EU CBAM creates a direct commercial threat for non-EU exporters even though the legal obligation falls entirely on EU importers. Under Regulation (EU) 2023/956, EU buyers of carbon-intensive goods must purchase certificates priced at the EU ETS carbon price (approximately €70 per tonne CO₂ as of late March 2026) to cover the embedded emissions of their imports. Exporters who cannot provide verified emission data force their EU customers to use punitive default values, which carry a 10% mark-up in 2026 rising to 30% from 2028 onward. That extra cost does not disappear: it becomes a price negotiation, a supplier switch, or a lost contract.
Five strategic options exist for non-EU exporters facing EU CBAM: provide verified actual emission data, invest in decarbonization, qualify for an Article 9 carbon price deduction, accept default values and absorb the commercial consequence, or redirect exports to non-CBAM markets. This article covers what CBAM means for your production installation, what data your EU buyers need from you, how to use the CBAM Operators Portal, and which countries face the highest commercial exposure.
Caption: Under EU CBAM, the certificate obligation sits with the EU importer, but the commercial cost pressure flows back to the non-EU exporter through price negotiations.
What EU CBAM Means for Non-EU Exporters
EU CBAM does not create a direct legal obligation for non-EU exporters, but it creates an immediate commercial obligation to provide verified embedded emissions data or lose competitive ground against suppliers who do.
The mechanism works as follows. EU importers of goods in the six CBAM sectors (iron and steel, cement, aluminium, fertilizers, electricity, and hydrogen) must purchase and surrender CBAM certificates equal to the embedded CO₂ equivalent emissions of their imports. The certificate price tracks the EU ETS auction price, which stood at approximately €70 per tonne CO₂ equivalent in late March 2026. When your EU buyer holds verified specific embedded emissions data for your production installation, they calculate their certificate obligation using that actual figure. When they do not hold verified data, they are required to use default values published under Implementing Regulation (EU) 2025/2621.
Default values are not neutral estimates. They are intentionally set above average actual emissions to incentivize measurement. The default for a Chinese steel slab, for example, is 3.167 tCO₂e per tonne, while typical actual emissions from Chinese blast furnace producers run between 1.8 and 2.1 tCO₂e per tonne. The gap translates directly into overpaid certificates that your EU buyer will price back into your contract.
The financial stakes for the full EU CBAM compliance cycle require understanding the broader regulatory context. The EU CBAM guide covers the complete regulatory framework, from how certificates are priced to when declarations fall due under the Omnibus amendments.
What Data Your EU Importers Need From You
Four categories of installation-level data are required from non-EU producers under the CBAM methodology established in Implementing Regulation (EU) 2025/2547.
Installation Identification Data
EU importers must declare the specific production installation where CBAM goods were produced, not just the exporting company. The installation identification data your EU buyer needs from you includes the following elements.
The required installation identification fields are listed below.
- Full legal name of the production company and physical address of the installation
- UN/LOCODE of the installation (the standardized international location code)
- Geographical coordinates (latitude and longitude) to the nearest degree
- For steel products: the steel mill identification number assigned by the Commission
- Contact person designated for CBAM data queries at your installation
Specific Embedded Emissions Data
Specific embedded emissions are the tonnes of CO₂ equivalent per tonne of goods produced, calculated at the installation level using the full EU methodology. From 2025 onward, only two approved calculation methods are accepted: the calculation-based method (Equation 11 of IR 2025/2547, using activity data multiplied by emission factors from laboratory analyses) and the mass balance method (Equation 12, tracking carbon inputs minus carbon outputs through the production process). Alternative methods based on third-country data that were permitted during the 2023 to 2025 transitional period are no longer valid.
The scope of emissions covered depends on your sector. The table below summarizes what your EU buyers need from each sector.
| Sector | Direct Emissions Required | Indirect Emissions Required | GHGs Covered |
|---|---|---|---|
| Iron and steel | Yes | No | CO₂ |
| Cement | Yes | Yes | CO₂ |
| Aluminium | Yes | No | CO₂ + PFCs (CF₄, C₂F₆) |
| Fertilizers | Yes | Yes | CO₂ + N₂O |
| Electricity | Yes | N/A | CO₂ |
| Hydrogen | Yes | No | CO₂ |
For cement and fertilizer producers, indirect embedded emissions from electricity consumed during production must also be provided. This requires disclosing your electricity consumption per tonne of product and the emission factor of your grid or specific power source.
Carbon Price Documentation (For Article 9 Deduction)
If your country operates a carbon pricing scheme, such as an emissions trading system or carbon tax, and you paid a carbon price on the embedded emissions of your exported goods, your EU buyer can apply an Article 9 deduction that reduces their CBAM certificate obligation. You must provide documentation showing the amount paid per tonne CO₂ equivalent (net of any free allocations, rebates, or state compensation), the name and legal basis of the scheme, and evidence of actual payment such as an invoice, registry record, or tax assessment.
