Does CBAM apply to producers outside the EU?
Not directly. The CBAM obligations (the authorisation, the annual declaration and the certificates) fall on the EU importer, the authorised CBAM declarant. But an importer can only declare a producer's actual emissions if the producer supplies them, verified. Without them the importer has to use the EU's default values, which include a mark-up that, for most CBAM goods, increases until 2028, so importers increasingly ask the producers they buy from for verified data.
What do importers need from a producer?
For each good and installation, an importer declaring actual emissions needs:
- the installation's name, location and operator;
- the specific embedded emissions of the good, in tonnes of CO₂e per tonne: direct emissions, and indirect emissions too for cement and fertilisers;
- the production route the good was made by;
- the specific embedded free allocation (SEFA) that goes with those emissions, which the importer needs to work out the free allocation adjustment;
- the verification report from an accredited verifier;
- where a carbon price was paid in the country of production, the amount net of rebates or other compensation and the evidence of payment, certified by an independent person.
Producers can pass this information to importers through Kariqa.
How are the emissions determined and verified?
The operator of the installation monitors its emissions and determines the embedded emissions for each type of good it produces, following the methods in Implementing Regulation (EU) 2025/2547. A verifier accredited under the CBAM rules by an EU national accreditation body then checks them and issues a verification report. Importers can only rely on actual emissions once they are verified.
Do producers have to register in the CBAM Registry?
No. Registration is voluntary: an operator of an installation outside the EU can ask the Commission to register it and its installations in the CBAM Registry, and the registration lasts five years. A registered operator can share its verified emissions with importers directly in the Registry, and must keep the verification report and the records behind the figures for four years after each verification.
Producers do not need to be registered for importers to use their data. They can share it with their importers through Kariqa, and the importer includes the verification reports with the CBAM declaration.
What happens if a producer shares nothing?
The importer uses default values for that producer's goods. Default values are country averages plus a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 (1% for fertilisers), so they usually cost the importer more than the installation's verified figures would. Default values or actual emissions compares the two.
When do importers need the data?
Importers declare each year's imports by 30 September of the following year, so they need verified data for the goods they imported before then, with time to check it. The first declaration, for imports in 2026, is due by 30 September 2027. The CBAM deadlines page lists the dates.