What your EU buyer will ask for under CBAM
The emissions data, documents and verification EU importers request from non-EU suppliers, and how to prepare before the first declaration in 2027.
Checked against the EU rules on 6 October 2026.
Your EU buyer has to file an annual CBAM declaration and buy certificates for the emissions in what it imported. The first declaration, for goods imported in 2026, is due by 30 September 2027. To keep that bill low, buyers are writing to suppliers now. Here is what they ask for and why.
1. Specific embedded emissions per product
The core request is your specific embedded emissions (SEE): tonnes of CO2e per tonne of each product you sell them, by CN code and by installation. For iron, steel and aluminium this means direct emissions only, including those of the precursors you use.
2. Installation and production details
- Name, address and coordinates of the installation that made the goods.
- The production route and the products made in the reporting period.
- The precursors you bought, how much, from whom, and their embedded emissions.
Many buyers send the Commission's communication template, an Excel file, for you to fill in. Others use their own questionnaire or a supplier portal.
3. A verification report
In the definitive period from 2026, the importer can only use your actual figure if it has been verified by a verifier accredited in the EU. Without the report your buyer must fall back to the default with its mark-up, however good your data. Verification normally includes a visit to your plant, so plan early: verifiers get busier as the September 2027 deadline approaches.
4. Carbon price paid at home
If a carbon price was actually paid in your country on these emissions, the importer can deduct it. Most Indian exporters will have nothing to report here, but say so explicitly.
How to prepare
- Work out what the default costs your buyer with the cost calculator, so you know what is at stake per tonne.
- Collect a full year of fuel invoices, production registers and precursor purchase records.
- Ask your wire rod, billet or aluminium suppliers for their verified figures now.
- Talk to an accredited verifier about timing and fees.
Read next: default values or actual emissions.
General information for planning, not legal, tax or customs advice. See the disclaimer.