Voluntary carbon offsets, internal corporate carbon prices, and government energy subsidies do not qualify. The carbon price must be legally binding and effectively enforced to meet the Article 9 eligibility threshold under Article 3(25) of Regulation (EU) 2023/956.
Precursor Emissions Data
Where your exported goods are complex goods (produced using other CBAM-listed goods as inputs), the embedded emissions of each precursor must be reported separately. A cement producer exporting Portland cement must provide the embedded emissions of the clinker used in production. A fertilizer producer exporting urea must provide the embedded emissions of the ammonia upstream. If the precursor comes from a different installation, that installation's data must also be obtained, verified, and passed to the EU importer.
Understanding exactly what specific embedded emissions means in practice, and how they are calculated per sector, is covered in full detail in the guide to CBAM embedded emissions.
The CBAM Operators Portal: How Exporters Submit Their Data
The CBAM Operators Portal is the European Commission's dedicated platform for non-EU production installation operators to upload verified emissions data and share it directly with their EU buyers.
What the Portal Does
The CBAM Operators Portal serves three functions for non-EU exporters. First, it stores installation-level emissions data in a structured format that matches the fields required in CBAM declarations. Second, it allows you to share that stored data selectively with specific authorized CBAM declarants (your EU buyers) or to grant open access to all EU declarants who import from your installation. Third, it provides the official Communication Template, an Excel-based matrix that maps your installation's energy flows, production data, and emission calculations to the exact required CBAM fields.
One data upload serves all of your EU importer relationships simultaneously. You upload your installation data once, the verifier attaches their verification report, and every EU buyer importing from your installation can access it. This is more efficient than providing data per-shipment or per-buyer relationship.
What the Portal Does Not Do
The CBAM Operators Portal does not replace the need for third-party verification. Data uploaded to the portal must be verified by an accredited verifier to be accepted by EU importers as specific (actual) embedded emissions data. For the first verification period covering 2026 imports, physical site visits to the production installation are mandatory. The verifier must attend your facility, observe production processes, review measurement instruments, and sample data records before issuing a verification report.
Verifiers must be accredited under EN ISO/IEC 14065 by a national accreditation body that holds a mutual recognition agreement with European Accreditation. Producers in India, China, Turkey, and South Korea can engage local verifiers accredited through this route rather than importing European verifiers at significantly higher cost.
Full guidance on how to register your installation, use the Communication Template, and select a verifier is available in the dedicated guide to the CBAM operators portal.
The Financial Case for Providing Verified Data
The commercial incentive to provide verified data grows significantly from 2027 onward as free allocation to EU domestic producers phases out and the net CBAM cost on imports increases proportionally.
In 2026, the CBAM factor (the proportion of embedded emissions for which certificates must be purchased) is only 2.5%. Net CBAM costs in 2026 are therefore small: blast furnace steel at €70 per tonne CO₂ costs €140 per tonne gross, but only €3.50 per tonne net after the 97.5% free allocation adjustment. Most exporters will barely feel CBAM financially in 2026. The real reckoning comes between 2028 and 2030 as the CBAM factor jumps from 10% to 48.5%.
By 2030, the same steel shipment carries a net CBAM cost of approximately €68 per tonne (€140 × 48.5%). At that point, the difference between actual emission intensity and the default value becomes existential for many producers. Exporters who cannot provide verified data face a growing price disadvantage against competitors who can. EU buyers accelerate their supplier switches as the financial stakes rise.
The cost difference between using defaults and providing verified data, calculated at the 2030 CBAM factor, is shown in the table below.
| Product | Country | Default (tCO₂e/t) | Typical Actual | Gap | Extra Cost @ €70 × 48.5% (2030) |
|---|---|---|---|---|---|
| Steel slab | China | 3.167 | ~2.0 | ~1.17 | ~€40/t |
| Portland cement | Turkey | ~1.584 | ~0.88 | ~0.70 | ~€24/t |
| Ammonia | Egypt | ~3.5 | ~2.0 | ~1.5 | ~€51/t |
| Primary aluminium | UAE | ~2.5 | ~1.75 | ~0.75 | ~€26/t |
For Turkish cement exporters, the €24 per tonne gap in 2030 often exceeds 30% of the FOB export price. Accepting default values beyond 2028 is not a passive choice: it is a decision to price your EU customers out of the relationship.
Understanding the full structure of default values, including how they are set by country and product, supports the commercial case covered in the article on CBAM default values for exporters.
Caption: Default value mark-ups under IR (EU) 2025/2621 make providing verified actual emission data increasingly urgent as the definitive phase advances toward 2030.
Five Strategic Options for CBAM Non-EU Exporters
Non-EU exporters have five strategic responses to EU CBAM, each with a different cost profile, timeline, and commercial risk. The five options are described below.
