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What is CBAM, and what does it mean for Indian exporters?

CBAM puts a carbon price on EU imports of steel, aluminium and other goods from 2026. Key dates, the data exporters must provide, and why traceability matters.

Quick answer

CBAM, the EU Carbon Border Adjustment Mechanism, puts a carbon price on imports of iron and steel, aluminium, cement, fertilisers, electricity and hydrogen into the EU. Its definitive period began on 1 January 2026. Importers must declare the embedded emissions of goods, using data from the producing installation, and buy CBAM certificates to cover them.

Updated 30 October 2026. Written by the Ajinkya Technologies engineering team, reviewed by Amey Kadle.

CBAM explained

CBAM ran a transitional reporting phase from October 2023 to the end of 2025. From 1 January 2026, importers bringing in covered goods above a de minimis threshold of 50 tonnes a year need to be authorised CBAM declarants. The first annual declaration, covering 2026 imports, is due by 30 September 2027, and CBAM certificates go on sale from February 2027.

The embedded emissions must be calculated per production installation, ideally from actual, verified data supplied by the producer. Where actual data is missing, default values apply, and these are generally set conservatively, which can make goods more expensive for the importer. That creates a commercial reason for exporters, including Indian steel and aluminium producers, to supply credible installation level data.

For a producer this is a traceability and data problem as much as an environmental one. Energy, fuel and material inputs need to be measured and allocated to products, and those products linked to the shipments that go to each EU customer. Plants that already track heats, batches and dispatches digitally can attach emissions data to the same records; plants that rely on paper and spreadsheets will find it hard to produce verifiable figures.

Key concepts

  • •Covers iron and steel, aluminium, cement, fertilisers, electricity, hydrogen
  • •Definitive period from 1 January 2026
  • •50 tonne per year de minimis for importers
  • •First declaration for 2026 imports due 30 September 2027
  • •Installation level data beats default values

Questions

Does CBAM apply to Indian exporters?

The legal obligation falls on the EU importer, but importers need emissions data from the producing installation. Indian exporters who can provide credible data help their customers avoid conservative default values.

When do CBAM payments start?

The definitive period began on 1 January 2026. CBAM certificates go on sale from February 2027, and the first annual declaration for 2026 imports is due by 30 September 2027.

What data does an exporter need for CBAM?

Embedded direct and relevant indirect emissions per installation and product, based on measured energy, fuels and inputs, ideally verified, and linked to the goods shipped.

References

  • European Commission: Carbon Border Adjustment Mechanism (opens in a new tab)
  • German Emissions Trading Authority (DEHSt): the CBAM definitive regime from 2026 (opens in a new tab)

How we help with CBAM

We build the production and dispatch traceability layer CBAM reporting depends on, linking heats, batches and energy data to shipments; we do not provide emissions verification.

Read the GS1 and EU traceability guideSee the service

Traceability rules by industry, with dates and sources, and how to build for them.

Related terms

What is Digital Product Passport?The EU Digital Product Passport (DPP) is a digital record attached to a product through a data carrier such as a QR code, giving access to information about its materials, origin, environmental performance, repair and recycling. It is required by the Ecodesign for Sustainable Products Regulation, product group by product group, with batteries the first through their own regulation.What is Heat number?A heat number is the unique identifier a steel plant gives to one melt (heat) of steel from a furnace. Every slab, billet, coil, plate or bar made from that melt carries the heat number, which links it to the chemical composition and mechanical test results recorded on the mill test certificate.What is Mill test certificate?A mill test certificate (MTC), also called a mill test report, is the quality document a steel producer issues to certify that a product meets its specification. It lists the heat number, chemical composition, mechanical properties such as yield and tensile strength, and the standard and grade, and travels with the material to the buyer.What is Manufacturing traceability?Manufacturing traceability is the ability to follow a product, its parts and its materials through production and the supply chain. Backward traceability finds where a finished item came from; forward traceability finds where a material or batch went. It relies on unique identifiers, recorded events at each step and data partners can share.

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