The first annual CBAM declaration is soon away.
CBAM is the EU's carbon border tax on imports of steel, aluminium, cement, fertilizers, hydrogen and electricity. From September 30, 2027, every EU importer above 50 tonnes per year owes a financial declaration backed by verified emission data. This page explains what's actually at stake, why the data layer is the real bottleneck, and how to prepare.
Who's concerned, and how much it costs
50 tons/year
Net mass threshold per importer per year. Below: exempt. Above: full declaration, certificates to surrender, third-party verification.
6 sectors
Steel, aluminium, cement, fertilizers, hydrogen, electricity. Processed products (cars, machinery containing CBAM materials) expected 2026 to 2027, multiplying the affected company base by roughly 10x.
+20 to 30%
Punitive markup of EU default values versus your supplier's actual emissions, rising to 20-40% by 2030. The default is not an option, it is a fine designed to push importers towards verified data.
The real problem isn't the calculation. It's the data.
The CBAM formula is simple and public. Embedded emissions multiplied by ETS price, minus carbon already paid in the producing country (Article 9), minus the EU free allocation still granted to domestic competitors.
What is hard is getting the embedded emissions from a Turkish steel mill, an Indian cement plant or a Chinese aluminium smelter. They do not track CO₂ per tonne in CBAM categories. They send PDFs of energy bills in their native language, with no audit trail.
And even when you collect the data, you have to prove it to an accredited EU verifier. That is where the math really breaks down.
The math doesn't work. Unless you change the math.
50K
non-EU industrial installations need to be verified by accredited bodies to deliver actual emission data instead of punitive defaults.
300
accredited verifiers exist in the EU today. Even doubling the number to 600 does not close the gap.
8h
average audit time per installation, on-site. Roughly 250 audits per verifier per year, far below CBAM demand at current productivity.
CBAM is physically unenforceable without a 4× productivity jump per audit. Implementing Regulation IR 2025/2546 (December 2025) unlocked remote verification when documentary proof is sufficient. That is what audit-ready Data Packs are for.
Four steps to be ready, before your first declaration
Map your CBAM-exposed imports
Pull your last 12 months of customs declarations. Flag every CN code in Annex I (steel, aluminium, cement, fertilizers, hydrogen, electricity). Compute net mass per origin country. Above 50 tons/year per importer puts you in CBAM scope.
Identify your top-exposure suppliers
Rank suppliers by tonnage multiplied by EU default value. Your top 5 suppliers usually represent 80% of your CBAM cost. Start data collection there, not everywhere at once.
Build the documentary chain
Energy bills, production logs, fuel receipts, mass balances, IPCC factors used. Every value in your declaration must trace back to a source document with a date, page, and quantity. This is what a verifier asks for.
Plan for remote verification
On-site audits don't scale. IR 2025/2546 (December 2025) allows remote verification when documentary proof is complete. Structure your data so a verifier can sign off in 2 hours instead of 8 hours on-site.
Ready to collect your supplier data?
Excert turns the documents your non-EU suppliers send into verified, audit-ready packs, replacing punitive default values with verified numbers.
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