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Your EU customer asked for CBAM data. What now?
If you send no data, your customer must use the EU default value for your country plus a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 — for hot-rolled steel from Türkiye that is 2.671 instead of 2.428 tonnes of CO₂e per tonne. The legal obligation is the importer's, and importers bringing in under 50 tonnes of CBAM goods a year are exempt.
You received an email asking for "embedded emissions per tonne", probably with a deadline and a warning about extra costs. Nothing is on fire. Here is the short version.
1. Check that your goods are even covered
CBAM applies to specific CN codes, not to whole industries. Take the code from your export invoice. Iron and steel sit in chapters 72 and 73, aluminium in 76. If your code is not on the list, say so to your customer and stop here. There is also a small-volume exemption: an importer bringing in under 50 tonnes a year across all CBAM goods owes nothing.
2. Understand what happens if you do nothing
You are not legally obliged to send anything — the obligation sits with the EU importer. If you send nothing, they use a default value: a figure published per country and product, plus a mark-up of 10% in 2026, rising to 30% from 2028. That value is deliberately pessimistic. The importer pays it, and then asks you to share the cost or finds a supplier who answers.
See the default value for your country →
3. Work out what you actually emit
For one calendar year you need: how many tonnes of each product you made, how much fuel you burned making them, any carbonates or electrodes consumed, and how much steel or aluminium you bought in. That last item usually dominates the result for a fabricator.
The formula the EU uses is plain arithmetic: your own direct emissions plus the emissions embedded in the material you bought, divided by the tonnes you produced.
4. Send it in the format they expect
Use the Commission's Communication Template. It is the file their reporting system is built around, and sending a PDF of your own design creates work for them and delay for you.
5. Know the limit of what you just sent
From 2026, actual values can only be used once they have been checked by an accredited verifier. Your first file is a verification-ready draft, not a verified figure — say so plainly to your customer. It is normal, and it is better than a default value with a mark-up on top.
A shortcut for steel and aluminium
This site calculates the number and fills the official template for you, with no account. Comparing with the default is free; the exact figures and the filled files come with a paid plan. Your production figures stay in your browser. It also produces a one-page report showing your customer how much your real data saves them — which tends to change the tone of the conversation.
Questions exporters ask
Is a non-EU producer legally required to report CBAM data?
No — the legal obligation sits with the EU importer, but without your data the importer must use a default value plus a mark-up, so most customers will insist on receiving it.
In practice the request arrives as a commercial condition: send actual emissions data or share the extra cost of the default value.
Source: Regulation (EU) 2023/956, Articles 4 and 6
What happens if I don't send emissions data to my EU customer?
Your customer must then use the Commission's default value for your country and product, plus a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028.
Default values are set deliberately high. The difference between the default and your real figure is money your customer pays for CBAM certificates.
Source: Implementing Regulation (EU) 2025/2621, Annex I
Does my CBAM data need to be verified?
Yes — from 2026 actual emission values can only be used by the importer once they have been verified by an accredited verifier; until then, describe your figures as verification-ready, not verified.
A first calculated file is still useful: it shows your customer the likely saving and is the input the verifier checks.
Source: Regulation (EU) 2023/956, Article 8; Commission Guidance No. 3, p. 50
Is the CBAM Communication Template mandatory?
No — the importer needs the numbers, not a particular format, but almost every EU importer asks for the Commission's Communication Template because their own reporting is built around it.
Sending your own PDF usually creates extra work and delay on the importer's side.
Source: European Commission, CBAM Communication Template for Installations
Are small EU importers exempt from CBAM?
Yes — an importer bringing in less than 50 tonnes of CBAM goods a year in total is exempt, so a buyer below that threshold may not need your data at all.
The threshold counts all CBAM goods the importer brings in during the year, not a single shipment.
Source: Regulation (EU) 2023/956, Article 2a (as amended in 2025)
Last updated 2026-10-05.
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