A customer has mentioned CBAM and asked for carbon data. Before treating it as a new compliance burden, establish whose obligation it is. For most suppliers it is not theirs: the CBAM duty sits with the EU importer. Your part is to supply the emissions data the importer needs.
| First question | Short answer |
|---|---|
| Do I have to file anything? | Not unless you are the EU importer of record. A non-EU supplier provides data to the customer who files. |
| Which goods? | Iron and steel, aluminum, cement, fertilizers, hydrogen, electricity, and certain downstream products. |
| Is my customer in scope? | Only if they import more than 50 metric tons of CBAM goods a year. Ask before building a data exercise. |
| What do they need? | Embedded emissions per metric ton or unit of the goods you sell them, with the method behind the figure. |
| When does money change hands? | Certificate sales start 1 February 2027. 2026 is registration and reporting. |
Regulation details and links checked 19 July 2026. Some implementing rules for the definitive regime were still being finalized; the European Commission's CBAM page carries the current position, and your customer's request tells you what they actually need.
What CBAM is
The Carbon Border Adjustment Mechanism puts a carbon price on certain imports into the EU, to match the price EU producers pay under the EU Emissions Trading System. It covers carbon-intensive goods — iron and steel, aluminum, cement, fertilizers, hydrogen, and electricity — plus certain downstream products of these.
The transitional reporting phase (October 2023 to December 2025) is over. The definitive period started on 1 January 2026. In the definitive regime, EU importers of CBAM goods must be authorized CBAM declarants and declare the embedded emissions of what they import each year. From 2027 they pay for those emissions by buying and surrendering CBAM certificates.
The 2026 timeline
- 1 January 2026 — the definitive period began. Importers above the threshold register as authorized declarants and prepare to declare embedded emissions. 2026 is registration and reporting, not payment.
- 1 February 2027 — certificate sales start (postponed from January 2026). From then, importers buy certificates to cover the embedded emissions of their imports at a price linked to the EU ETS.
In 2026 your customer's request is a data and registration exercise. The cost follows in 2027, which is why they want the emissions figures right now.
Whose obligation it is
The CBAM obligation falls on the EU importer of record — the company bringing the goods into the EU — not on the non-EU producer or supplier.
- A non-EU supplier selling CBAM goods to an EU customer has no direct CBAM filing obligation. The EU customer needs the supplier's emissions data to complete their own declaration, so they ask for it.
- An EU supplier who is not importing is not affected on domestic sales. CBAM applies at the EU border.
- An EU importer bringing CBAM goods in from outside the EU carries the obligation. See below.
For the large majority of suppliers, CBAM arrives as a customer data request, not a filing owed to an authority. This is the same pattern as the EUDR and the German LkSG: the legal duty sits with the EU company and reaches the supplier as questions.
The de minimis threshold
Under the simplifications adopted in 2025, importers bringing in 50 metric tons or less of CBAM goods (cumulative net mass) per year are exempt from CBAM obligations: no declaration, no certificates. Hydrogen and electricity are excluded from the exemption. For the main goods categories the Commission estimates the threshold exempts around 90% of importers while still covering roughly 99% of embedded emissions.
Two consequences for a supplier:
- Whether your customer asks depends on their import volume, not yours. A small EU buyer importing modest quantities may be out of scope and not need your data. Ask before investing effort.
- The threshold is cumulative. If an importer exceeds 50 metric tons at any point in the year, the whole year's imports become subject to CBAM, not only the excess. Customers near the line may ask for data as a precaution. That is a reasonable request.
What the customer needs
If the customer is in scope, they need the embedded emissions of the goods you supply: the greenhouse gases released in producing them, per product.
- Direct emissions from the production process, and relevant indirect emissions from the electricity used in production
- Per-metric-ton or per-unit figures for the specific CBAM goods you sell them
- The calculation method and data behind the figure, so it withstands scrutiny
This is closely related to a product carbon footprint — a per-product emissions figure — but CBAM uses its own defined methodology for embedded emissions. If the customer references a specific CBAM data template or methodology, follow it.
Actual values versus default values
In the definitive regime an importer declares embedded emissions in one of two ways:
- Verified actual values — real production data from the supplier, checked by an accredited verifier.
- Commission default values — fallback figures based on the average emission intensity of the ten highest-emitting exporter countries for each good, with regional adjustments.
The defaults are pegged to the worst-performing exporters, not the average producer. If your actual emissions are lower than the default — and for many producers they are — verifiable actual data reduces your customer's CBAM cost from 2027. A supplier who can provide a documented, verifiable embedded-emissions figure lowers the importer's cost where actual values come in below the defaults. That is a commercial advantage. Germany's CBAM authority explains the definitive-regime mechanics on the DEHSt CBAM page.
Preparing the data
- Confirm scope with the customer. Which products, whether they expect to exceed the de minimis threshold, and which methodology and template they want.
- Gather production data. Energy and fuel used to make the goods, process emissions, electricity consumption, output quantities. The carbon calculator and the manufacturing footprint guide cover the operational side.
- Calculate embedded emissions per unit of the CBAM good, using the method the customer specifies.
- Document everything. Data sources, factors, boundaries, period. If the customer intends to use actual values, the figure has to pass an accredited verifier.
If you are the EU importer
If you import more than 50 metric tons of CBAM goods into the EU per year, the obligation is yours: authorized CBAM declarant status, annual declaration of embedded emissions, and purchase and surrender of certificates once sales start on 1 February 2027. Implementing rules were still being finalized at the time of checking. Use the Commission's CBAM page or an advisor for the current schedule rather than older summaries.
What not to do
- Do not assume you must file. For most suppliers CBAM is a customer data request.
- Do not invent embedded-emissions figures. Actual values must pass accredited verification. Use real production data and document the method.
- Do not send a company footprint when they need product embedded emissions. They are different numbers. Provide the per-product figure.
- Do not assume the customer is in scope. The 50-metric-ton de minimis exempts most importers. Confirm before building a large data exercise.
The bottom line
CBAM entered its definitive period in January 2026, with certificate purchases from February 2027, and the obligation sits with the EU importer. If your customer imports more than 50 metric tons of CBAM goods a year, they may ask for documented per-product embedded-emissions data, and verified actual data below the default values reduces their cost. Get the production data and the method right once and every CBAM-driven request after that is a repeat.