EU CBAM for producers and exporters outside the EU: registration, verification and who pays

If you make steel, aluminium, cement, fertilisers, hydrogen or electricity outside the EU and sell them to EU buyers, the Carbon Border Adjustment Mechanism (CBAM) makes your buyers pay for the emissions in those goods, not you 31415. What you can do is register your installations in the CBAM registry, have your emissions checked by an accredited verifier and share the results with your buyers 4. Without your data, your buyers declare default values: for goods other than electricity, standard figures set per exporting country with a mark-up, while electricity has default values of its own 1617. The rules are in the CBAM Regulation (Regulation (EU) 2023/956), as amended by Regulation (EU) 2025/2083 4. Our CBAM hub explains the mechanism as a whole.

Does EU CBAM apply to me if I produce or export outside the EU?

CBAM applies to your goods, not to your company: it covers the goods listed in its Annex I that originate outside the EU when they are imported into the EU 23. Annex I lists cement, electricity, fertilisers, iron and steel, aluminium and hydrogen, each identified by its Combined Nomenclature (CN) code, the EU's customs product code 3. Where goods originate is decided by the EU's customs rules on non-preferential origin 2.

The only countries outside the scope are Iceland, Liechtenstein, Norway and Switzerland, plus five territories: Büsingen, Heligoland, Livigno, Ceuta and Melilla 218. So CBAM applies to goods from India, as it does to goods from every other country that Annex III doesn't list 218.

The Regulation calls a producer outside the EU an "operator": any person that operates or controls an installation outside the EU, including a parent company that controls one 1. An installation is a stationary technical unit where a production process is carried out 1. Our reading: the operator duties in this guide bind only operators that register, because Article 10 sets them for an operator that has asked to be registered. An exporter that only trades the goods has no role of its own in the Regulation; the data your buyers can use comes from the operator of the installation 4.

Who pays for CBAM, the importer or the exporter?

Law: the authorised CBAM declarant in the EU buys and surrenders the CBAM certificates, one for each tonne of CO₂ equivalent (CO₂e) embedded in the goods 115. An authorised CBAM declarant is an importer, or an indirect customs representative (a representative that lodges the customs declaration on the importer's behalf), that holds this status, granted by a competent authority: the authority each EU country designates under the Regulation 15. The importer is the person that lodges the customs declaration, or the client of an indirect customs representative that lodges it 1. The Regulation puts no duty to surrender certificates on a producer or exporter outside the EU 415.

Our reading: whether your buyer passes the cost back to you through the price is a commercial question the Regulation doesn't settle. What the law does tie to you is your data: verified actual emissions replace default values in your buyer's count, and a carbon price effectively paid at home can lower the number of certificates your buyer has to surrender 4816.

If the customs declaration for the goods is lodged in your name, or for you by an indirect customs representative, you are the importer 1. A company not established in the EU must then import through an indirect customs representative that holds the status of authorised CBAM declarant, even under the 50-tonne exemption, and the representative takes on the CBAM obligations for those goods 519. Our guide to the authorised declarant status explains that route.

From 21 September 2027, a new Union Customs Code (Regulation (EU) 2026/2108) applies and repeals the current one, Regulation (EU) No 952/2013 2021. Its Article 33(3) says that an indirect customs representative acting in its own name on behalf of an importer not established in the EU's customs territory "shall be considered to be the importer" for the purposes of its Article 27(2) 2223. Article 27(2) lists what the importer must do towards customs, such as ensuring payment of customs duties 23.

What happens if I don't share my emissions data?

Your buyers declare your goods with default values instead of actual emissions 16. For goods other than electricity, default values are set at the average emission intensity of each exporting country for each good, increased by a mark-up 17. When reliable data for the exporting country can't be applied, they are based on the average of the 10 exporting countries with the highest emission intensities for that good 17. For electricity, default values are set at the CO₂ emission factor of the country or region where it was produced or, where no such value is available, at the EU's CO₂ emission factor 17. The CO₂ emission factor is the weighted average CO₂ intensity of electricity produced from fossil fuels in an area 17.