Option 1: Provide verified actual emission data. This is the primary short-term defense for exporters whose actual emissions are below the published default values. Verification fees for a single installation run between €5,000 and €50,000 per period depending on installation complexity and verifier location. The benefit is immediate: every tonne of verified emission data below the default avoids the mark-up cost and signals credibility to EU buyers. This option requires investment in continuous monitoring systems or enhanced data collection procedures, staff training, and a standing verifier relationship.
Option 2: Invest in decarbonization. Reducing the actual embedded emissions intensity of production addresses the root cause rather than the symptom. Blast furnace producers transitioning to electric arc furnace routes, cement producers increasing supplementary cementitious material ratios, and aluminium smelters switching to renewable electricity grids all reduce their CBAM exposure structurally. This option operates on a 3 to 10 year investment horizon but creates a durable competitive advantage as CBAM costs accelerate toward 2034.
Option 3: Qualify for the Article 9 carbon price deduction. If your home government operates a qualifying carbon pricing scheme, your EU buyers can deduct the carbon price you effectively paid from their CBAM certificate obligation. South Korea's K-ETS, which has operated since 2015 and covers approximately 70% of national emissions, is the scheme most likely to receive Commission recognition. South Africa's Carbon Tax (introduced June 2019 at approximately R159 per tonne, equivalent to about $9) is also under assessment. For exporters in countries with qualifying schemes, lobbying for the EU Commission's recognition of that scheme directly reduces your EU buyers' CBAM bill.
Option 4: Accept default values and absorb the commercial consequence. This option is viable only in 2026 and 2027, when the net CBAM cost is still small due to high free allocation. From 2028 onward, the 30% default mark-up combined with a rising CBAM factor creates a compounding disadvantage that makes this option commercially unsustainable for most exporters in volume EU markets.
Option 5: Redirect exports to non-CBAM markets. The UK CBAM starts in January 2027. Canada is developing a carbon border adjustment mechanism. The United States is debating the Foreign Pollution Fee Act in the 119th Congress. The window for market diversion to equivalent economies is narrowing. This option provides short-term relief for exporters with genuinely high emission intensity who cannot reduce emissions quickly enough to compete on verified data. It is not a durable strategy at the scale of most CBAM-exposed export volumes.
Which Countries Face the Highest CBAM Exposure
CBAM non-EU exporters face different levels of commercial pressure depending on their country's export volume to the EU, sectoral emission intensity, and availability of a qualifying carbon pricing scheme.
Turkey: The Most Commercially Exposed Country
Turkey faces approximately €19 billion in CBAM-affected exports to the EU, representing nearly 8% of Turkey's total export value. Turkey is the EU's largest supplier of cement (accounting for 35 to 39% of EU cement imports) and a major steel supplier at approximately 6 million tonnes per year. Turkey enacted its first Climate Law (No. 7552) on July 9, 2025, establishing the legal basis for a Turkish ETS. However, the pilot phase operating in 2026 carries full free allocation, meaning no effectively paid carbon price exists for Article 9 deduction purposes. Turkish cement producers face the largest gap between their actual emissions (approximately 0.88 tCO₂ per tonne) and the default value applied for their country (approximately 1.584 tCO₂e per tonne). That gap alone costs Turkish cement exporters approximately €83 per tonne in gross certificate terms at €70 ETS, before free allocation adjustment. A dedicated country analysis is available in the guide to CBAM Turkey.
India: Strongest Diplomatic Opposition, Growing Commercial Exposure
India accounts for approximately 6.6% of total CBAM-covered imports to the EU. Steel represents over 60% of India's CBAM exposure, with EU-bound Indian steel exports falling 24.4% in FY2024 to 25, partly in anticipation of CBAM costs. India's Carbon Credit Trading Scheme covers aluminium and cement in Phase 1 but excludes steel, and the scheme is intensity-based rather than absolute-cap, meaning it does not currently meet Article 9 qualification criteria. Major Indian steel producers, including Tata Steel, JSW Steel, and SAIL, are under pressure to build verification capacity and reduce emission intensity.
China: Largest Volume Exposure
China accounts for roughly 15% of total CBAM-covered imports to the EU by value, concentrated in steel and aluminium. China expanded its national ETS to cover steel, cement, and aluminium in March 2025, adding approximately 3 billion tonnes CO₂ and 1,500 entities. The current Chinese ETS price of approximately $11 per tonne CO₂ (approximately CNY 67 per tonne) would provide only limited Article 9 deduction relief even if the system qualifies, covering approximately 15% of CBAM liability relative to the EU ETS price. The default value for Chinese steel slab at 3.167 tCO₂e per tonne creates a strong incentive for Chinese producers with actual emissions below that threshold to provide verified data.
