CBAM for Indian exporters, at the consignment level.

Where CBAM stands today

The EU Carbon Border Adjustment Mechanism entered its definitive period on 1 January 2026. Embedded emissions in covered goods now carry a price at the EU border rather than only a reporting duty. The first declaration falls due on 30 September 2027 and covers calendar-year 2026 imports, which means the data being generated on your shop floor right now is the data that will be declared.

That timing is the whole problem. Emissions data cannot be reconstructed a year later from memory and a stack of invoices. If it was not captured per batch, per furnace, per month, it will be estimated, and estimates are the expensive option at the border.

Covered goods

CBAM applies to imports into the EU of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen, along with a defined list of downstream goods within those categories. For Indian exporters the exposure concentrates in steel and aluminium products, followed by cement and fertilisers.

Coverage is defined by CN code, not by product name. The first check on any consignment is whether its CN code sits in the covered list, because that decides whether an emissions figure has to travel with the shipment at all.

What the EU importer actually needs from you

The declarant of record is the EU importer, but they cannot declare anything you have not given them. In practice they will come back with a request for the following, per consignment.

Data point	Granularity	Why it is asked for
Installation identity	Per production site	Emissions are attributed to the installation that made the goods, not to the exporting company
CN code and quantity	Per consignment line	Determines coverage and the tonnage the emissions are multiplied against
Direct embedded emissions	Tonnes CO2e per tonne of product	Fuel combustion and process emissions attributable to the production route
Indirect embedded emissions	Tonnes CO2e per tonne of product	Electricity consumed in production, with the factor and source stated
Precursor emissions	Per input material	Embedded emissions carried in inputs such as pig iron, clinker or alumina
Production route	Per process	Blast furnace and electric arc routes give materially different figures for the same CN code
Carbon price already paid	Per tonne, with evidence	Any carbon price paid in the country of origin can be claimed against the border adjustment

A worked example

Take a steel exporter running two routes at one plant. The blast furnace line and the electric arc line share a CN code on the export invoice but do not share an emissions profile. If you report a plant-wide average, the arc-route consignments carry the blast furnace's emissions and your buyer pays a border cost you did not need to hand them.

Getting this right means allocating monthly fuel, electricity and process inputs to each route, dividing by that route's saleable output for the month, and carrying precursor emissions in with the pig iron or scrap you bought. It is not conceptually hard. It is a data-plumbing problem: the meter readings, the weighbridge slips and the purchase records have to land in one place, keyed to the same production period.

The carbon price you already pay counts

India's Carbon Credit Trading Scheme is now operating, with the first annual emissions report due to BEE on 31 July 2026 for roughly 490 obligated entities across seven notified sectors. Where a carbon price has genuinely been paid on the production of exported goods, that can be set against the CBAM obligation, provided it can be evidenced. Exporters in notified sectors therefore have two reasons to hold clean per-installation data, and only one dataset to build.

One data layer, three regimes

The activity records that produce CBAM embedded emissions are the same records behind your CCTS report and your BRSR Core Scope 1 and Scope 2 intensity. The difference is granularity: BRSR Core wants it per entity per year, CCTS wants it per obligated installation, CBAM wants it per product per route per consignment. Build to the finest of those and the other two are aggregations. Build to the coarsest and CBAM cannot be answered at all.

Our compliance timeline lays out how these dates interact over the next two years.