EU CBAM compliance support for exporters
Help for manufacturers shipping steel, aluminium, cement, fertilisers and hydrogen to the EU: accurate embedded-emissions data, clear documentation, and smooth coordination with your EU importer. English and Chinese.
What CBAM is
The Carbon Border Adjustment Mechanism (CBAM), established by Regulation (EU) 2023/956, puts a carbon price on certain goods imported into the EU. It mirrors the EU Emissions Trading System (EU ETS): EU importers buy and surrender CBAM certificates priced off EU ETS allowances, for the emissions embedded in the goods they import.
The transitional period (October 2023 – December 2025) required reporting only. The definitive regime, with a financial obligation, applies from 1 January 2026.
Covered sectors
Iron & steel
Including many steel products and certain downstream articles listed in Annex I.
Aluminium
Unwrought aluminium and listed aluminium products.
Cement
Clinker, cement and related goods.
Fertilisers
Nitrogen-based fertilisers and related products such as ammonia.
Hydrogen
Hydrogen imports.
Electricity
Electricity imported into the EU.
Exact coverage is defined by the CN codes in Annex I of the Regulation.
Obligations from 2026
- Authorised CBAM declarantThe obligation sits mainly with the EU importer (or its indirect customs representative), who must be an authorised CBAM declarant. Importers of CBAM goods other than hydrogen and electricity below a 50-tonne annual mass threshold are generally exempt; hydrogen and electricity always require authorisation.
- Certificate priceBased on the EU ETS auction price (€/tCO₂e): the quarterly average in 2026, the weekly average from 2027.
- From February 2027Sales of CBAM certificates begin on 1 February 2027. From 2027, declarants above the threshold must hold certificates covering at least 50% of embedded emissions in goods imported since the start of the year, at the end of each quarter.
- By 30 September 2027First annual CBAM declaration and certificate surrender for goods imported in 2026.
How the charge is calculated
- Embedded emissions — direct emissions from production, plus indirect emissions from electricity where the sector rules require it (for example, cement and fertilisers), per the Annexes and implementing acts.
- Actual vs default values — embedded emissions can be based on verified actual plant data or on default values. Default values are designed to be conservative, so they typically lead to a higher charge than accurate actual data.
- Free allocation adjustment — reflects the free allocation still given to EU producers under the EU ETS. It is calculated per tonne from CBAM benchmarks and the CBAM factor (Implementing Regulation (EU) 2025/2620), and is zero for electricity. The right CN code and production route determine which benchmark applies.
- Carbon price paid — a deduction is possible for a carbon price effectively paid in the country of origin, if and to the extent it is recognised under CBAM rules and properly evidenced.
How we help exporters
Emissions data packs
- Collect plant-level production and energy data
- Prepare actual specific embedded emissions per product, following the EU methodology
- Organize records for independent verification
Classification & route
- Check CN codes against Annex I
- Document the production route (e.g., BF-BOF vs EAF steel)
- Map precursors and their emissions
EU importer coordination
- Bilingual liaison between your plant and the EU buyer
- Data in the format the importer needs for its declaration
- Evidence trail for any carbon price paid
Lower-carbon roadmap
- Identify where real emissions intensity can fall: efficiency, fuel, scrap-based routes, cleaner electricity
- Product-mix review for EU-bound goods
- No promised savings — results depend on your data
Our role
Sources: Regulation (EU) 2023/956 · European Commission — CBAM. This page summarizes the public EU framework for general information and is not legal advice.
FAQ
Who has to file the CBAM declaration?
Mainly the EU importer or its indirect customs representative, acting as an authorised CBAM declarant. Non-EU exporters usually do not file, but their EU buyers need their plant-level emissions data.
When is the first payment due?
The first annual CBAM declaration and certificate surrender for goods imported in 2026 is due by 30 September 2027. Certificate sales begin on 1 February 2027.
Why do actual emissions data matter?
Default values are conservative. Verified actual data that reflects your real production usually avoids overpaying compared with defaults, which can make your goods more competitive for EU buyers.
Can a carbon price paid in China be deducted?
Only if and to the extent it is recognised under CBAM rules and properly evidenced. We help document what has been paid; recognition is decided under EU rules.
Do you sell CBAM certificates or guarantee savings?
No. Certificates are bought by authorised declarants through the EU system. We provide data preparation and coordination support and do not promise a specific saving.
Talk to us — free 30-minute consultation
Tell us where you are stuck: hiring, field visibility, filings, website, or trade shows. English or Chinese.