EU CBAM guidelines

If you're importing cement, steel, aluminium, fertilisers, or hydrogen into the EU, you've probably already heard about CBAM. The Carbon Border Adjustment Mechanism is now in its definitive phase, and the clock is ticking.

But here's the part nobody warned you about: your biggest headache won't be understanding the regulation. It will be getting the right data from your suppliers.

The new reality of 2026

Since January 1, 2026, CBAM has moved beyond reporting. Now, importers must actually purchase and surrender CBAM certificates based on the carbon emissions embedded in their products. The first deadline is September 30, 2027.

Miss it, and you're looking at €100 per tonne of unreported emissions—on top of still having to surrender the certificates. For unauthorised importers, penalties can climb to three to five times that amount.

The days of using rough estimates or default values are essentially over. The EU wants actual numbers, verified by accredited third parties, calculated at the installation level where your goods were made.

The problem? Your suppliers probably aren't ready

Here's where things get complicated.

Your steel supplier in Turkey or cement manufacturer in Egypt likely hasn't set up the emissions monitoring systems that align with EU methodology. Many don't even know what data you need—or why you need it at that level of detail.

Generic sustainability reports won't cut it. Lifecycle assessments (LCAs) and Environmental Product Declarations (EPDs) are useful for other purposes, but they're typically based on averages and don't meet CBAM's installation-specific requirements.

What you actually need is:

• Direct emissions (from the production process itself)

• Indirect emissions (from electricity used)

• Data tied to a specific production facility, not company-wide averages

• Calculations following the EU's Monitoring and Reporting Regulation (MRR) methodology

Four steps to get the data you need

1. Find the right person at your supplier

Don't just email your sales contact. You need someone who handles environmental data—typically in EHS (Environment, Health & Safety), sustainability, or plant operations. Sales teams rarely have access to installation-level emissions figures.

2. Make the request crystal clear

Provide a template. Explain exactly which data points you need and why. Include an example. Suppliers are far more likely to respond when they don't have to guess what you're asking for.

The minimum you'll need:

• Production installation name and location

• Direct and indirect emissions per product

• Production method and energy sources used

• Calculation methodology and emission factors applied

3. Set deadlines and follow up

Treat this like any other critical business process. Set a clear deadline, send reminders, and escalate to procurement or legal if needed. Document everything—auditors will want to see your due diligence.

4. Have a backup plan

If a supplier simply cannot provide the data, you have limited options. Default values may be applied in some cases, but they're calculated conservatively—meaning you'll likely pay more in certificates than necessary. For critical suppliers, consider whether it's worth investing in helping them build the right monitoring capabilities.

What if suppliers don't respond?

This is the uncomfortable reality many importers face. And unfortunately, there's no easy workaround.

Without installation-level emissions data calculated according to EU standards and verified by an accredited third party, you may not be able to submit a compliant CBAM declaration for those imports.

Some practical options:

• Embed CBAM data obligations into your contracts. Make it a condition of doing business.

• Offer support. Some suppliers genuinely want to help but don't know how. Training materials, templates, or even connecting them with verification services can unlock the data.

• Escalate strategically. If a supplier remains unresponsive after clear requests and reminders, involve your legal or procurement teams.

• Consider alternatives. In extreme cases, you may need to source from suppliers who can provide compliant data.

The software question

Managing CBAM supplier data manually—across dozens or hundreds of suppliers—becomes unworkable fast. Spreadsheets don't scale. Email threads get lost.

Digital platforms can help by:

• Centralizing all supplier communications

• Providing pre-built templates aligned with CBAM requirements

• Automating reminders and tracking response rates

• Validating incoming data before it goes into your declaration

The goal is simple: collect once, reuse across reporting periods, and have an audit trail ready when regulators come knocking.

The bottom line

CBAM isn't just a reporting exercise anymore—it's a cost driver. The quality of your supplier emissions data directly affects how many certificates you need to buy.

Getting that data requires building new processes, educating your supply chain, and sometimes having difficult conversations with long-standing partners.

Start now. The September 2027 deadline sounds far away, but collecting verified, installation-level emissions data from a global supply chain takes longer than most companies expect.

References

1. European Commission - Carbon Border Adjustment Mechanism - Official EU CBAM portal with regulation details and guidance

2. EU ETS Monitoring and Reporting Regulation (MRR) - Details on emissions calculation methodology

3. SGS - CBAM pre-verification key requirements - Third-party verification requirements

4. Mayer Brown - EU CBAM simplification regulation - Updated deadlines and penalties

5. UK Government - EU CBAM guide - Practical overview of requirements