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CBAM questions from non-EU suppliers
The questions steel and aluminium producers ask after an EU customer requests CBAM data. Each answer starts with one sentence you can rely on, followed by the detail and the official source.
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Does CBAM apply to goods from your country?
Yes — CBAM applies to covered goods produced in any country outside the EU, including your country; the exceptions are Iceland, Liechtenstein, Norway, Switzerland and a few small territories listed in Annex III.
What matters is the CN code of the goods and where they were produced, not where the exporter is registered. The obligation to pay falls on the EU importer, which is why the request for data reaches you through your customer.
Source: Regulation (EU) 2023/956, Article 2 and Annex III
Which products does CBAM cover?
CBAM covers cement, iron and steel, aluminium, fertilisers, hydrogen and electricity, identified by CN code rather than by product name.
For metals, iron and steel sit mainly in CN chapters 72 and 73 and aluminium in chapter 76, from unwrought metal to finished items such as screws, tubes and structures. Check the code on your export invoice against Annex I of the Regulation.
Source: Regulation (EU) 2023/956, Annex I
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 with a penalty 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
How large is the mark-up on CBAM default values?
For iron, steel and aluminium the mark-up on the published default value is 10% in 2026, 20% in 2027 and 30% from 2028.
The mark-up exists to make real data more attractive than the default. It is applied on top of the base value shown for each CN code.
Source: Implementing Regulation (EU) 2025/2621
How is the CBAM emissions value per tonne calculated?
It is your installation's direct emissions attributed to the product, plus the emissions embedded in the CBAM materials you bought and consumed, divided by the tonnes of product you made.
The result is tonnes of CO₂e per tonne of goods for one calendar year. Scrap and returned product are excluded from output; offcuts and losses stay on the input side.
Source: Regulation (EU) 2023/956, Annex IV
Do electricity emissions count for steel and aluminium under CBAM?
No — in the definitive period only direct emissions count for iron, steel and aluminium; electricity is reported in the template but does not enter the product's value, with sintered ore as the single exception.
Electric arc furnace producers still count electrodes, natural gas and the carbon in scrap and alloys.
Source: Regulation (EU) 2023/956, Annex II; Commission Guidance No. 5d/5e, pp. 8–9
Does steel or aluminium I buy in count towards my CBAM figure?
Yes — purchased CBAM material such as rod, coil, billet or unwrought aluminium carries its producer's emissions into your product, and for fabricators it is usually most of the total.
Enter the tonnes consumed, not the tonnes that end up in the product: if 100 tonnes of rod go in and 80 tonnes of screws come out, the figure is 100.
Source: Commission Guidance No. 3, pp. 34, 68
Can I use an emission value my supplier gave me?
Only if it comes with a verification report from an accredited verifier covering the year the material was produced; otherwise the country default value for that material applies.
An email, a datasheet or an environmental product declaration is not enough on its own.
Source: Commission Guidance No. 3, pp. 110, 115
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
Which period of data do I report for CBAM?
A full calendar year, 1 January to 31 December — not your fiscal year — for one installation, meaning one physical production site.
A company with two factories sends two separate sets of data.
Source: Commission Guidance No. 3, pp. 9, 18
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
Is there a free official way to share CBAM data with importers?
Yes — the Commission's operator portal (O3CI) lets an installation register its data once and share it with every importer, free of charge, though it requires an EU Login account.
For a producer who prefers a spreadsheet, the Communication Template remains the common route.
Source: European Commission, CBAM Registry and O3CI
How much does CBAM cost my EU customer?
Roughly: tonnes imported × emissions per tonne × the EU carbon price × the phase-in factor, which is 2.5% in 2026 and rises to 100% by 2034.
Using the default value with its mark-up instead of your real figure raises the emissions per tonne, and therefore the cost, for every tonne.
Source: Regulation (EU) 2023/956, Article 31
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)
Does CBAM File send my production data anywhere?
No — every calculation and the filled template are produced inside your browser; your production, fuel and purchase figures are never uploaded to our servers.
The only thing we ever store is an email address, and only if you ask for regulatory update alerts.
Source: CBAM File Privacy Policy
Last updated 2026-09-17.
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