Cbam Compliance & Emissions Documentation

CBAM entered its definitive phase in January 2026. From February 2027, EU importers must surrender CBAM certificates proportional to the embedded carbon emissions of covered goods imported from non-EU countries. The EU ETS carbon price directly determines the cost of those certificates.

Exporters of covered goods — steel and iron, aluminium, cement, fertilisers, hydrogen, and electricity — now face a binary commercial situation: either provide verified actual embedded emissions data, or have their EU importers pay certificate costs based on EU default values, which are typically higher than actual production emissions and result in higher costs. From July 2024, using default values is already restricted to 20% of total reported emissions for complex goods. From 2026, full reliance on defaults is not available.

Many exporters in LATAM, MENA, and Asia have not yet calculated their actual embedded emissions using EU methodology, do not have CBAM-compliant documentation, and are uncertain whether their EU importers understand what data is required from them. This creates commercial risk — EU importers facing CBAM compliance liability may seek alternative suppliers who can provide verified emissions data.

Our project leads work with your production team to calculate embedded emissions per product line using the EU's specified methodology under Commission Implementing Regulation (EU) 2023/956 and its implementing rules. We produce the specific data formats EU importers require, provide a cost comparison showing your verified emissions versus applicable default values, and prepare a cost projection for your EU buyers. For clients interested in emissions reduction, we produce a prioritised decarbonisation roadmap connected directly to CBAM cost savings.

We work with exporters in LATAM, MENA, and Asia who export to the EU, as well as with EU importers who need to support their suppliers through the verification process.

Scope Confirmation and CBAM Classification

• Confirmation of which of your products are covered under CBAM regulation
• HS code classification of covered goods
• Determination of applicable direct and indirect emission calculation requirements

Embedded Emissions Calculation

• Direct emissions: combustion, process emissions, and fugitive emissions per installation
• Indirect emissions (where required): purchased electricity emissions per product
• Calculation using EU-accepted methodology — activity-based where data is available
• Documentation of emission factors, data sources, and assumptions per the EU implementing rules

Default Value Comparison

• Calculation of what your product would attract under EU published default values
• Cost comparison: your actual verified emissions vs. EU defaults at current ETS prices
• Quantification of the cost difference — presented in a format usable by your EU importers

CBAM Documentation Package

• Embedded emissions data in the structure required by EU importers for CBAM reporting
• Documentation of calculation methodology and data sources to the standard required for EU authority verification
• Summary document for direct use by your EU importer in their CBAM declaration

Carbon Cost Projection

• CBAM certificate cost projection per product line at current EU ETS price and two scenario prices
• Multi-year projection illustrating how costs change as ETS prices evolve
• Applicable carbon price deduction assessment (for exporters in countries with domestic carbon pricing)

Expert Consultation

• Minimum one 90-minute session to review findings, explain the documentation to your team, and advise on EU importer communication

Verified Emissions Documentation: CBAM-compliant embedded emissions data ready for use by your EU importers

Cost Clarity: Quantified difference between your verified emissions and EU default values — expressed in euros per tonne and per shipment

Commercial Preparation: Documentation your EU importers need to manage their CBAM obligations, reducing the risk that they seek alternative suppliers

Deduction Analysis: Identification of any domestic carbon pricing credits applicable to your exports under CBAM rules

Protect EU Market Access: EU importers facing CBAM liability increasingly prefer suppliers who can provide verified emissions data — this service provides that documentation

Quantify Your Carbon Position: Understand the actual cost of your embedded emissions under CBAM pricing before your importers absorb it as a problem

Support Your EU Importers: CBAM compliance is your importer's legal obligation — but providing verified emissions data reduces their cost and administrative burden, strengthening the commercial relationship

Foundation for Reduction: The emissions calculation is the starting point for any decarbonisation plan connected to CBAM cost reduction

• Discovery call (60 min) — product lines, production volumes, and EU export volumes confirmed
• Production data access — energy consumption, fuel use, process input quantities, and production output data per installation
• Electricity data — source, volume, and emission factor for purchased electricity where applicable
• Identify production contact — the internal person with access to operational data
• Existing environmental data — any prior carbon calculations, environmental permits, or emission factor records
• EU importer contact — we recommend looping in your EU importer to confirm the documentation format they require
• Review draft documentation — timely feedback within the agreed revision window

Regulatory Context

CBAM was designed to prevent carbon leakage- the movement of production to non-EU countries with lower carbon costs. Under the definitive phase, EU importers must declare the embedded carbon emissions of covered goods and surrender CBAM certificates proportional to those emissions. The certificate price tracks the EU Emissions Trading System (ETS) price.

Exporters have two options: provide verified actual emissions data (resulting in certificate costs based on real production efficiency) or rely on EU default values (set at the 90th percentile of EU production -a deliberately conservative benchmark). The default value approach results in higher certificate costs for most non-EU producers and is restricted in its application from 2024 onward.

The calculation methodology is defined in EU implementing regulations. Embedded emissions include direct process and combustion emissions per product installation, and indirect electricity emissions where applicable. The data and methodology must be documented to the standard required for EU authority verification.

Our Approach

We work from your actual production data - energy inputs, process parameters, and output volumes - to calculate embedded emissions per tonne of product using EU-specified methodology. We document every calculation step, data source, and emission factor to create a traceable record. We then produce the data summary in the format your EU importer needs for their CBAM declaration.

We also quantify the cost difference between your verified emissions and the EU default values at current ETS pricing, so you have a clear commercial case for the data collection investment.

The engagement does not require on-site visits in most cases - production data can typically be provided remotely. Where on-site data collection is needed, this is scoped separately.

What's Included — All Packages

All engagements include:

• Lead CBAM methodology specialist as primary contact
• Embedded emissions calculation per agreed product scope
• CBAM documentation package for EU importer use
• Default value comparison and cost projection
• Expert consultation session
• Email support throughout engagement