Indian exporters of steel, aluminium, cement and fertiliser now face a hard EU compliance deadline, and the system meant to help them meet it does not exist yet. The first CBAM declaration, covering 2026 imports, is due 30 September 2027. As of today, zero CBAM verifiers are accredited anywhere in the EU. This is what that gap actually costs, and what we built to work inside it.
- The deadline is fixed. The first CBAM declaration, covering everything imported into the EU during 2026, is due 30 September 2027.
- The verification system is not built yet. Zero CBAM verifiers are accredited anywhere in the EU, and India's request to have NABCB recognised is an open negotiation, not a settled outcome.
- Showing up unprepared has a price. Using the Commission's default emissions values instead of real verified data carries a mark-up of 10% in 2026, rising to 30% from 2028.
- CRBN.credit built a free preparation suite for exactly this gap, grounded in the definitive-period regulations themselves rather than in summaries of them.
- None of it verifies emissions or files anything. All of it is free, with no signup required.
The Problem, Stated Plainly
Starting 1 January 2026, the EU's Carbon Border Adjustment Mechanism entered its definitive phase. If you export steel, aluminium, cement, fertiliser, hydrogen or electricity to the EU, your buyer now has a real and growing financial exposure tied to the actual carbon emissions embedded in what you shipped them.
Here is the part most coverage of this glosses over: as of today, there is no functioning verification system for Indian exporters to use. Accredited CBAM verifiers, the only entities legally allowed to certify anyone's embedded emissions data for CBAM purposes, do not exist yet anywhere in the EU in meaningful numbers. India's own request to have its National Accreditation Board for Certification Bodies recognised by the EU is a live, unresolved policy negotiation, not a done deal.
So exporters are stuck in a real and uncomfortable gap: the deadline is real and fixed, the penalty for showing up unprepared is real and escalating, and the infrastructure to actually get verified is not fully built yet. Waiting for that infrastructure to arrive before doing anything is not a neutral choice. It is an expensive one.
The asymmetry is the point. The deadline does not move while the accreditation question is being settled. Every month spent waiting is a month not spent collecting the production and energy data that verification will require the moment it becomes available.
What the Penalty Actually Looks Like in Real Numbers
Abstract percentages do not land the way a real figure does, so here is one. It is clearly illustrative rather than exact, since the precise number depends on your specific CN code and your actual production data.
Take a 1,000 tonne steel shipment with embedded emissions toward the middle of the Commission's published default range for steel, which spans 0.34 to 8.58 tCO2e per tonne depending on the exact product. At roughly 2.0 tCO2e per tonne, that is 2,000 tonnes of embedded CO2e. At a CBAM certificate price of €75.28, that is a base exposure of about €150,560.
| Basis used | Mark-up applied | Cost of the same 1,000 t shipment |
|---|---|---|
| Verified actual data | None | Based on your real emissions, which may be well below the default |
| Commission default value, 2026 | 10% | Approximately €165,600 |
| Commission default value, 2027 | 20% | Approximately €180,700 |
| Commission default value, 2028 onward | 30% | Approximately €195,700 |
← Scroll table horizontally on mobile
That is not a rounding difference. That is tens of thousands of euros moving from year to year on the exact same shipment, purely because the underlying emissions figure was a Commission default instead of your own verified number.
The width of that default range is the real lesson. A product at the bottom of it and a product at the top of it are both "steel" in conversation and are nothing alike on an invoice. Looking up your own CN code is not a formality.
What CRBN.credit Built
One thing worth being direct about before going further. CRBN.credit itself is a global carbon market intelligence platform: live EU ETS and voluntary carbon market pricing, a projects database spanning more than 11,000 records across seven international registries, and analytical tools used by people well beyond any one country. The India CBAM Center is a deliberately narrower build inside that platform, purpose-made for Indian exporters specifically, not a rebrand of the whole thing. The rest of CRBN.credit serves anyone working in carbon markets, anywhere. This one section exists because India's specific situation, a hard EU deadline colliding with an accreditation system that is not finished yet, needed something built for it directly.
The embedded emissions calculator
This is the core of it. The embedded emissions calculator implements the actual definitive-period calculation methodology: Implementing Regulation (EU) 2025/2547 for the formula, and Implementing Regulation (EU) 2025/2621 as corrected by 2026/1740 for the default values. It covers direct emissions, precursor emissions and, where relevant, indirect emissions from electricity.
Walk through what a real session looks like. You select your product category and CN code, enter production quantity and your direct process emissions, then the tool asks specifically for precursor materials, meaning anything upstream that went into your product: pig iron into crude steel, clinker into cement. Leave that field empty and the tool blocks submission with an explicit warning rather than silently treating it as zero, because leaving out a precursor is documented as one of the most common ways declarants understate their real emissions. If you are in cement, fertiliser or agglomerated iron ore, it also asks for your electricity consumption, since those specific sectors currently carry an indirect emissions component.
The result shows your specific embedded emissions per tonne and, in one line, what using that real number instead of the Commission's default would actually save you, using the same kind of arithmetic shown above.
The India-specific advantage inside it
For the electricity-related calculation, the tool uses India's own official grid emission factor, published annually by the Central Electricity Authority, currently 0.71 tCO2e per MWh under Version 21.0 for FY 2024-25, instead of a generic assumption. That is a real and defensible number from India's own government, and no international CBAM tool bothers to source it, because building for India specifically was never their point.