You don't have to register for your buyer to use actual emissions. The declarant must have actual emissions checked by an accredited verifier, and may use the verified data a registered operator shares with it 7. When the operator isn't registered, the verifier sends the verification report to the operator by other means than the registry 24. Our explainer on default values and actual emissions shows how both are calculated.

How do I register as an operator in the CBAM registry?

The Commission registers you and your installations in the CBAM registry when you ask it to 4. The registration rules have applied since 31 December 2024 25. Operators reach the registry through the CBAM Operators Portal, which is open from the internet, and request access through the Commission's EU Access central service 13.

First you ask the Commission for a profile on the portal. The request comes with documents showing your company's legal registration or proof of activity in your country, with its name, address, contact information and national registration number, plus evidence that the person asking may act for the company and proof of that person's identity 13. Commission guidance, not law: every user needs an EU Login account with two-factor authentication, and the documents go in as a single PDF, preferably in English, with a courtesy translation next to the originals 26.

Then you request the registration itself. It must contain 4:

• ☐ The name, address, corporate or activity registration number and contact information of your company and, if applicable, of the entities that control it, including the parent company, with supporting documents 4
• ☐ The location of each installation: its complete address and its geographical coordinates in longitude and latitude, to six decimals 4
• ☐ The main economic activity of each installation 4

The Commission notifies you of the registration, which is valid for five years from that notification 4. You must tell the Commission without delay about any change to that information 4. You can ask to be deregistered at any time 4. The Commission can also deregister you if your information is no longer accurate, after giving you the chance to be heard 4.

What must I do once I'm registered?

A registered operator must do four things 4:

• Determine the embedded emissions of each type of goods made at the installation, by the calculation methods in Annex IV of the Regulation 4.
• Have those emissions verified by an accredited verifier, under the principles in Annex VI 4.
• Keep a copy of the verification report and the records needed to calculate the emissions for four years after the verification 4.
• Where it applies, determine the carbon price paid in your country and upload the documents and evidence 4.

Embedded emissions are the direct emissions from making the goods plus the indirect emissions from producing the electricity used in making them 1. Your records must be detailed enough for the emissions to be verified and for the authorities to review your buyers' declarations 4.

Who verifies my emissions, and when?

Only a verifier accredited by a national accreditation body of an EU country can verify your emissions 1127. A verification company established outside the EU can request accreditation from the national accreditation body of any EU country that provides it 28. Once accredited, a verifier must ask the competent authority of the EU country where its accreditation body is established to register it in the CBAM registry, within two months of accreditation but not before 1 September 2026, and it verifies your emissions through the registry 9.

Commission guidance, not law: "The first CBAM verifiers are expected to receive CBAM accreditation around September 2026", and the Commission says it will publish the list of accredited verifiers on its verification page 29. We haven't read that list, so we can't say which verifiers are accredited yet.

The verifier visits your installation in person unless the criteria for waiving the visit are met 30. Under the general conditions for these waivers, it can replace the physical visit with a virtual one, or skip it, when a verifier visited physically in the reporting period just before, the installation hasn't changed significantly, and the risk analysis allows it 1231. Skipping the visit also needs physical visits in the two reporting periods before 31. An installation that makes only electricity, and uses nothing that can emit greenhouse gases in normal operation, can have the visit skipped if a verifier visited physically at least once in the last five reporting periods and the same risk conditions are met 31. Apart from these routes, the verifier can switch to a virtual visit when serious, extraordinary and unforeseeable circumstances outside your control prevent a physical one 1232. Our reading: the first verification of an installation therefore includes a physical visit, unless such circumstances prevent it 3132.

The verifier checks your emissions report against your installation's monitoring plan and the calculation rules, and it must make sure you give it access to your sites 24. A misstatement counts as material above 5% of the total specific embedded emissions, per tonne of each good by CN code 33. The report can be verified as satisfactory only when it is free from material misstatements 24.

