CBAM country exposure splits into two distinct groups: 15 non-EU exporters that face rising compliance costs on goods shipped to the EU, and 7 EU member states whose importers hold the direct legal obligation under Regulation (EU) 2023/956. Understanding which group applies to your country determines whether your concern is carbon pricing credit, sector exposure, or National Competent Authority (NCA) registration. This guide maps all 22 countries covered on this site, with links to each country's dedicated page for sector-level detail, Article 9 eligibility, and cost estimates at the current EU ETS price of approximately €70 per tonne CO₂ (as of late March 2026).
Caption: CBAM applies to goods entering the EU from all non-EU countries, with exposure concentrated in steel, cement, aluminium, fertilizers, electricity, and hydrogen.
What CBAM Means Differently for Each Country Type
CBAM (Carbon Border Adjustment Mechanism) is the EU regulatory system, established by Regulation (EU) 2023/956, that requires EU importers of carbon-intensive goods to purchase certificates proportional to the embedded CO₂ emissions of those imports, priced at the EU ETS level, in order to prevent carbon leakage. The mechanism entered its definitive phase on January 1, 2026. The obligation sits with the EU importer, not the exporting country's manufacturers. However, the commercial pressure on exporters is real: EU buyers pass costs back through pricing negotiations, contract renegotiation, or supplier switching.
The first mandatory step for understanding CBAM's regulatory framework is recognizing that the six covered sectors (iron and steel, cement, aluminium, fertilizers, electricity, and hydrogen) do not affect all countries equally. Turkey ships approximately 6 million tonnes of steel per year to the EU, while Taiwan's exposure concentrates in a single efficient producer. Country-level analysis begins with the sector composition of each country's EU exports.
CBAM Exposure for Non-EU Exporting Countries
The 15 non-EU exporting countries covered on this site face two financially distinct variables: the gross CBAM cost based on their sector's embedded emissions, and the Article 9 deduction available to importers if the exporting country operates a qualifying carbon pricing scheme. South Korea, with its K-ETS active since 2015, is the best-positioned major exporter for a potential Article 9 offset. Turkey, with no national carbon pricing as of April 2026, faces the full gross cost on steel exports worth an estimated €6 to 8 billion per year to the EU.
The table below summarizes the 15 non-EU exporting countries by primary sector, Article 9 eligibility, and carbon pricing status. Each row links to a full country page with cost modeling, sector detail, and strategic options.
| Country | Primary CBAM Sector | Article 9 Status | Carbon Pricing Scheme |
|---|---|---|---|
| Turkey | Steel (BF-BOF and EAF mixed) | Not eligible | No national carbon pricing (ETS in development) |
| India | Steel, aluminium, fertilizers | Not eligible | CCTS (pilot phase; not qualifying) |
| China | Steel, aluminium | Not eligible | National ETS (electricity sector only; steel not covered) |
| Russia | Steel, aluminium, fertilizers | Not eligible | Token levy; not qualifying |
| Ukraine | Steel | Special status (EU accession candidate) | ETS in development |
| South Korea | Steel, aluminium | Likely eligible (K-ETS; Commission assessment pending) | K-ETS active since 2015 |
| USA | Steel, aluminium | Not eligible | No federal carbon price |
| Brazil | Steel, aluminium | Potential (if national market meets criteria by 2027) | National carbon market (legislation passed 2024) |
| South Africa | Steel, aluminium, fertilizers | Potentially eligible (Carbon Tax pending assessment) | Carbon Tax Act (2019; rate increasing annually) |
| Morocco | Cement, steel, electricity | Not eligible | No carbon pricing scheme |
| Egypt | Cement, fertilizers, steel | Not eligible | No carbon pricing scheme |
| Vietnam | Steel, aluminium | Not eligible | Domestic market in development (target 2025–2028) |
| Indonesia | Aluminium, steel | Not eligible | Carbon market (voluntary phase since 2023) |
| Taiwan | Steel | Not eligible | Carbon fee system (launched 2024; not yet assessed) |
| Japan | Steel, aluminium | Not yet (GX-ETS not mature enough) | GX-ETS (launched 2023; transitional) |
The de minimis threshold of 50 tonnes annual mass exempts approximately 90% of EU importing companies by count, but those exempt importers represent only about 1% of total CBAM-affected import volume. For large-volume exporters, this threshold provides no practical relief.
Caption: Article 9 deduction eligibility depends on whether the exporting country's carbon pricing scheme is assessed as equivalent by the European Commission.
