Ask about CBAM
Plain questions, answered from the regulation with the instrument named. Where there is no checked answer, it says so rather than producing one.
That last part is the design. This is the page where a confident invented answer would be handed to somebody about to make a compliance decision, so it will not guess.
Everything it has a checked answer for
20 questions. Each answer was verified against its source on 16 September 2026.
Do I have to pay CBAM as an Indian exporter?
No. CBAM is charged to the authorised declarant, who is the importer in the EU. You do not file a declaration and you do not surrender certificates.
What reaches you is commercial rather than legal. The certificates your buyer surrenders are priced on your emissions, and where you cannot supply verified figures they must use the Commission's default value with a mark-up on top. That difference is priced into what your goods are worth against a competitor who can supply figures.
Is there a minimum below which CBAM does not apply?
Yes. An importer bringing in less than 50 tonnes of covered goods in a year has no CBAM obligation at all.
Two cautions. It is assessed per importer per year across every covered good they buy from everyone, not per shipment and not per supplier, so an importer buying from several suppliers can cross it without any one of them knowing. And if you sell to more than one EU customer it is assessed for each of them separately.
When is the first CBAM declaration due?
The first annual declaration, covering everything imported into the EU during 2026, is due on 30 September 2027. That date was moved from the original 31 May 2027.
Your own timetable is earlier. Certificate sales open on 1 February 2027, and from 2027 importers must hold certificates covering at least half their year to date emissions at the end of each quarter. A buyer who does not have your figures by then will be buying against default values.
Which products are covered by CBAM?
Six sectors: iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. Coverage is defined by CN code in Annex I to the CBAM regulation, not by sector name, so whether a particular product is caught depends on its code.
The Commission publishes default values against 283 codes. The calculator on this site searches all of them, so the reliable way to answer this for your own product is to look up its CN code there.
What is the mark-up on default values?
Where embedded emissions are determined with default values rather than verified actual values, a mark-up is added. For iron and steel, aluminium, cement and hydrogen it is 10 per cent in 2026, 20 per cent in 2027 and 30 per cent from 2028. For fertilisers it is a flat 1 per cent.
The mark-up exists to make default values the worse option, and it is the concrete financial reason to get actual data verified early rather than late.
Are emissions measured per tonne of product?
Not always, and this is the mistake that most often produces a wrong number. The general rule is tonnes of the good, but cement is measured per tonne of clinker contained, several nitrogen fertilisers per kilogram of nitrogen contained, other fertilisers by their supplementary unit, and electricity per kWh.
A cement producer who divides by tonnes of cement instead of tonnes of clinker gets a figure that is wrong and looks entirely plausible. The regulation supplies conversion equations for goods sold in varying composition.
What are precursors and do I have to include them?
A precursor is any input to your process that is itself on the CBAM goods list, such as pig iron going into crude steel or clinker into cement. Their embedded emissions are added to yours, and omitting one is the documented common way declarants understate their emissions.
Two details matter. You count the total mass consumed, including anything that never reached the finished goods, so offcuts, scrap and spillage are in. And a precursor originating in the EU, Iceland, Liechtenstein, Norway or Switzerland counts as zero, because it already carries an ETS price.
You need the specific embedded emissions of each precursor from whoever produced it. That usually has to be requested from a supplier, and it is the item that takes longest to arrive.
Do my electricity emissions count?
For some goods and not others. Indirect emissions from electricity are in scope where the Commission publishes an indirect default value, which today means cement, fertilisers and agglomerated iron ore. For other iron and steel, aluminium and hydrogen, emissions are reported on a direct basis.
Where they are in scope, the emission factor is not yours to choose. It is taken from the Commission's published value for your country grid, with narrow exceptions.
Can I use the CEA grid emission factor?
Not directly in a CBAM calculation. The regulation takes the electricity emission factor from the Commission's published value for the country of origin grid.
There are two exceptions and neither is available to an exporter acting alone. A third country can ask the Commission to lower the published value by demonstrating, by 30 June, that the five year average intensity of its grid is lower, which is a government submission. And actual factors can be used only where a direct technical link or power purchase criteria are met, meaning a captive plant or dedicated line rather than grid supply.
How do I find a CBAM verifier?
You cannot yet. No verifier anywhere in the EU held CBAM accreditation when this was last checked, against 24 national accreditation bodies that have agreed to offer it.
