EU CBAM is now live: what steel, aluminium and fertiliser exporters must give their EU buyers

Since 1 January 2026, the EU Carbon Border Adjustment Mechanism (CBAM) has been in its definitive phase. EU importers of steel, aluminium, fertilisers, cement and hydrogen now have to pay for the carbon emissions embedded in those goods. The legal obligation sits with the EU importer, but the information needed to meet it comes from the producer outside the EU.

For exporters in India, the GCC, Asia and Africa, this changes the sales conversation. Your EU buyer will increasingly ask for emissions data alongside price, quality and delivery. Suppliers who can provide reliable data may find it easier to keep and win EU business. This article explains the rules as they stand in October 2026 and what you should prepare.

The key rules in 2026

Who is covered: EU importers whose annual imports of CBAM goods (iron and steel, aluminium, fertilisers and cement) exceed 50 tonnes. Importers at or below 50 tonnes a year are exempt. Once the threshold is crossed, all of that year's imports count.
Authorised CBAM declarant: an importer above the threshold must hold this status from the EU authorities. Goods not declared by an authorised declarant can be refused customs clearance.
Certificates: the importer must buy and surrender CBAM certificates covering the embedded emissions. Sales on the EU central platform start in February 2027 for 2026 imports.
Annual declaration: the first declaration, covering 2026 imports, is due by 30 September 2027.
Price: in 2026 the certificate price is set each quarter from EU carbon auction prices. The Commission published EUR 75.36 for Q1, EUR 75.28 for Q2 and EUR 82.32 for Q3 2026. From 2027 the price will be published weekly.
Free allocation phase-out: the CBAM charge is reduced to reflect free allowances still given to EU producers. That reduction shrinks gradually, starting with a 2.5% cut in 2026, so the cost will rise over time.

Actual emissions or default values

The importer can declare either the actual embedded emissions of your product, verified by an accredited verifier, or default values published by the European Commission. Default values are set by country and product and are deliberately cautious. They also carry a mark-up: 10% in 2026, 20% in 2027 and 30% from 2028 for most goods. For fertilisers the mark-up is 1%.

The Commission corrected the definitive default values in July 2026 (Implementing Regulation (EU) 2026/1740), with effect back to 1 January 2026. Buyers who calculated costs using the December 2025 tables may need to recheck them.

In practice, if your production is cleaner than the default for your country, verified actual data will lower your buyer's CBAM cost. If you cannot provide data, the buyer will use defaults and may price that cost into the deal.

A worked example

The following figures are illustrative only and are not official default values. Suppose an EU importer buys 1,000 tonnes of a steel product. The producer's verified emissions are 1.9 tonnes of CO2 per tonne of steel. The default value for that product and country is 2.5 tonnes, which becomes 2.75 tonnes after the 10% mark-up for 2026.

Using defaults, the importer reports 2,750 tonnes of CO2; using actual data, 1,900 tonnes. The difference is 850 tonnes. At the Q3 2026 price of EUR 82.32, that is about EUR 70,000 of certificates before the free allocation adjustment. Exact obligations depend on the benchmarks and any carbon price already paid in the country of production.

What your EU buyer will ask you for

Installation details: name, address and location of the plant where the goods were made, and a contact person.
Product details: the CN (customs) code, the production route (for example blast furnace or electric arc furnace for steel) and the quantity produced.
Specific embedded emissions per tonne: direct emissions and, for fertilisers and cement, indirect emissions from electricity.
Emissions in precursors: for example, the emissions in the ammonia used to make a fertiliser, or the crude steel used for a finished steel product, with data from your own suppliers.
A verification report from a CBAM-accredited verifier if the buyer will declare actual values. Verification normally includes a site visit.
Evidence of any carbon price effectively paid in your country, if one applies, so the buyer can claim a deduction.

Steps to take now

Ask each EU customer whether they are an authorised CBAM declarant and whether they plan to use actual or default values.
Set up monitoring of fuel, electricity and materials at installation level following the EU methodology. Data for the 2026 calendar year is needed for the first declaration.
Collect emissions data from your own suppliers of precursors such as pig iron, unwrought aluminium or ammonia.
Contact a CBAM-accredited verifier early. Accredited verifiers have been able to access the CBAM Registry since September 2026, and demand is likely to rise ahead of the September 2027 deadline.
Use the Commission's registry for third-country operators, if your buyer requests it, to share installation data with several EU customers without repeating the work.
Agree in your contracts who provides which data, by when, and who bears the cost if defaults must be used.

What may change next

In December 2025 the Commission proposed extending CBAM to about 180 downstream steel and aluminium products, such as certain machinery parts and fabricated goods, and adding anti-circumvention rules. The EU Council and Parliament adopted different positions in 2026, and negotiations between them began in late September, with political agreement targeted for the end of 2026. Exporters of steel and aluminium components should follow this closely.

This is a summary, not legal advice. Your EU buyer, a CBAM-accredited verifier or the European Commission's CBAM guidance can confirm the requirements for your products.

Meeting EU buyers on Nexus BYF

Exporters who can show credible emissions data have something extra to offer EU customers. On Nexus BYF you can describe this in your company profile and sell offers, list them free, and browse buy requirements from EU importers. Membership unlocks direct contact details so you can discuss CBAM data with buyers early in the conversation.