CBAM does not charge an exporter directly. The EU importer is the one who registers, declares and buys certificates. Those are counted on the emissions of the installation that made the goods. So the importer needs the exporter's data, and the cost of missing data lands on the exporter's price.
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 country. A mark-up comes on top: 10% in 2026, 20% in 2027, 30% from 2028. Default values are set high on purpose, so that real data pays.
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:
| Exporting country | Default with 2026 mark-up, tCO2e/t | Certificates | Cost to the buyer |
|---|---|---|---|
| India | 4.708 | 118 | €8,883 |
| Rest of world | 4.454 | 112 | €8,431 |
| China | 3.506 | 88 | €6,625 |
| Ukraine | 2.731 | 69 | €5,194 |
| Türkiye | 2.671 | 67 | €5,044 |
| Vietnam | 2.585 | 65 | €4,893 |
| South Korea | 2.330 | 59 | €4,442 |
| United States | 1.540 | 39 | €2,936 |
That is €5 to €9 per tonne of steel in 2026. It is small this year because only 2.5% of the emissions are charged. The share rises every year:
| Year | CBAM factor | Buyer's cost per 1,000 t from India, default value |
|---|---|---|
| 2026 | 2.5% | €8,883 |
| 2027 | 5% | €19,347 |
| 2028 | 10% | €41,931 |
| 2030 | 48.5% | €203,181 |
By 2030, an Indian mill with no data adds about €203 per tonne to its buyer's cost. A competing mill with verified emissions of half the default carries no mark-up and saves the same buyer about €125 a tonne. Buyers compare offers on that basis.
The data your buyer will request
The EU importer needs, per installation and per product:
- 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 cannot 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
- 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 with the CBAM factor every year.
- An installation dirtier than the default should not rush to verify. The buyer can use the default, and the verified number would cost it more. That will not 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 plan for the next 12 months
- List every product sold into the EU by CN code, and check each against the CBAM CN code list.
- 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.
- Set up monitoring to the EU method at the installations that ship to the EU.
- Book an accredited verifier before the first declarations in 2027 fill their calendars.
- 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.
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. Costs computed on 16 September 2026 with the CBAM Data engine.