CBAM for exporters: what 1,000 t of steel costs your buyer

Under CBAM, a non-EU exporter pays nothing directly: the EU importer registers, declares and buys the certificates. Those certificates are counted on the emissions of the installation that made the goods, so the importer needs your data, and when you can't send it, the importer pays on the Commission's default value and prices that into your offer.

Who pays CBAM on exported goods

The EU side pays. CBAM is paid by the authorised CBAM declarant in the EU, usually the importer. But the bill depends on your mill's emissions, and a buyer choosing between suppliers will pick the one whose goods cost less to declare. That's why CBAM lands on the exporter's price even though the exporter never files anything.

CBAM default values by exporting country

Without verified emissions from the producer, an EU importer uses the Commission's default value for the CN code and the country of origin. A mark-up comes on top: 10% in 2026, 20% in 2027, 30% from 2028. The defaults are set high on purpose, so that real data pays.

Here's what that costs for hot-rolled steel coil, CN 7208 39 00, per 1,000 tonnes imported in 2026 on the default value, at the Q2 2026 price of €75.28:

That's €15 to €254 per tonne of steel in 2026. The buyer deducts 97.5% of the CBAM benchmark, 1.37 tCO2e per tonne for this code, and pays for every tonne of emissions above it. The benchmark doesn't change with the country, which leaves a high default paid almost in full. The deduction shrinks every year:

By 2030, an Indian mill with no data adds about €365.79 per tonne to its buyer's cost. A competing mill with verified emissions of half the default carries no mark-up, costs €108.03 a tonne, and saves the same buyer about €258 a tonne. Buyers compare offers on that basis. You can check any other code and origin in the CBAM calculator, and the default values guide lists the rows that changed on 31 July.

The CBAM data your EU buyer will ask for

Your EU buyer will ask for the embedded emissions of each product, per installation, backed by a verification report. In full, the importer needs:

• Installation name, address, country, and the production route used.
• Embedded emissions per tonne, direct and, for cement and fertilisers, indirect, calculated with the EU method for the reporting period.
• Emissions of the precursors used in the product, for example the crude steel inside a tube.
• A verification report from an accredited verifier. Without verification, actual values can't replace the default in the definitive regime.
• Any carbon price effectively paid in the country of production, with evidence, which the importer can deduct.

The Commission publishes a communication template, a spreadsheet for producers to pass this data to importers. Most buyers send it, or their own version of it.

Exporters who gain and exporters who lose under CBAM

An installation cleaner than its country's default gains, and one dirtier than the default loses once the mark-up rises.

• An installation cleaner than its country's default wins. The further its verified emissions sit below the default, the more its buyer saves. The saving grows as the mark-up on the default rises.
• An installation dirtier than the default shouldn't rush to verify. The buyer can use the default, and the verified number would cost it more. That won't last: the mark-up rises to 30% by 2028 to push everyone towards real data.
• The rest-of-world value can be higher than a named country's. A country with no row of its own takes the rest-of-world value. For CN 7208 that value is higher than China's.
• Downstream goods count. Screws, bolts, tubes, fittings and steel structures are in scope. A fastener exporter to the EU needs the emissions of the steel it bought, as well as its own.

A CBAM plan for exporters, the next 12 months

Start with your CN codes and your country's default, then get verified before the buyers' first declarations.

1. List every product sold into the EU by CN code, and check each against the CBAM CN code list.
2. Compare the default for your country with your own emissions. The CBAM calculator shows the default and the cost for any code and origin. The cost chart compares up to 4 countries from 2026 to 2034.
3. Set up monitoring to the EU method at the installations that ship to the EU.
4. Book an accredited verifier before the first declarations in 2027 fill their calendars.
5. Put the CBAM number in the offer. A verified value below the default is a price argument the buyer can check against the Commission's own table.

FAQ

Does CBAM apply to exports from India?

Yes, when the goods are in scope: iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. India's default for hot-rolled coil, CN 7208 39 00, is the highest in the table above, at 4.708 tCO2e per tonne with the 2026 mark-up.

Who pays CBAM, the exporter or the importer?

The EU buyer, or the authorised CBAM declarant acting for it, buys and surrenders the certificates. The exporter pays indirectly, through the price the buyer is willing to accept.

What is the CBAM communication template?

It's the Commission's spreadsheet for passing installation emissions from a producer to an EU importer. Most buyers send it to their suppliers, or send their own version of it.

Can a carbon price paid at home be deducted?

Yes. A carbon price effectively paid in the country of production can be deducted by the importer, as long as the exporter provides the evidence.

What happens if an exporter sends no data?

The importer declares on the default value for the CN code and country, plus the mark-up: 10% in 2026, 20% in 2027 and 30% from 2028.

Sources: Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083. Default values from Regulation (EU) 2026/1740. Certificate price from the Commission's price page. CBAM benchmarks from Implementing Regulation (EU) 2025/2620, Annex. Costs recomputed on 19 October 2026 with the CBAM Data engine.