CBAM for non-EU manufacturers: What your EU customers are about to ask you (and how to get ahead of it)

If you manufacture cement, steel, aluminium, fertilisers, or hydrogen outside the EU and sell to European customers, you've probably started receiving some unusual requests lately.

Data requests. Emissions data, specifically. And not the generic sustainability numbers you might have shared before—something much more detailed.

Here's what's happening, why it matters to your business, and what you can do about it.

Why your EU customers suddenly care about your emissions

The EU's Carbon Border Adjustment Mechanism—CBAM—went into full force on January 1, 2026.

Here's the short version: EU importers now have to buy carbon certificates based on the emissions embedded in the products they import. The more emissions, the more they pay.

Your emissions directly affect your customers' costs.

This creates an interesting dynamic. Your EU customers don't just want your data for compliance paperwork. They need it to calculate how much importing your products will cost them in carbon fees.

And if they can't get accurate data from you? They'll use EU-provided default values instead. These defaults are intentionally set high—designed to encourage suppliers to provide real numbers. Which means your customers pay more than necessary. Which means they start looking at alternative suppliers who can provide the data.

The uncomfortable truth: you have no legal obligations (but that's not the point)

Let's be clear: CBAM doesn't impose any legal obligations on non-EU manufacturers. The regulation targets EU importers, not you.

But here's the commercial reality. If you can provide verified, installation-level emissions data, your EU customers:

• Pay lower CBAM costs (based on your actual, hopefully lower-than-default emissions)

• Meet their compliance deadlines without scrambling

• Have audit-ready documentation

If you can't? They pay more, they stress more, and eventually, they may decide the hassle isn't worth it. Especially when a competitor down the road can provide what they need.

CBAM isn't just a regulation. It's a supplier selection criterion.

What exactly will your customers ask for?

Expect requests for:

1. Installation-specific emissions

Not your company's overall carbon footprint. Not industry averages. The actual emissions from the specific factory where the products are made.

2. Direct and indirect emissions

• Direct: CO₂ from your production process (burning fuel, chemical reactions)

• Indirect: CO₂ from the electricity you use

3. Product-level allocation

If your factory makes multiple products, how much of those emissions belong to the specific product your customer is buying?

4. EU methodology compliance

Calculations must follow the EU's Monitoring and Reporting Regulation (MRR) methodology—the same standards used for EU factories under the Emissions Trading System.

5. Third-party verification (from 2026)

Starting now, all emissions data must be verified by an accredited verifier. And for the first year, that verifier is required to conduct an on-site visit to your installation.

Three things you can do right now

1. Register on the EU's CBAM operator portal

Since January 2025, non-EU manufacturers can register directly with the European Commission's CBAM portal. This lets you:

• Upload your installation and emissions data once

• Share it securely with multiple EU customers (instead of responding to each request separately)

• Control what data each customer sees

How to register:

1. Create an EU Login account at webgate.ec.europa.eu/cas

2. Set up two-factor authentication (security key or trusted platform recommended)

3. Access the "Operators Third Countries Installations" section

4. Submit your company and installation details for approval

You'll need your EU customers' EORI numbers to share data with them, so ask for those upfront.

2. Use the official communication template

The EU Commission provides an Excel template that automates most emissions calculations. When you enter your raw data—fuel consumption, electricity use, production volumes—it calculates the embedded emissions per product.

The template includes a "Summary_Communication" sheet with everything your EU customers need to file their CBAM reports.

You don't have to use this template, but it makes life easier for everyone. Customers recognize it, verifiers understand it, and it reduces back-and-forth questions.

Download it from the official EU CBAM guidance page.

3. Start the verification conversation now

Finding an accredited verifier, scheduling an on-site visit, and completing the verification process takes time. If you wait until your customers are desperate, you'll be competing with every other supplier who also waited.

Verifiers must be accredited by EU accreditation bodies, but they can be based anywhere in the world. The first-year site visit requirement means international travel scheduling—not something that happens overnight.

Common mistakes to avoid

Sending generic sustainability reports

LCAs, EPDs, and corporate sustainability reports are useful for other purposes, but they don't meet CBAM requirements. They typically use industry averages instead of installation-specific data.

Using company-wide emissions data

If you have three factories, your customer needs the emissions from the specific factory that made their products—not an average across all three.

Waiting for customers to explain what they need

Many EU importers are still figuring this out themselves. If you can proactively provide CBAM-ready data before they ask, you've just made their lives significantly easier.

Ignoring precursor materials

If your products contain materials from other suppliers (like bought-in steel components), the embedded emissions of those inputs count too. You may need to collect CBAM data from your own suppliers.

The bigger picture: this is a competitive opportunity

Here's what most suppliers miss.

CBAM is being framed as a burden—more paperwork, more data requests, more hassle. And yes, there's effort involved.

But think about what happens over the next few years. Every non-EU supplier selling carbon-intensive products to Europe will face the same challenge. The ones who build proper emissions monitoring systems, register on the EU portal, and establish relationships with verifiers early will have a significant advantage.

Lower-emission products will cost EU customers less in CBAM certificates. Verified data will be table stakes for doing business. And suppliers who can demonstrate continuous emissions reductions will become preferred partners.

The question isn't whether to adapt. It's whether to do it now—while it's still a differentiator—or later, when it's just the minimum requirement.

Quick reference: Key dates and facts

CBAM definitive phase started	January 1, 2026
First declaration deadline for importers	September 30, 2027
Products covered	Cement, iron & steel, aluminium, fertilisers, hydrogen, electricity
Third-party verification	Mandatory from 2026
On-site verifier visit	Required in first year (2026)
EU operator portal	Live since January 2025
Penalty for importers using defaults	Higher certificate costs (defaults set conservatively high)

References

1. European Commission - CBAM Registry and Reporting - Official portal access and registration guidance

2. European Commission - CBAM Legislation and Guidance - Communication templates and operator guidance documents

3. Carbon Trust - CBAM for Exporters to the EU - Practical checklist for non-EU exporters