Verification has to be done by a verifier accredited by a national accreditation body in an EU or EEA country. That does not mean the verifier must be European: several of those bodies accept applications from bodies established in third countries.
Anyone offering you completed CBAM verification today is offering something that cannot yet be granted. Preparation and gap analysis are real and worth buying. A verification statement is not.
Does my BEE or CCTS reporting cover CBAM?
No. They measure different things. CCTS measures greenhouse gas emission intensity at entity level against a notified Indian target. CBAM measures absolute embedded emissions in specific goods, per production process, on a functional unit the EU regulation sets.
A good deal does carry across: fuel and energy records, production quantities, measurement infrastructure, and the experience of external verification. What does not is the boundary, the denominator, precursors, and the verifier, since BEE accreditation does not make somebody a CBAM verifier.
What data do I actually need to collect?
A monitoring plan, production quantities by CN code in the correct functional unit, fuel and process emission records with their calculation factors, electricity consumption where indirect emissions are in scope, the total mass and embedded emissions of every precursor, and the supporting records behind all of it.
It has to cover a full calendar year, and it is per installation and per production process rather than per company.
Where do the default values come from?
The Commission publishes them by CN code and country of origin, as a workbook attached to its own guidance page. Annexes I and IV of the original act were replaced in full by a correcting act in July 2026, retroactive to 1 January 2026, so a calculation made earlier in 2026 against the original annexes may need redoing.
Where no value is published for your good from your country, the highest value in Annex IV applies instead, which is usually considerably worse.
What does a CBAM certificate cost?
The Commission publishes a certificate price each quarter, derived from EU ETS allowance prices. It is the figure a declarant actually pays, and it is not the same as the EUA spot price.
The calculator on this site uses the current published quarterly price to turn a tonnage difference into money, and names the quarter it used.
Is there any reduction for EU free allocation?
Yes. The number of certificates actually surrendered is reduced to reflect free allocation still given under the EU ETS, using benchmarks set in a separate implementing regulation.
That calculation belongs to the declarant rather than to you, and the tools here do not attempt it. The Commission sets it out in its Guidance No. 4.
Can I deduct a carbon price already paid in India?
In principle a carbon price paid on the same emissions in the country of production can be deducted. In practice India has no carbon price on these sectors today, so for an Indian exporter there is nothing to deduct.
CCTS is an intensity target scheme with certificates traded against it, which is not the same thing as a price paid on the emissions embedded in a specific consignment. The rules for claiming a deduction are set by a separate implementing act.
Is this the same as the CBAM reporting I did before?
No, and most CBAM material still online describes the older transitional rules. The transitional phase was reporting only. The definitive period began on 1 January 2026, and from that date embedded emissions carry a certificate obligation.
The calculation methodology, the default values and the verification framework are all set by implementing acts adopted in December 2025, which did not exist during the transitional phase.
Do I report per company or per plant?
Per installation, and within it per production process. A company with three plants has three sets of figures, and a plant making several covered goods has to attribute emissions to each production process separately.
This is one of the larger differences from Indian domestic reporting, which works at designated entity level.
Is it only carbon dioxide that counts?
Not for every good. Nitric acid and mixed fertilisers carry nitrous oxide as well as carbon dioxide, so an inventory that measures only carbon dioxide understates them.
The greenhouse gas that applies to each aggregated goods category is set out in the regulation, alongside the CN code mapping.
Where should I start?
Ask your EU customer whether they cross the 50 tonne threshold. If they do not, there is nothing to prepare.
If they do, run the readiness check to see which records you already hold, then start requesting precursor emissions from your suppliers, because that is the item that depends on other people and takes longest.
The calculation itself is the easy part once the data exists.
Why this is not a chatbot
A language model asked which article sets the functional unit for cement will produce an article number whether or not it knows one, and it looks identical either way. On a page where the answer feeds a compliance decision, that is not a trade worth making.
Every answer above was read out of the regulation during the build and carries the instrument it came from. Where a question falls outside that, this says so and points at the Commission's own guidance, which is linked from the document checklist.
This is preparation guidance based on published EU rules, not legal or regulatory advice. Confirm requirements against the European Commission's official CBAM guidance or a qualified adviser before making a compliance decision. Preparation estimate. Not an official CBAM declaration or verification.