EU CBAM Compliance: Complete Guide for Non-EU Exporters

What is CBAM and which goods does it cover?

The Carbon Border Adjustment Mechanism (CBAM) is the EU system that applies a carbon price to the embedded emissions of certain goods imported into the EU. Since January 2026, its definitive regime covers six sectors: iron and steel, aluminium, cement, fertilisers, hydrogen and electricity.

Whether a specific product is covered depends on its CN code, not only on its commercial description. The complete list is in Annex I of Regulation (EU) 2023/956.

For a complete overview of how CBAM works, its timeline and certificate prices, read our guide: What is CBAM?

But CBAM is not only an issue for European importers.

It also has important implications for manufacturers and exporters outside the European Union.

Does CBAM apply to non-EU companies?

Most formal CBAM obligations are placed on the EU importer or authorised CBAM declarant.

However, the information needed to comply with those obligations often originates at the manufacturing installation outside the EU.

An importer cannot independently know how much fuel was consumed at a steel plant in India, how cement was produced at a Turkish installation or what electricity and raw materials were used to manufacture aluminium in the Gulf.

For this reason, European importers may request detailed emissions information from their non-EU suppliers.

For exporters, CBAM therefore becomes part of the commercial relationship with European customers.

What does an EU importer need from a non-EU supplier?

When actual emissions are used for CBAM purposes, the calculation requires information relating to the installation and production processes where the goods were manufactured.

Depending on the product and production route, manufacturers may need to collect information on:

• production quantities;
• fuels and energy consumption;
• direct greenhouse gas emissions;
• electricity consumption;
• relevant raw materials and precursors;
• production routes;
• emission factors;
• allocation of emissions between products.

This is why receiving a request for “CBAM data” from a European customer can quickly become more complex than completing a simple questionnaire.

The manufacturer needs a structured system for collecting, calculating and documenting the relevant information.

How are CBAM embedded emissions calculated?

One of the most important requirements for non-EU manufacturers is the CBAM embedded emissions calculation.

Embedded emissions represent the greenhouse gas emissions attributed to the production of a CBAM good according to the methodology established by EU legislation.

The calculation starts at the manufacturing installation.

The relevant production processes must first be identified, after which the company needs to collect the data necessary to determine the emissions associated with those processes.

Depending on the product, CBAM calculations may consider:

• direct emissions generated during production;
• indirect emissions where applicable;
• electricity consumption;
• fuels;
• relevant precursor materials;
• production quantities;
• allocation of emissions between different products.

For complex goods, the embedded emissions associated with certain precursor materials may also need to be included.

The final objective is to determine the specific embedded emissions of the CBAM goods exported to the European Union.

What is a CBAM Monitoring Plan?

If a non-EU manufacturer wants its actual emissions to be used for CBAM purposes, the data and calculation methodology must be properly documented.

The CBAM monitoring plan explains how embedded emissions are monitored and calculated at installation level.

It identifies the relevant production processes, emission sources, data sources and calculation methodologies and provides the methodological basis for both the emissions calculation and subsequent verification.

For manufacturers producing several CBAM goods or operating multiple production processes, preparing the monitoring plan early can also help create a more consistent and repeatable data-management process.

Do CBAM emissions need to be verified?

Yes, when actual emissions are used.

The verification must be carried out by an independent verifier accredited for CBAM by an EU National Accreditation Body.

The verifier assesses whether the monitoring methodology, emissions calculation and supporting evidence meet the relevant CBAM requirements.

The manufacturer can receive technical support in preparing the calculation, monitoring plan and documentation, but the actual verification must be performed by the accredited independent verifier.

CBAM actual emissions vs default values: why it matters for exporters

This is one of the most important aspects of CBAM for non-EU manufacturers.

CBAM allows embedded emissions to be determined using actual emissions or, where applicable, regulatory default values. At first sight, using default values may appear simpler because the manufacturer does not need to demonstrate the specific carbon performance of its installation.

However, this simplicity can have a commercial downside.

Default values are set by the European Commission in Implementing Regulation (EU) 2025/2621, by product and by country of origin, and include a mark-up. For most goods, the mark-up is 10% in 2026, 20% in 2027 and 30% from 2028. As a result, default values do not necessarily reflect the actual carbon performance of a specific manufacturing installation.