From 1 January 2027, the verifier issues the verification report in the CBAM registry, in English 24. If you are registered, the report reaches you through the registry 24. Your buyers submit their CBAM declaration by 30 September each year, the first time in 2027 for 2026 6.

How do I share verified data with my EU buyers?

You can disclose your verified emissions and the carbon price you paid to an authorised CBAM declarant, which may then use them to meet its own verification obligation 47. Sharing is your choice 4. Under the registry act, declarants can access the personal data you registered only where you have authorised it 34.

Commission guidance, not law: through the registry's portal for non-EU operators, you upload your installation and emissions data once and share them with your buyers, instead of sending them to each buyer separately 26. For this to work, your buyers need to give you their Economic Operators Registration and Identification (EORI) number, the EU customs number, outside the registry 26.

Wrong data has a consequence for your buyer. If a declarant surrenders too few certificates because an operator or a verifier gave it incorrect information, the competent authority can reduce its penalty 35. The penalty itself falls on the declarant 35.

Does a carbon price I pay at home count?

Yes, if it was effectively paid. Your buyer can claim fewer certificates for a carbon price effectively paid in your country on the declared emissions, when it declares actual emissions 8. A carbon price is an amount paid under a carbon emissions reduction scheme, as a tax, levy or fee or as allowances in an emissions trading system 1. Any rebate or other compensation available in your country that would lower that price is taken into account 8.

The proof needs a third party. The documentation must be certified by a person independent from the declarant and from your country's authorities, and there must be evidence that the price was actually paid 8. As a registered operator, you determine the carbon price paid and upload the documents and evidence; you keep the documentation until the end of the fourth year after the year the independent person certified it 4. The registry act has independent persons register in the CBAM registry from 1 December 2026 at the earliest 13.

With default values, your buyer can only claim a reduction by reference to yearly default carbon prices 8. From 2027, the Commission may make such default carbon prices available in the CBAM registry for countries with carbon pricing rules 8.

Will my company's details be public?

Some of them, unless you opt out. Your name, address, registration number, contact information and the location of your installations are public, but you can choose not to make them accessible to the public 10. The rest of the information in the registry, including your emissions data, is confidential 1034.

What would the pending proposal change?

Pending, not law: Commission proposal COM(2025) 989 would make operator registration the route for actual emissions 36. A declaration based on actual emissions would use emissions "provided by the operator via the CBAM registry", and could have to include evidence that the goods were produced at the declared installation at the declared time 36. Operators could share only a summary of their data, and share it with another operator as well as with declarants 36. As proposed, three of the operator changes would apply from 1 January 2028: the new wording of the registration rule, a new duty to make sure that, where conditions are set for using actual emissions for a combination of goods and origins, they are met, and sharing with another operator 36. The declaration wording and the summary option carry no such date, so they would apply from the amending regulation's entry into force 36. Our Decode on the downstream proposal follows it.

What to do

1. Check whether you make CBAM goods: find their CN codes in Annex I of the Regulation 3. If your goods originate in a country Annex III lists, CBAM doesn't apply to them 218.
2. Decide whether to provide actual emissions 416.

• If you want your buyers to declare your actual emissions, you can register your company and installations in the CBAM registry. Once registered, you must determine and have verified the emissions of each type of goods, and keep the records for four years.
• Or you can provide none, and your buyers declare default values.

1. If you register, choose a verifier accredited for CBAM in the EU and plan for its visit to your installation 430.
2. If you pay a carbon price at home, collect the evidence of payment and have the documentation certified by an independent person 48.
3. Agree with your buyers how you share your data, and ask for their EORI number if you share through the registry 426.
4. If you import the goods into the EU yourself and aren't established there, use an indirect customs representative that holds the status of authorised CBAM declarant 5.

This is general information, not legal advice. For decisions about your company, check with a lawyer or adviser.