EU CBAM guide for Indian exporters

What is CBAM?

CBAM is the EU’s way of applying the same carbon price to imported goods that EU producers pay under the EU Emissions Trading System. EU importers of covered goods must account for the greenhouse-gas emissions embedded in those goods and, from the definitive phase onward, surrender CBAM certificates to cover them.

Which goods are covered?

• Iron and steel (including many downstream articles such as screws, bolts, tubes and structures)
• Aluminium
• Cement and clinker
• Fertilisers
• Hydrogen
• Electricity

Coverage is defined by customs (CN) codes, so the first step is always to map your exported products to the codes in scope.

Timeline

• October 2023 – December 2025: transitional period. Importers reported embedded emissions quarterly, with no payment.
• From 1 January 2026: definitive period. Imports must be made by authorised CBAM declarants, who account for embedded emissions and will need to surrender certificates.
• 2027: the first annual CBAM declaration, covering 2026 imports, and the start of certificate sales.

Simplifications adopted in 2025 exempt importers bringing in less than 50 tonnes of covered goods per year — but most of your EU customers will be above this threshold in aggregate.

Why it matters to you as the exporter

The legal obligation sits with the EU importer, but the importer depends on your installation data. If you can’t provide verified actual emissions, they must use default values set by the European Commission — which are designed to be conservative and will usually cost more. That turns CBAM into a pricing and supplier-selection issue for you.

Any carbon price effectively paid in the country of production can be deducted — relevant as India’s own Carbon Credit Trading Scheme develops.

What your EU buyers will ask for

1. Installation details and the production route for each product
2. Direct (and, where relevant, indirect) embedded emissions per tonne of product
3. Emissions embedded in precursors you buy in (e.g. pig iron, clinker, unwrought aluminium)
4. The monitoring methodology used, and evidence behind each number
5. Verification by an accredited verifier during the definitive period

A practical 5-step plan

1. Scope: map exported products to CN codes and identify the installations that make them.
2. Boundaries: define production processes and system boundaries for each installation.
3. Data: collect fuel, electricity, process and precursor data — including from your suppliers.
4. Calculate: compute specific embedded emissions per product, with a documented methodology.
5. Communicate & verify: complete the EU communication template for each importer and prepare for verification.

Airenvo’s CBAM & export compliance service covers each of these steps.