CBAM Obligations for EU Member State Importers
EU importers in the 7 member states covered on this site hold the full legal and financial obligation under CBAM. The obligation chain requires authorization as an authorized declarant, reporting embedded emissions for all CBAM goods imported above the 50-tonne threshold, and surrendering CBAM certificates by September 30, 2027 (covering calendar year 2026). Each member state designates a National Competent Authority (NCA) to process authorizations, manage the national registry, and enforce compliance.
The authorization application deadline passed on March 31, 2026. Importers who applied before that date can continue importing provisionally while their application is assessed. Importers who missed the deadline face the unauthorized importing penalty of €300 to 500 per tonne CO₂e, compared to the standard €100 per tonne for authorized declarants who fail to surrender certificates.
The 7 EU member state pages covered on this site are listed below with their respective NCAs.
- Germany — DEHSt (Deutsche Emissionshandelsstelle), Federal Environment Agency
- France — DGEC (Direction Générale de l'Énergie et du Climat)
- Netherlands — NEa (Nederlandse Emissieautoriteit)
- Italy — ISPRA (Comitato nazionale, Ministry of Environment)
- Spain — OECC (Oficina Española de Cambio Climático)
- Poland — KOBiZE (National Centre for Emissions Management)
- Belgium — SPF Santé publique, Climate Change Service
For the full importer compliance obligation chain, including authorization steps, reporting requirements, and certificate surrender mechanics, see the EU importer compliance guide.
How to Use the Country Pages on This Site
Country pages are structured around the variables that differ between countries, not the variables that are identical across all CBAM cases. The regulation's text, the six covered sectors, and the certificate surrender deadlines are constant. What varies is each country's sector composition of EU exports, the Article 9 eligibility status of its carbon pricing system, the gross and net cost estimates at current ETS prices, and (for EU members) the NCA contact details and national enforcement approach.
The five questions each country page answers are listed below.
- Which CBAM sectors does this country export to the EU, and at what volume?
- What is the gross CBAM cost per tonne of product at the current EU ETS price (~€70/tCO₂)?
- Does the country operate a qualifying carbon pricing scheme enabling an Article 9 deduction?
- What is the government's regulatory and WTO response to CBAM?
- What strategic options exist for exporters or importers from this country?
What Determines Article 9 Deduction Eligibility?
Article 9 of Regulation (EU) 2023/956 permits EU importers to deduct a carbon price effectively paid in the country of production from their CBAM certificate obligation. The deduction applies at the installation level, not the national level. A qualifying carbon price must be legally binding, actually enforced, and set at a price high enough to be material relative to the EU ETS. The European Commission assesses each third-country scheme individually. No country has received formal Commission confirmation of a qualifying Article 9 deduction as of April 2026, though South Korea's K-ETS is the most advanced candidate.
For non-EU exporters seeking to understand the full scope of non-EU exporter compliance obligations, Article 9 eligibility represents the single most valuable commercial variable to monitor through 2027 when real certificate costs begin flowing.
Frequently Asked Questions
Which country has the highest CBAM exposure?
Turkey has the highest commercial CBAM exposure of any single non-EU country. Turkey exports approximately 6 million tonnes of steel per year to the EU, with an estimated export value of €6 to 8 billion annually across steel and aluminium. With no qualifying national carbon pricing scheme as of April 2026, Turkish exporters face the full gross CBAM cost with no Article 9 offset. At the current EU ETS price of approximately €70 per tonne CO₂ and a blended emission factor of around 1.2 tCO₂ per tonne of steel, the gross cost reaches approximately €84 per tonne before the 2026 free allocation adjustment.
Does CBAM apply to all countries equally?
CBAM applies uniformly to all non-EU countries as a mechanism, but the financial impact differs substantially by country based on 3 variables: the carbon intensity of the country's production methods, the sector composition of EU-bound exports, and whether the country operates a carbon pricing scheme that qualifies for an Article 9 deduction. Countries with cleaner production methods and active carbon pricing (such as South Korea) face materially lower net CBAM costs than countries using high-carbon processes with no qualifying carbon price (such as India or Egypt).
Is CBAM a country-level or installation-level obligation?
CBAM operates at the installation level for emissions reporting purposes, but the legal obligation sits with the EU importer at the declarant level. The embedded emissions of each imported good are traced to the specific production installation where the goods were manufactured. Two exporters in the same country can face different CBAM costs if their production methods and emission factors differ. The country-level figures cited in this guide and its sub-pages represent industry averages, not obligations imposed on individual producers.