The evidence pack generator and readiness checker
Neither of these computes anything new. They take whatever production, energy and emissions data an exporter already has and organise it into the structure a verifier will actually need, once verifiers exist, flagging exactly what is missing rather than guessing at it. The readiness checker specifically returns a percentage and a named list of gaps, along the lines of "82% ready, missing: process emission measurements, electricity allocation methodology", rather than a vague score with no actionable detail behind it. The evidence pack generator does the same job for the documents themselves.
The sector pages
Steel, aluminium, cement and fertiliser each get a dedicated page listing every Commission-published CN code relevant to that sector, its actual default emission value, and what that value implies in real cost terms. The steel page alone documents all 200 real CN codes covered. This is the part that took the most direct regulatory research, because it is the part that is actually useful to have on hand rather than looked up separately every time, and it is exactly the kind of specific, checkable reference material that tends to get cited rather than skimmed.
The PAT and CCTS bridge
This is the one page that could not exist without deep knowledge of India's own domestic climate policy. Many Indian exporters in these exact sectors are already Designated Consumers under India's Perform, Achieve, Trade scheme, now transitioning into the Carbon Credit Trading Scheme, and already report energy and emissions data to the Bureau of Energy Efficiency for a completely different purpose.
The PAT and CCTS bridge explains exactly what overlaps with CBAM's requirements and what does not. PAT and CCTS measure energy intensity against a domestic target; CBAM measures absolute embedded emissions against an EU default. The point is that existing reporting effort is not wasted, and gaps are not assumed away in either direction.
The countdown and the NABCB status page
The countdown is exactly what it sounds like, a running count to 30 September 2027, with the preparation steps that actually matter between now and then: identify affected products, identify installations, collect emissions data, calculate embedded emissions, prepare evidence, monitor verifier accreditation status.
The NABCB status page tracks India's accreditation request honestly, as an ongoing negotiation rather than a settled outcome in either direction, since the Commission's current framework requires CBAM verifiers to hold accreditation from an EU or EEA national accreditation body, and does not yet provide for NABCB itself to accredit verifiers for EU purposes.
What It Deliberately Does Not Do
None of this verifies anyone's emissions. None of it files a declaration. None of it claims to be, or to replace, an accredited verifier, because that accreditation does not exist yet for anyone serving this specific need.
Every single output across every tool in this section carries the same label: a preparation estimate, not an official declaration or verification. That distinction is not a legal formality tacked on at the end. It is the entire design principle behind the whole build. CRBN.credit prepares the evidence. An accredited verifier, once one exists, verifies it.
Why This Matters Beyond One Company's Product
The honest version of this story is that nobody, not CRBN.credit, not the Indian government, not the EU, has fully solved this problem yet. What exists right now is a real regulatory deadline, a real financial penalty for showing up unprepared, and a genuine gap in the infrastructure meant to bridge the two.
Free tools built directly from the actual regulation, rather than from a summary of a summary, are a real if partial answer to that gap, and they are built to be replaced by the real thing the moment accredited verification exists.
For the mechanism itself rather than the India-specific picture, see our explainer on what CBAM is and how the certificate price is set, and the guide to how the EU ETS works, which is the system CBAM's price is ultimately derived from.
Working out what CBAM actually costs your shipments?
The India CBAM Center is free, needs no signup, and runs on the published definitive-period regulations.
Sources and Further Reading
- Implementing Regulation (EU) 2025/2547, the calculation methodology for the definitive period
- Implementing Regulation (EU) 2025/2621, as corrected by 2026/1740, the published default values
- European Commission CBAM guidance, taxation-customs.ec.europa.eu
- Central Electricity Authority CO2 Baseline Database, cea.nic.in
- Bureau of Energy Efficiency, PAT and CCTS, beeindia.gov.in
Frequently Asked Questions
Is CRBN.credit an accredited CBAM verifier?
No. No CBAM verifiers are currently accredited anywhere in the EU. CRBN.credit prepares your data and evidence for that process; it does not perform verification itself.
Do I have to pay to use the India CBAM tools?
No. The calculator, evidence pack generator, readiness checker, sector pages, and every other tool in this section are free, with no signup required.
Is CRBN.credit only for Indian users?
No. CRBN.credit as a whole is a global carbon market platform: live pricing, an international projects database, and analytical tools used well beyond India. The India CBAM Center specifically is built only for this one situation, Indian exporters facing EU CBAM requirements. It is not the whole product.
Is my company definitely covered by CBAM?
It depends on your EU importer's total annual imports of CBAM-covered goods across all their suppliers, not on your shipment alone. A 50 tonne per year exemption threshold, introduced by a 2025 simplification, removes most smaller importers from full obligations, though hydrogen and electricity are excluded from that exemption regardless of volume.
If I already report to BEE under PAT or CCTS, do I already meet CBAM's requirements?
Not automatically. The two schemes measure different things. PAT and CCTS track energy intensity against a domestic target; CBAM tracks absolute embedded emissions against an EU default. Some of the underlying data overlaps meaningfully. The PAT and CCTS bridge page explains exactly what carries over and what does not.
When do I actually need to have this sorted out?
Certificate sales open 1 February 2027. The first full declaration, covering everything imported during 2026, is due 30 September 2027. Getting your data organised well before either date, rather than on the day itself, is what actually protects your competitiveness with your EU buyer.
A note on this article. CBAM rules and India's accreditation position are both actively evolving. Figures, default value ranges and thresholds above reflect the position as of publication, and the worked cost example is illustrative rather than an exact figure for any specific shipment. Nothing here is legal, tax or investment advice, and no tool described performs CBAM verification. Confirm current requirements against the European Commission's own CBAM guidance before making compliance decisions.