CBAM for Indian exporters, at the consignment level.
Your EU buyer needs embedded emissions per tonne of what you shipped, per production route, per installation. Not a company average. This is what they will ask for, and what your plant has to be able to produce.
The EU Carbon Border Adjustment Mechanism (CBAM) puts a carbon price on embedded emissions in cement, iron and steel, aluminium, fertilisers, electricity and hydrogen imported into the EU. It entered its definitive period on 1 January 2026, so covered imports now carry a cost rather than only a reporting duty. The declarant of record is the EU importer, and importers below 50 tonnes of covered goods a year are out of scope. The first declaration falls due on 30 September 2027 and covers calendar-year 2026 imports, with CBAM certificate sales opening on 1 February 2027. For an Indian exporter, the obligation is practical rather than legal: the EU buyer cannot declare embedded emissions you have not given them, per consignment, per installation and per production route.
Where CBAM stands today
CBAM 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.
Which goods CBAM covers, and who has to report
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. The Commission proposed extending coverage to a further tranche of steel-intensive and aluminium-intensive downstream products on 17 December 2025, with application proposed for 1 January 2028. That proposal is still in the legislative process and is not law yet.
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. A de minimis threshold applies at the importer level: an EU importer bringing in less than 50 tonnes of cement, iron and steel, fertilisers and aluminium in a calendar year falls outside the declaration requirement. The threshold does not apply to electricity or hydrogen. It is worth establishing early with smaller buyers before you build reporting for a consignment nobody will declare.
What CBAM reporting requires from an Indian exporter
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 CBAM example: two routes, one CN code
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 CCTS carbon price you already pay counts against CBAM
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 sectors carrying binding targets. 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 for CBAM, CCTS and BRSR
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.
What CBAM software has to get right.
Four things a general-purpose carbon accounting platform does not do. Carbon-OS holds plant data at the granularity CBAM needs, so declarations are produced rather than reconstructed.
01 · Map the exposure
Export lines screened by CN code and destination so you know which consignments carry an obligation and which do not.
CN-code screening02 · Meter the routes
Fuel, power and process inputs allocated per installation and per production route, month by month.
Per-route allocation03 · Carry the precursors
Supplier-declared embedded emissions collected against the input materials they belong to, with the evidence attached.
Supply-chain data04 · Issue to the importer
A per-consignment emissions statement your EU buyer can lodge, with the calculation open behind it.
Declaration-readyCBAM questions, answered straight.
Does CBAM apply to the Indian exporter or to the EU importer?
Legally, to the EU importer. They are the declarant of record and they buy and surrender the certificates. Practically, to you, because the importer cannot declare embedded emissions you have not supplied, and the fallback in the absence of your data is a default value that is usually worse than your real number.
When is the first CBAM declaration due?
30 September 2027, covering calendar-year 2026 imports. Sales of CBAM certificates open on 1 February 2027. The definitive period itself started on 1 January 2026, so the emissions being generated at your plant now are the ones that will be declared.
Which goods does CBAM cover?
Cement, iron and steel, aluminium, fertilisers, electricity and hydrogen, plus a defined list of downstream goods, all identified by CN code rather than product name. A further tranche of steel-intensive and aluminium-intensive downstream products was proposed for inclusion on 17 December 2025, with application proposed for 1 January 2028. That proposal has not been adopted.
Is there a threshold below which CBAM does not apply?
Yes. An EU importer bringing in less than 50 tonnes of cement, iron and steel, fertilisers and aluminium in a calendar year falls outside the declaration requirement. It does not apply to electricity or hydrogen. The threshold sits with the importer, not with you, so it is worth confirming per buyer before building reporting for a consignment that will never be declared.
What does CBAM software actually need to do?
Four things a general carbon accounting platform does not. Screen export lines by CN code so obligation is decided before the shipment leaves. Allocate fuel, power and process inputs per installation and per production route rather than per company. Carry supplier-declared precursor emissions against the input materials they belong to. And produce a per-consignment statement in the format the EU importer lodges, with the calculation open behind it.
Can a company-wide carbon footprint be used for CBAM?
No. CBAM is calculated per tonne of product, per installation, per production route. A company average fails on all three counts, and where two routes share a CN code it actively overstates the cleaner route and hands your buyer a border cost you did not need to hand them.
Can we deduct the carbon price we pay in India?
Yes, where a carbon price has genuinely been paid on the production of the exported goods and it can be evidenced. For obligated entities under CCTS this is a direct reason to keep the CCTS number and the CBAM number reconciled, since both are calculated from the same activity data.
What happens if we do not provide emissions data to our buyer?
The importer falls back on default values. Defaults are set conservatively, so the border cost rises and it lands in the commercial conversation with your buyer as a price problem rather than a data problem.
Does CBAM require third-party verification of our figures?
In the definitive period embedded emissions are to be verified by an accredited verifier. That is one more reason the underlying records, meter readings, weighbridge slips, purchase invoices, have to be retrievable per production period rather than assembled after the fact.
How do CBAM and CCTS fit together for an Indian exporter?
They share the source data and differ in granularity. CCTS wants intensity per obligated installation on a sector output metric. CBAM wants embedded emissions per product per route per consignment. Building to the CBAM level gives you the CCTS number as an aggregation. Building only to the CCTS level leaves CBAM unanswerable.