If a manufacturer operates an efficient plant with emissions lower than the applicable default value, calculating and verifying its actual embedded emissions allows the European customer to use data that reflect the real performance of that installation.

If actual emissions are not available and the default value is used instead, this better performance may not be recognised. A higher default value means that the EU importer has to account for more embedded emissions and surrender more CBAM certificates, increasing the CBAM cost associated with the imported goods.

For manufacturers whose actual emissions are lower than the applicable default value, calculating and verifying actual embedded emissions can therefore help reduce the CBAM exposure of their European customers and improve the competitiveness of their products in the EU market.

What should you do if an EU customer asks for CBAM data?

If your company has received its first request for CBAM information from a European customer, the following process can help clarify what needs to be done.

1. Check whether the exported product is covered by CBAM

Start from the product’s CN code.

Do not assume that every steel, aluminium or downstream product falls automatically within the same CBAM requirements.

2. Identify the relevant installation

Determine where the product is manufactured and which installation or installations contribute to its production.

3. Map the production process

Identify the production routes, emission sources, energy consumption and relevant precursor materials associated with the product.

4. Prepare the CBAM monitoring plan

Define how the necessary data will be measured, collected, controlled and documented.

5. Collect the required data

This can include production records, fuel consumption, electricity consumption, material flows and information relating to relevant precursor materials.

6. Calculate CBAM embedded emissions

Apply the specific methodology required by the CBAM regulation.

An existing LCA or Product Carbon Footprint may provide useful data, but it does not replace the CBAM calculation.

7. Prepare the emissions documentation

Organise the calculation, methodological information and supporting data so that the emissions can be reviewed and verified.

8. Obtain independent CBAM verification

If actual emissions are used, they must be verified by an accredited CBAM verifier.

9. Provide verified emissions data to the EU customer

Once verification has been completed, the relevant information can be shared with the European importer for use in its CBAM obligations.

CBAM requirements by sector: what changes for exporters

The data an exporter must provide depends above all on its sector and production route. Here are the main differences.

Cement and clinker

For cement, CBAM counts both direct and indirect emissions. Clinker production is the main source, through limestone calcination and kiln fuel combustion. Data on clinker content, kiln fuels and electricity consumption is therefore essential.

Türkiye is one of the largest suppliers of cement and clinker to the EU.

Iron and steel

For iron and steel, CBAM counts direct emissions only. The production route makes the difference: blast furnace routes have a much higher carbon intensity than scrap-based electric arc furnaces. For many finished products, the embedded emissions of precursors such as pig iron or crude steel must also be included.

India, China and Türkiye are among the main exporters of CBAM steel to the EU.

Aluminium

For aluminium, CBAM currently counts direct emissions only, including perfluorocarbons (PFCs) from the electrolysis process. Electricity used in smelting is not priced under the current rules. Process control at the smelter therefore has a direct effect on the CBAM result.

The Gulf region, including the UAE and Oman, is a major source of primary aluminium for European manufacturers.

Fertilisers

For fertilisers, CBAM counts direct and indirect emissions, and nitrous oxide (N₂O) for some products such as nitric acid. Accurate data on natural gas use, electricity and process emissions is essential.

Egypt and other North African countries, such as Algeria and Morocco, are key suppliers of fertilisers to Europe.

CBAM compliance as a carbon-management opportunity

CBAM can be more than a regulatory requirement. Calculating embedded emissions can help manufacturers identify the main emission sources in their production processes and highlight opportunities to improve energy efficiency, materials and production technologies.

For non-EU exporters, this can support both CBAM compliance and product competitiveness in the European market.

How can Ollum support non-EU manufacturers with CBAM?

We support many EU importers with their CBAM obligations, so we know exactly what data and documentation they expect from their suppliers. We bring this knowledge to non-EU companies throughout the technical CBAM process, including:

• identification of covered products and installations;
• calculation of embedded emissions according to the CBAM methodology;
• preparation of the monitoring plan;
• preparation and support for third-party verification;
• organisation of verified data for EU customers.

If your company exports CBAM goods to the European Union, you can learn more about our CBAM compliance services for non-EU manufacturers.