Carbon Compliance

EU CBAM

Definitive phase

Pay for your own emissions, not the EU's default guess.

If you export steel, aluminium, cement, fertiliser, hydrogen or electricity to the EU, someone is going to put a number on your product's embedded carbon. Either it's your real number, verified and evidenced — or it's the EU's default value, deliberately set above the global average. Carbon Compliance produces the first one.

Certificates for emissions embedded in 2026 imports are surrendered September 2027.

§ 1

Default values

What the EU assumes, unless you prove otherwise.

These are the India-specific default values for the definitive period, read from the Commission's own published workbook. They are set above the real global average on purpose. Every tonne you ship under a default rather than your own verified figure is priced as though it came from a worse plant than yours.

EU CBAM default emission values by sector, tonnes of CO2 equivalent per tonne of product
SectortCO₂e / tAssumed unless you prove otherwise
SteelCN 72084.28
Aluminium, unwroughtCN 76011.87
Cement, grey PortlandCN 2523 29 001.48
Fertiliser — ammonia, anhydrousCN 2814 10 003.28
HydrogenCN 2804 10 0014.03
India-specific CBAM default values for the definitive period, before the 2026 mark-up. Electricity is excluded — its defaults are per-MWh, not per-tonne.

Reg. (EU) 2025/2621

Primary source

§ 2

What changed

Three things became binding on the same day.

The transitional phase only asked EU importers to report embedded emissions. The definitive phase made authorisation, verified reporting and certificate obligations binding at once.

  • Authorisation

    EU importers of covered goods must hold authorised CBAM declarant status before they can bring your product in.

  • Verified reporting

    Actual emissions figures — as opposed to EU default values — must be signed off by an accredited verifier who visits the installation.

  • Certificates

    Certificate sales begin 1 February 2027. The first declaration and surrender deadline is 30 September 2027, for emissions embedded in 2026 imports.

EU CBAM · where you are now

Oct 2023
Transitional phase begins
Reporting only — no certificates.
Jan 2026
Definitive phase begins
Authorisation, verified reporting and certificate obligations are binding.
Sep 2027
First certificates due
Declare and surrender certificates for emissions embedded in 2026 imports.

1 January 2026

Commission — verification

checked 2026-08-09

ICAP — compliance phase

checked 2026-08-09

§ 3

The artefact

What a filing actually requires.

  • Embedded emissions, per good, per installation

    Calculated with the CBAM methodology for your sector — direct and indirect emissions from production, tied to the specific installation that made the goods, not a company-wide average.

  • A verifiable evidence chain

    Production volumes, fuel and energy consumption, and purchased electricity, each traceable back to source documents — because an accredited verifier will ask.

  • Adjustment for carbon price already paid

    Any carbon price you've already paid in India on the same emissions is deducted from what's owed in the EU — you need that paid-price evidence on file too.

  • The EU's declaration format

    Your importer files through the CBAM registry, in the Commission's structure — a number in a spreadsheet doesn't satisfy it.

Per good, per installation

Not a dashboard: a specific, auditable figure in the shape the EU asks for.

§ 4

Supplier data

Your number isn't only yours.

Your embedded-emissions figure includes what your own upstream suppliers embedded in what they sold you — scrap, alloys, clinker, intermediate goods. If they don't give you a number, the EU supplies one for you, and you end up certifying for a dirtier plant than the one you actually used.

We send each supplier a tokenised link — no account, no login — where they enter their own specific embedded emissions and supporting documents. The moment that's verified, your calculation switches from the EU default to their actual figure. You chase your supply chain without chasing anyone by phone.

Your biggest cost lever

Default values sit above the real global average — that is what makes them a penalty.

§ 5

Questions

Questions we actually get asked.

Is the transitional phase still running?
No. The transitional phase (reporting only) ran from October 2023 to December 2025. The definitive phase started 1 January 2026 and is the phase you're in now — authorisation, verified reporting and certificate obligations are all binding.
How much will CBAM certificates actually cost in 2026?
Less than the eventual full exposure. The number of certificates you owe is reduced by the free allocation still granted to EU producers of the same goods, and that free allocation is being phased out gradually — a factor starting at 2.5% in 2026 and rising to 100% (no offset left) by 2034. Your bill grows every year through 2034; it does not arrive all at once.
What happens if my suppliers won't give me emissions data?
Your declaration falls back to the EU's default values for that good — figures set above the real global average, so you pay for a worse plant than the one you actually bought from. This is the single biggest lever most exporters have on their own CBAM cost, and it depends entirely on suppliers who have no EU account and no reason to log into anything.
Who can verify our embedded emissions?
From 2026, only an independent verifier accredited by an EU national accreditation body can sign off on actual (non-default) emissions data — and verifiers are required to visit the installation. The first CBAM verifiers are expected to be accredited around September 2026.
Which sectors does CBAM cover?
Cement, iron & steel, aluminium, fertilisers, electricity and hydrogen.

Asked by real exporters

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Your exposure

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Run the numbers yourself, or talk to us — either way, get a real figure instead of a guess.