CBAM · Exporters to the EU
CBAM readiness for exporters to the EU
The carbon border adjustment mechanism now applies in full. We help exporters of steel, aluminium, cement and fertilisers get their emissions data, evidence and customer conversations ready before the first declaration, due on 30 September 2027.
Who this is for
- Producers and exporters of cement, iron and steel, aluminium and fertilisers who sell to the EU.
- Suppliers whose EU customers have asked for emissions data, a monitoring plan or a verifier.
- Companies that are not sure whether their products, or their customers, are covered.
Why it matters to you, even though your customer pays
The legal obligation sits with your EU importer, but your emissions decide their bill. An importer that cannot get reliable data from you has to declare on default values. The Commission sets those with a mark-up, so that emissions are not underestimated, and the mark-up rises over the years. The Commission says it should in most cases be more advantageous to use actual values where they are available.
Actual values must be verified by an independent accredited verifier, at the level of the installation. That takes records, a method and time, so the work has to start well before the first annual declaration on 30 September 2027.
How we work
1
Map
We match your products to their customs (CN) codes, find which are covered, and ask each EU customer how it plans to declare them.
2
Set the boundaries
We identify the installations that make the goods, the production routes, and what has to be measured.
3
Collect the data
We list the fuel, electricity and production records you need, including data from your input suppliers, and show you the gaps.
4
Write the method
We draft a monitoring plan and a calculation method that a verifier can review.
5
Prepare for verification
We organise your evidence for an independent accredited verifier and help you brief and compare verifiers.
6
Serve your customers
We prepare a clear data summary for each key EU customer and a timetable and owner inside your company, working back from the first declaration.
What you receive
- A map of your products to their customs codes, with those covered by CBAM marked.
- An inventory of your installations, the data you hold and the gaps.
- A draft monitoring plan and calculation method for a verifier to review.
- An evidence file organised for verification.
- A short summary for each key EU customer: what you can provide, in what form and by when.
- A timetable and a named owner, working back from 30 September 2027.
What we do not do
- We are not an accredited verifier and we do not verify emissions. Verification is done by an independent accredited verifier, which we help you prepare for.
- We do not act as your customs representative or CBAM declarant, and we do not give customs, legal or tax advice.
- We do not promise a particular emissions figure, cost or customer decision.
Common questions
Does CBAM apply to us if we are not in the EU?
The legal obligation sits with the EU importer, known as the authorised CBAM declarant. But the embedded emissions of your goods set the importer’s bill, so your customers will ask you for data.
Is there a minimum quantity?
There is an exemption for importers that bring in no more than 50 tonnes a year of covered goods, counted per importer across all its suppliers. Above it, every tonne imported that year is covered, not only the excess. A small order from you does not make your customer exempt.
Do we need verified data?
Importers may declare on default values or on the actual emissions of the installation. Actual data has to be verified by an independent accredited verifier. Without it, your customers will declare on default values.
What will the certificates cost?
It is not a flat rate per tonne. It depends on the embedded emissions, the free allocation that is deducted and any carbon price paid in your country, multiplied by the certificate price, which follows the EU emissions trading system. Our guide on the certificate cost explains the formula.
What are the deadlines?
Certificates for 2026 imports are sold from 1 February 2027. The first annual CBAM declaration, for 2026 imports, is due by 30 September 2027.
Read next
Start with the free CBAM Compass Report
In about three minutes you see how ready your installation is and the cost per tonne your buyers may face on default values.
Sources
Facts last checked against these sources on 25 October 2026.