Exporters

A checklist for producers outside the EU

Registering installations, monitoring emissions, verification and sharing data with EU customers — in the order that matters.

CBAM obligations fall on EU importers, but the information they need sits with producers outside the EU. A producer that can hand its customers verified emissions data is cheaper to buy from than one that leaves them with default values — across the atlas, the difference adds up to billions of euros a year (€14.4 bn in the 2026 default-value scenario).

1. Know which of your products are CBAM goods

Check your CN codes against Annex I of the CBAM Regulation: cement, iron and steel (including pellets and many articles of chapter 73), aluminium, fertilisers, hydrogen and electricity. A proposal to add around 180 downstream steel and aluminium products from 2028 is under negotiation.

2. Monitor emissions the CBAM way

Embedded emissions must be calculated with the methodology in Implementing Regulation (EU) 2025/2547: system boundaries per production process, direct emissions, indirect emissions where they count (cement, fertilisers), and the emissions of precursors. Existing ISO or national reporting is a starting point, not a substitute.

3. Register your installation

Operators of installations outside the EU can register in the CBAM Registry’s operator portal, describe their installations and production processes, and decide which information is visible to whom. Registration lets EU declarants find your verified data.

4. Get verified

Actual emissions used in a CBAM declaration must be verified by a verifier accredited under CBAM, normally including a site visit. Accreditation is granted by national accreditation bodies in the EU. Verification reports for 2026 production can be issued from 2027, in time for the first declarations due on 30 September 2027.

5. Share data with each customer

Share the verified embedded emissions per product and the supporting reports with your EU customers through the registry, and include the obligation in contracts. Customers will ask for it per consignment or per year; be consistent.

6. Document any carbon price paid

If you pay a carbon tax or buy allowances at home, keep evidence of the amount paid for the emissions in the goods, net of rebates. Your customer may be able to deduct it — see carbon prices abroad.

Start with the products that carry the biggest gap between your country’s default value and your real emissions.

Find your country’s figures in the country list, and see why default values are expensive.

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