CBAM for Exporters: Installation Emissions Data for EU Importers

Does the CBAM concern your company?

Yes, if you export to the EU goods whose CN code appears in Annex I to Regulation (EU) 2023/956: cement, electricity, fertilisers, iron and steel, aluminium or hydrogen. You are not the liable party; your importing customer is. But you hold the installation’s emissions data, and that is what your customer now asks for.

The CBAM went through a transitional period from 1 October 2023 to 31 December 2025, with reporting only. The definitive period has applied since 1 January 2026: the importer must be an authorised CBAM declarant, declare the embedded emissions of imported goods each year and surrender CBAM certificates. Regulation (EU) 2025/2083 of 8 October 2025, published in the Official Journal on 17 October 2025 and in force since 20 October 2025, simplified the regime.

For a producer in Morocco, elsewhere in Africa or in the Middle East, the question arises in six sectors, and only these: cement, electricity, fertilisers, iron and steel, aluminium, hydrogen. This page gives no export volumes on purpose: what matters is the CN code of each good you sell to an EU customer.

Which goods are in the scope of the CBAM?

The goods in Annex I to Regulation (EU) 2023/956, identified by their Combined Nomenclature (CN) code. The same annex sets the greenhouse gases to account for. Table based on the consolidated version of 20 October 2025, read on EUR-Lex on 11 November 2026.

The indirect-emissions column comes from Article 7(1) and Annex II of the regulation: for iron and steel, aluminium, hydrogen and electricity, only direct emissions are taken into account. For cement and fertilisers, emissions from electricity consumed in the production process are added.

Downstream products are covered too: steel screws and bolts (7318), steel structures (7308), aluminium profiles and foil (7604, 7607). And when your good contains a covered precursor, such as purchased steel used to make tubes, the precursor’s embedded emissions enter your calculation.

What does your EU importer ask for, and who produces it?

The data it needs to declare actual emissions: installation identification, direct and, where relevant, indirect emissions, specific embedded emissions per good, the share of default values and the verification report. The template in Annex IV to Implementing Regulation (EU) 2025/2547 sets the minimum content of the operator’s emissions report.

How is a CBAM calculation different from a carbon footprint?

A corporate carbon footprint measures the whole organisation’s emissions over a year; the CBAM measures an installation’s emissions attributed to each good, per functional unit. They share data, not method.

ISO 14064-1:2018 is under revision: the ISO/WD 14064-1.2 draft was at stage 20.60 on iso.org on 11 November 2026, and the 2018 edition remains current. For an organisational inventory, see our page on carbon footprint under ISO 14064. The energy metering used for the CBAM also feeds scopes 1 and 2 of your inventory.

How are an installation’s embedded emissions calculated?

With the method set by Implementing Regulation (EU) 2025/2547 of 10 December 2025: define the production processes, monitor the installation’s emissions, then attribute them to goods. The method builds on the one used for installations in the EU Emissions Trading System.

1. System boundaries. Processes within the boundaries defined per aggregated goods category (Annex I to the implementing regulation) are included: direct emissions, indirect emissions for goods outside Annex II to the basic regulation, and the embedded emissions of precursors (Article 3).
2. Production processes and functional unit. The operator identifies the processes producing goods with the same functional unit; several routes producing the same good form one process (Article 4).
3. Monitoring. Direct emissions are monitored under Annex II to the implementing regulation; indirect emissions from the electricity consumed by the process (Article 5).
4. Monitoring plan. The operator designs and applies a monitoring plan with at least the elements of point A.5 of Annex II, submitted in English (Article 5(6)).
5. Attribution. Direct and, where relevant, indirect emissions of the processes are attributed to goods under Annex III (Article 6).
6. Operator’s emissions report. The operator prepares this report, in English, and its summary following Annex IV, and sends them to the verifier through the CBAM registry or by other means (Article 10).

The reporting period is the calendar year; for a good imported in 2026, it is 2026 (Article 7). Where an installation receives electricity from several sources, the emission factor is by default the weighted average of the sources, unless there is evidence that a process used only one source (Article 9). This page gives no emission factor figures on purpose: each factor must come from a documented source cited in the monitoring plan.

Default values or actual values: what will your customer declare?

For goods other than electricity, the importer determines embedded emissions either from your installation’s actual emissions or by reference to default values (Article 7(2) of Regulation (EU) 2023/956). Only actual values go through verification.

Default values are set by Implementing Regulation (EU) 2025/2621 of 16 December 2025, applicable since 1 January 2026. Its Annex I gives tables per country, including a table for Morocco; where a country is not listed, the “other countries and territories” table applies. For each CN code it gives direct, indirect and total emissions, then a marked-up value that differs for 2026, 2027, and 2028 onwards. Implementing Regulation (EU) 2026/1740 of 20 July 2026 replaced that Annex I with effect from 1 January 2026: the mark-ups are 10% for 2026, 20% for 2027 and 30% from 2028 for cement, iron and steel, aluminium and hydrogen, and 1% every year for fertilisers. The Morocco table covers cement, fertilisers, aluminium and hydrogen but not iron and steel: Moroccan steel falls under the “other countries and territories” table. Regulation 2025/2621 is to be revised in 2027 at the latest.

• Complex goods can combine both. Your own process can use actual values and a purchased precursor default values (Article 15 of Implementing Regulation (EU) 2025/2547).
• Carbon price paid at origin. With actual values, the declarant may claim a reduction in certificates for a carbon price effectively paid in the third country, backed by documentation certified by an independent person. With default values, a reduction can only be claimed by reference to yearly default carbon prices, which the Commission may publish from 2027 (Article 9).

