CBAM Compliance for Exporters

Six sectors fall under CBAM today: iron and steel, aluminium, cement, fertilisers, hydrogen and electricity.

Non-EU operators of installations that export CBAM goods to the EU use the CBAM Communication Template to provide verified embedded emission data to their EU importers.

Since the definitive period started on 1 January 2026, actual emissions verified by an EU-accredited verifier are required for most installations. Default values from the transitional period are only allowed in narrowly defined fallback cases.

For complex goods, such as downstream steel or aluminium products, the embedded emissions of input materials (precursors) must be tracked back through the value chain, each with its own emission data or default value, and linked to the final good in the Communication Template.

A carbon price effectively paid in the country of origin, such as China ETS allowances or a national carbon tax, can be deducted from the CBAM certificate obligation, provided it is paid, documented and not refunded.

Direct emissions are Scope 1 emissions from the production process; indirect emissions are Scope 2 emissions from consumed electricity. Both are required for most CBAM goods.

The EU importer, or their indirect customs representative, is legally responsible for the CBAM filing. Non-EU exporters have no direct obligation under CBAM, but in practice most of the data collection burden falls on them because the importer needs production-level emission data only the supplier has.

Penalties for late, incomplete or inaccurate reports range from EUR 10 to 50 per tonne of undeclared embedded emissions, with falsified data risking fines up to three times the CBAM certificate price, which is why an EU importer will press its exporters for clean, timely data.