for each installation
An embedded-emissions calculation workbook
A data set for your EU customers, ready for their declarations
A verification evidence file and an improvement plan
Producers and exporters of CBAM goods, including small and medium exporters whose EU buyers have started asking for data; trading companies that need data from the manufacturers they buy from; and EU importers sourcing from India.
The CBAM declaration is the EU importer's obligation, and the importer must be an authorised CBAM declarant. As the producer, you supply the embedded-emissions data your customer declares. Without good data from you, your customer may have to use default values.
Cement, iron and steel, aluminium, fertilisers, hydrogen and electricity, identified by their customs (CN) codes. We check your product list code by code.
The CCTS is India's domestic scheme, with emission intensity targets for obligated entities. CBAM is an EU charge on imports. A company can be affected by both, and the same plant-level data can support both – see CCTS (compliance entity).
As soon as you export CBAM goods to the EU. The definitive regime began on 1 January 2026, and your customers' first annual declarations, covering 2026 imports, are due by 30 September 2027.
CCTS (compliance entity) · GHG accounting · Carbon footprint · Product Life Cycle Assessment study
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