A customer that receives actual, verified data can declare it as is; otherwise, it declares marked-up values.

How does verification work?

An accredited verifier reviews your monitoring plan, calculation and evidence, visits the installation and issues one verification report per installation, concluding with reasonable assurance that the report is free of material misstatements and non-conformities (Annex VI to Regulation (EU) 2023/956).

• Accreditation. Delegated Regulation (EU) 2025/2551 of 20 November 2025 sets the accreditation conditions. According to the Commission’s verification page, only national accreditation bodies of EU or EEA states accredit CBAM verifiers; a company established outside the EU may apply to any of them. Verifiers then register in the CBAM registry, not before 1 September 2026 (Article 10a).
• Site visit. It is mandatory. Implementing Regulation (EU) 2025/2546, applicable since 1 January 2026, allows a virtual visit or a waiver only under strict conditions, including a physical visit in the preceding reporting period and no significant change to the installation or monitoring plan.
• Materiality. For each tonne of good identified by CN code, the verifier applies a materiality level of 5% of total specific embedded emissions, and professional judgement below it (Article 5 of Regulation 2025/2546).
• Record keeping. A registered operator keeps the verification report and calculation records for four years after verification (Article 10 of the basic regulation).

ACG prepares your installation for verification; it does not carry it out.

What is the CBAM timeline for an exporter?

Dates below come from texts read on EUR-Lex and European Commission pages consulted on 11 November 2026.

For you, the deadline that matters is your customer’s: your verified 2026 data must be available early enough for its declaration before 30 September 2027.

Should you register in the CBAM registry?

It is not mandatory, but it is the intended channel for sharing your data. Article 10 of Regulation (EU) 2023/956 lets the operator of a third-country installation request registration, valid for five years. A registered operator determines embedded emissions, has them verified, keeps the records and may disclose verified information to declarants.

According to the Commission’s registry and reporting page, the O3CI module is reserved for operators outside the EU. It lets them upload their installation and emissions data once and share it with declarants, with confidential treatment of business-sensitive data. The declarant finds the installation in the registry and must give its EORI number to the supplier. The Commission publishes, in English, a registration guide for non-EU operators (24 February 2026) and methodological and sector guidance documents (14 August 2026).

Does the UK CBAM apply to you too?

Yes, if you sell to UK importers. According to the GOV.UK CBAM page, updated 9 September 2026, the UK CBAM applies from 1 January 2027 to aluminium, cement, fertiliser, hydrogen, and iron and steel goods. Indirect emissions are not in scope at the start.

• It is a tax, due from the person importing the goods for commercial purposes.
• Businesses importing less than £50,000 of covered goods over twelve months are below the registration threshold.
• The importer uses actual verified emissions or a default value; an overseas producer is involved only if it chooses to supply its data.
• The Emissions and Verification Regulations 2026 (SI 2026/995), in force on 1 January 2027, require a verifier independent of the importer and the operator, accredited for the goods concerned, and a verification report per monitoring period.

A verification report issued under the EU CBAM does not, as it stands, count for the UK CBAM: neither SI 2026/995 nor the HMRC guidance published on 16 October 2026 provides for its reuse. Verification follows UK requirements and must be carried out by a verifier accredited for the UK CBAM by an accreditation body that is a full member of the Global Accreditation Cooperation (regulations 12 to 15); according to HMRC’s technical guidance, that body may take an existing accreditation into account, for example under Implementing Regulation (EU) 2018/2067. HMRC’s policy summary (updated 2 November 2026) states that the monitoring and verification methods are designed to support interoperability with the EU CBAM. Plan, therefore, for a UK CBAM verification report in addition to the EU one.

Are you ready for your customer’s CBAM data request?

• Goods exported to the EU and the UK are listed with their CN codes, and those in Annex I identified.
  
• Importing customers are known, with their authorised CBAM declarant status and deadline.
  
• Installation boundaries and production processes are drawn on a diagram.
  
• Purchased precursors are identified, with supplier and installation of origin.
  
• Fuels, materials, emission sources and electricity (cement, fertilisers) are metered with calibrated instruments.
  
• A monitoring plan exists, in English.
  
• Production and emissions data for calendar year 2026 are complete.
  
• One person owns the CBAM file and customer replies.
  
• Registration in the CBAM registry (O3CI) has been decided.
  
• Verification is scheduled with an accredited verifier.
  
• Any carbon price paid in the country of production is documented.
  

Several boxes empty: your customer is likely to declare default values for 2026.

How does the CBAM connect to your other EU requirements?

Through the same customers and often the same data.

• To reduce emissions, which lowers the embedded emissions declared: decarbonisation strategy.
• For the organisational inventory: carbon footprint under ISO 14064.
• For packaging: PPWR packaging compliance and the PPWR guide for non-EU exporters.
• For the supply chain: supply-chain due diligence and our article on the EUDR from 30 December 2026.
• For the overall view of ESG requests: ESG and CSR and our industry and energy sector page.
• For an environmental management system that frames data collection: ISO 14001 certification.

What ACG does for exporters under the CBAM

ACG works with manufacturers in Morocco, Africa and the Middle East, with 10 in-house consultants and more than 100 qualified external experts. On the CBAM, we start from your CN codes and customers, define the installation, draft the monitoring plan, calculate embedded emissions and prepare for verification. We do not verify and issue no attestation: an accredited verifier does.

Your teams can be trained on collecting and evidencing carbon data: see our training offer. To discuss your installation, contact us.