FAQ

Fee Timeline:

Cost Trigger Date: Starting January 1, 2026, any goods entering the EU customs after this date will incur CBAM carbon costs.

Actual Payment Date: In February 2027, the EU will begin selling CBAM certificates. Importers must pay the full carbon tax for all 2026 imports by September 30, 2027 — meaning the cost accrues on 2026 shipments, though payment occurs in 2027.

CBAM is determined by "goods arrival date" to the EU, not by contract signing date:

1. Projects executed last year and shipped this year: If goods arrive in the EU after January 1, 2026, CBAM applies — even if the contract was signed in 2024. As long as customs clearance occurs this year, compliance reporting and carbon cost liability are mandatory.

Note: If goods were produced in 2025, use 2025 emission data; if produced in 2026, use 2026 data. They cannot be mixed.

2. Projects signed now with next-year delivery: With delivery in 2027, the project falls fully within the formal levy period. CBAM carbon costs must be incorporated into pricing, otherwise you'll incur losses — with EU ETS carbon prices currently around €80/tonne, this cost must be reserved in advance.

Different CN codes must be separated: CBAM is managed per EU 8-digit CN code. For example, if your factory exports both cold-rolled steel sheets (7209.15) and galvanized sheets (7210.49), these are different CN codes and must be accounted and reported separately — they cannot be mixed together.

Same CN code, same factory — annual averages can be used: If the same factory produces the same CN code product throughout the year, regardless of how many batches are shipped to different customers, you don't need to calculate emissions for each batch separately — you can calculate an annual average emission intensity and distribute it across different customers, reducing your accounting workload.

Each shipment must be reported individually: Even for the same CN code and same factory, every batch shipped to the EU requires the customer to declare the quantity and corresponding emission data during customs clearance — annual production cannot be reported in one lump sum.

It is at the "individual shipment + corresponding CN code + production factory" granularity, not a factory-wide mixed report. Specific rules:

Different CN codes must be separated: CBAM is managed per EU 8-digit CN code. For example, if your factory exports both cold-rolled steel sheets and galvanized sheets, these are different CN codes and must be accounted and reported separately — they cannot be mixed together.

Same CN code, same factory — annual averages can be used: If the same factory produces the same CN code product throughout the year, regardless of how many batches are shipped to different customers, you don't need to calculate emissions for each batch separately — you can calculate an annual average emission intensity and distribute it across different customers, reducing your accounting workload.

Each shipment must be reported individually: Even for the same CN code and same factory, every batch shipped to the EU requires the customer to declare the quantity and corresponding emission data during customs clearance — annual production cannot be reported in one lump sum.

Formula: CBAM Payable = (Product Actual Embedded Emission Intensity - EU Benchmark) × Goods Quantity × EU ETS Weekly Average Carbon Price - Domestic Carbon Cost Already Paid

Three core data categories required:

1. Direct Emissions Data: Fuel combustion emissions from your factory's production process (e.g., coal or natural gas consumption × corresponding emission factor), plus process emissions (e.g., cement calcination, aluminum electrolysis) — must be supported by fuel purchase invoices and production metering records.

2. Indirect Emissions Data: How much purchased electricity/steam was used for production, multiplied by the corresponding grid emission factor — if you use self-generated and self-consumed green electricity, emissions for that portion can be counted as 0.

3. Upstream Precursor Emissions Data: If your product uses CBAM-regulated raw materials (e.g., aluminum ingots for aluminum profiles, crude steel for screws), you must obtain precursor emission data from upstream suppliers — effectively adding upstream carbon to your product's footprint. Without this data, the EU will apply the highest default values, significantly increasing your costs.