South Korea: Best-Positioned for Article 9
South Korea's K-ETS has operated since 2015, covers approximately 70% of national emissions, and entered Phase 4 in 2026. At a current price of approximately $6 to $7 per tonne CO₂, K-ETS would cover approximately 9% of CBAM liability if recognized. The Commission is assessing K-ETS for Article 9 qualification as of April 2026. South Korea is actively pursuing bilateral recognition, making it the country most likely to secure a partial deduction for producers such as POSCO and Hyundai Steel.
Caption: CBAM exposure by key exporting country, ranked by combination of export volume to EU and absence of qualifying carbon pricing scheme.
How CBAM for Exporters Relates to Importer Obligations
The exporter strategy described in this article operates within the broader importer compliance chain that runs from authorization through to annual declaration and certificate surrender.
What EU Importers Do With Your Data
EU importers who receive your verified emission data use it to calculate their specific certificate obligation: tonnes of goods imported, multiplied by specific embedded emissions per tonne, multiplied by the applicable CBAM factor, multiplied by the EU ETS certificate price. Exporters can use the CBAM cost calculator to model the certificate cost your EU buyers face at different ETS price levels and CBAM factor years. Where you have a qualifying carbon price, the importer applies an Article 9 deduction before calculating their net obligation. Where your data is unavailable, they apply the default value plus the punitive mark-up, then negotiate that extra cost into your contract price.
EU importers must hold CBAM certificates equal to at least 50% of their cumulative embedded emissions at the end of each calendar quarter, under the quarterly holding requirement established in Article 22(2) of Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083. Certificate purchases begin on February 1, 2027. The first annual CBAM declaration, covering calendar year 2026 imports, is due by September 30, 2027.
For the full picture of how your EU buyers manage their compliance obligations, the guide to CBAM for EU importers covers the authorization, registry, quarterly holding, and declaration process in detail.
Frequently Asked Questions: CBAM for Non-EU Exporters
Do non-EU exporters have a legal obligation under EU CBAM?
No. Non-EU exporters have no direct legal obligation under Regulation (EU) 2023/956. The financial and reporting obligation falls entirely on EU-established authorized CBAM declarants, the importers. However, exporters who cannot provide verified embedded emissions data create higher CBAM costs for their EU buyers, who pass those costs back through lower purchase prices or by switching to suppliers who can provide verified data.
What happens if an exporter does not provide any emissions data?
EU importers apply the Commission's default values with a punitive mark-up: 10% above the calculated default in 2026, 20% in 2027, and 30% from 2028 onward. For most producers in high-emission sectors, actual emissions are below the default, meaning defaults overstate the real CBAM obligation and cost the EU importer more than necessary. That extra cost becomes a commercial pressure on the exporter to supply data or accept a lower contract price.
Can exporters claim a deduction for carbon taxes paid in their home country?
Yes, exporters can support an Article 9 deduction if their home country operates a qualifying carbon pricing scheme. The carbon price must be legally binding and effectively enforced, and the amount effectively paid (net of free allocations and rebates) must be documented with payment evidence. Voluntary carbon offsets and internal corporate shadow prices do not qualify. South Korea's K-ETS is the most likely current scheme to receive EU recognition. Turkey, China (for its steel sector ETS), India, South Africa, and Brazil are all at various stages of development toward qualifying schemes.
Is the CBAM Operators Portal mandatory for exporters?
No. The CBAM Operators Portal is voluntary for non-EU installation operators. Exporters can also provide emission data directly to EU importers by other documented means. However, the portal provides a single-submission route that serves all EU buyer relationships simultaneously and integrates with the Commission's official Communication Template, reducing the administrative burden of managing multiple importer data requests.
Which CBAM sectors affect non-EU exporters?
Six sectors are covered by CBAM under Annex I of Regulation (EU) 2023/956: iron and steel, cement, aluminium, fertilizers (ammonia, nitric acid, urea, and mixed fertilizers), electricity, and hydrogen. Within each sector, CBAM applies only to goods classified under specific Combined Nomenclature (CN) codes. Exporters of goods in adjacent sectors, such as downstream steel products, processed aluminium goods, or organic fertilizers, are not subject to CBAM unless their specific CN code appears in Annex I.
When does CBAM financial exposure become significant for exporters?
The net CBAM cost in 2026 is minimal because the CBAM factor is only 2.5% (97.5% of EU ETS free allocation for domestic producers remains in place). At €70 per tonne CO₂ and a 2.5% factor, blast furnace steel costs approximately €3.50 per tonne net. The significant increase comes between 2028 and 2030, when the CBAM factor rises from 10% to 48.5%. Exporters who are not prepared with verified data, lower actual emissions, or an Article 9 deduction face a structurally uncompetitive cost position in their EU markets from 2028 onward. Planning for 2028 requirements needs to start in 2026.