How does the EU CBAM impact overseas manufacturers?
The EU CBAM applies a carbon cost on carbon-intensive imports into the EU.
Since 1 January 2026, EU businesses importing over 50 tonnes of in-scope goods are required to comply with CBAM requirements. This includes registering as a CBAM Authorised Declarant and submitting annual CBAM declarations.
While the obligation and financial burden falls on the importer, a significant portion of the work actually falls on the overseas manufacturer, as they are the only party able to collect the required emissions data.
There are two main types of CBAM data:
- Actual emissions data: monitored at the source by the manufacturer and verified by an accredited third party.
- Default values: provided by the European Commission to be used as a last resort when actual data is unavailable.
The framework is designed to incentivise the use of actual emissions data, while the use of default values can result in a higher CBAM liability for importers.
As a result, EU importers are increasingly asking their overseas suppliers for verified emissions data.
However, this can represent a significant new administrative and technical challenge for manufacturers operating in countries where carbon reporting and pricing requirements are less developed. This has led to a growing amount of confusion, which the EU Commission is trying to address through its guidance documents.
What’s included in the EU Commission’s guidance?
The EU Commission has structured its guidance in an accessible manner, splitting it into five key areas:
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- Introduction to CBAM concepts
- Quick guide for non-EU operators on CBAM implementation
- CBAM methods for calculation of embedded emissions
- CBAM calculation of the free allocation adjustment
- Sector-specific guidance
Together, these documents provide a clear step-by-step framework for understanding what CBAM means for manufacturers and how the required emissions data can be calculated and reported.
Collectively, the guidance provides practical support for manufacturers, helping them understand CBAM reporting requirements and the emissions data their customers may request.
Each guidance document is linked above so it can be shared directly with overseas suppliers to help them understand what their EU customers are asking them to provide.
How can Valpak help with EU CBAM compliance?
Valpak’s team of CBAM experts can support EU importers and their overseas suppliers with:
- Regulatory review and threshold confirmation
- Supplier engagement
- Embedded emissions data support
- Cost forecasting
- Supplier pre-verification support
- Full EU CBAM compliance
If your business is affected by the EU CBAM, now is the time to establish what data will be required and how it can be verified.
Visit our website or get in touch via our online enquiry form if you would like to book a consultation with our CBAM team.
Ready to prepare for EU CBAM?
If your business imports CBAM goods into the EU or supplies manufacturers that do, now is the time to establish what emissions data will be required and how it can be verified.
Speak to our specialists about EU CBAM compliance support, supplier engagement and embedded emissions data collection. We can help you understand your reporting obligations, prepare emissions data and assess potential CBAM costs before your next reporting cycle.
