The CBAM definitive period has begun: what should manufacturers exporting to the EU do in 2026?

The European Union's Carbon Border Adjustment Mechanism (CBAM) entered its definitive period on 1 January 2026. During the transitional period, from October 2023 to the end of 2025, EU importers only filed quarterly reports. Now emissions are verified, and the first annual declaration and surrender of CBAM certificates for 2026 imports takes place in 2027.

On paper the obligation lies with the importer in the EU. But the only party that can produce the figure the importer declares is you: the manufacturer. So in 2026, every company shipping iron and steel, aluminium, cement, fertilisers, hydrogen or electricity to the EU faces the same question: what are the embedded emissions of my product, and how do I pass them on to my buyer?

What are embedded emissions and SEE?

Embedded emissions are the greenhouse gases released while producing a good. Under CBAM they are requested as specific embedded emissions (SEE): tonnes of CO₂e per tonne of product. SEE has two parts:

• Direct emissions: fuel combustion and process emissions at the installation (for example calcination in clinker production).
• Indirect emissions: emissions from the electricity consumed in production.

The embedded emissions of precursors (inputs that are themselves CBAM goods, such as clinker for cement or crude steel for steel tubes) are added too. If you make the precursor yourself, the chain is built inside the installation; if you buy it, you need the actual value from your supplier.

What happens without actual data?

When actual data cannot be provided, the default values published by the EU may be used. In the definitive period, however, a mark-up that grows over the years is added to these defaults. Because default values are deliberately conservative, an efficient installation that does not calculate its actual value passes an unnecessary cost on to its buyer, and that is a direct disadvantage in price negotiations.

Seven steps for manufacturers

1. Map your products to CN codes. Identify which 8-digit CN codes on the EU goods list are your products; routes and goods categories follow from this mapping.
2. Draw the installation boundary. Which equipment and buildings are inside, and which energy and material flows cross the boundary?
3. Define production processes. In multi-product installations, emissions must be attributed correctly to processes and products.
4. Choose the monitoring approach. Most installations use the calculation-based approach (activity data × emission factor); some sources use continuous measurement (CEMS).
5. Collect precursor data. Ask suppliers of purchased precursors for their actual embedded emission values.
6. Calculate SEE and report it to your buyer. Data has to be passed to the buyer with the method and in the form set by the EU.
7. Prepare for verification and record keeping. In the definitive period, data is checked by an accredited verifier and records must be kept for years.

Is a corporate carbon footprint the same as a CBAM calculation?

No, but one feeds the other. A corporate inventory under ISO 14064-1 or the GHG Protocol gives the company's total annual emissions (t CO₂e / year). CBAM works per product (t CO₂e / t product) and only covers certain emission sources. For example, fuel for company cars is Scope 1 in the corporate inventory but is not part of a product's CBAM embedded emissions.

The good news: the fuel, electricity and process data you collect for your corporate footprint is the raw material of the CBAM calculation. Instead of collecting data twice, you can produce two different outputs from the same source.

What does Carbonet do?

Carbonet's CBAM module transfers the emission data you enter for your carbon footprint to your installation's production processes, builds the precursor chain and calculates SEE. The result is calculated with the method set by the EU; checked against the example calculations published by the EU, the results match one-to-one.

If your EU buyer has asked, or is about to ask, for your data, request a demo and we will walk you through it with your own data.

Frequently asked questions

Is the CBAM obligation on the manufacturer or the importer?

The declaration and certificate obligation lies with the importer in the EU. The embedded emission value to be declared, however, is calculated by the manufacturer and passed on to the importer.

Which products are covered by CBAM?

Iron and steel, aluminium, cement, fertilisers, hydrogen and electricity, including certain products of these sectors listed by CN code on the EU goods list.

Can default values be used instead of actual data?

Yes, but in the definitive period a mark-up that grows over the years is added to default values. For efficient installations, actual values usually mean a lower cost.