CBAM 2026: How Asian Suppliers Can Provide Verifiable Embedded-Emissions Data to EU Buyers

Under CBAM’s definitive regime, Asian producers of steel, aluminium, cement, fertilisers and hydrogen can keep EU customers off punitive default values only by providing installation-level embedded-emissions data calculated with the EU methodology and checked by an accredited verifier. In practice, that means five things: a monitoring plan, records of fuel, materials and precursors, emissions allocated to the goods each buyer receives, a verification report, and a clear way to share the data, ideally through the EU’s registry portal for non-EU operators.

The timing is tight. Emissions embedded in 2026 imports must be declared by 30 September 2027, and the first verification reports can only be issued from January 2027 2. Suppliers that begin preparing now will be in a much stronger commercial position than those that wait for customers to chase them.

What has changed for suppliers in 2026

The transitional period (October 2023 to December 2025) was about reporting. Importers could lean on estimates, and supplier data was rarely checked. Since 1 January 2026, CBAM has a financial obligation attached. EU importers bringing in more than 50 tonnes of CBAM goods a year must be authorised declarants, and they will buy CBAM certificates, with sales opening in February 2027 1 3. The 50-tonne threshold introduced by the 2025 simplification package exempts most small importers but, according to the Commission, still captures about 99% of embedded emissions 7.

The rules for how suppliers calculate and prove their emissions are now in force. They sit in a set of implementing and delegated acts adopted in late 2025: Implementing Regulation (EU) 2025/2547 on calculation methods, Implementing Regulation 2025/2546 on verification principles, Delegated Regulation 2025/2551 on accreditation and verification, and Implementing Regulation 2025/2621 on default values 2 3.

Why default values are now a commercial problem

If an importer has no verified actual data, it must use default values. For the definitive period these are country- and product-specific, and they include a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 onwards. Fertilisers follow a gentler schedule 4.

For an EU buyer, the choice is simple: a supplier with verified data that is lower than the marked-up default reduces its certificate bill. Suppliers should expect verified CBAM data to become a factor in supplier selection and price negotiations. For efficient Asian producers, verified data is a way to show an advantage that defaults would otherwise hide. For less efficient producers, the default may be lower than their actual emissions, but relying on it leaves the buyer exposed to rising mark-ups and gives no route to improvement.

What the data package needs to contain

Suppliers do not file anything with EU authorities themselves. Their job is to give the importer data it can rely on and defend. A complete package for each installation usually includes:

Element	What it covers	Practical note
Installation details	Legal entity, site location, production processes, CN codes of goods produced	Must match what appears on customs declarations
Monitoring methodology	System boundaries, production routes, calculation approach, measurement equipment	Documented as a monitoring plan and kept up to date
Activity data	Fuels, raw materials, precursors, electricity, output volumes	Backed by invoices, meter readings and production records
Emission factors	Fuel and material factors and their sources	Deviations from standard factors need justification
Precursor emissions	Embedded emissions of purchased precursors such as clinker, pig iron or unwrought aluminium	Requires data from your own upstream suppliers
Specific embedded emissions	Tonnes CO₂e per tonne of each good	Direct emissions, plus indirect emissions where the regulation requires them
Carbon price paid	Evidence of any carbon price effectively paid in the country of production	Only relevant once deduction rules are final (see below)
Verification report	Opinion of an accredited verifier	Must accompany the importer’s declaration

Two technical points often cause errors. First, which emissions count depends on the product: under Annex II of the CBAM Regulation, only direct emissions count for goods such as iron, steel and aluminium, while indirect emissions from electricity also count for cement and fertilisers 6. Second, precursors matter. A rolling mill that buys in slabs, or an aluminium products maker that buys ingots, cannot report credible values without data from its own suppliers.

Verification: timing and choosing a verifier

Actual emissions only count in the definitive regime if an accredited verifier has verified them. National accreditation bodies in the EU and EEA accredit verifiers, and companies established outside the EU can apply to any accreditation body offering the service. The Commission expected the first accreditations, document reviews and site visits from September 2026, with verification reports issuable from January 2027 2.

Verifier capacity will be limited in the first cycle, especially for site visits in China, India, Vietnam and elsewhere in Asia. Suppliers should:

• confirm with their main EU buyers whether they intend to use actual values for 2026 imports;
• contact potential verifiers now, and check their accreditation scope for the relevant sector;
• prepare the monitoring documentation before the verifier arrives, since gaps found during a site visit take time to close;
• agree who pays for verification, as the cost is often shared or reflected in pricing.

Experience from domestic schemes helps but does not replace CBAM verification. Chinese steel, cement and aluminium producers covered by the national ETS already submit monthly emissions reports under Ministry of Ecology and Environment rules 10. That data is a strong starting point, but system boundaries, allocation to specific products and precursor treatment differ from the CBAM methodology, so it needs to be reconciled rather than copied across.

Sharing data through the O3CI portal

Rather than sending spreadsheets to every customer, non-EU operators can register in the CBAM registry through the Operators of Third Country Installations (O3CI) portal. Registered operators can record installation and emissions data and share it with declarants, who can then use it in their reports 5. Registration is voluntary and requires an access request and supporting documents, so allow time for approval.

For suppliers with many EU customers, the portal reduces duplicated requests and version-control problems. It also protects confidential process information better than email attachments. Suppliers that work with only one or two importers may still prefer to share data directly, but registering early costs little.

Carbon prices paid in Asia: do not count on a deduction yet

The CBAM Regulation allows importers to reduce their obligation where a carbon price has already been effectively paid in the country of production 3. The detailed rules, including proof of payment, currency conversion and third-party certification, were still at the draft implementing-act stage in mid-2026 8.

For producers under China’s national ETS or Korea’s ETS, this could eventually matter. But free allocation and low domestic prices limit the net carbon price actually paid, and the final rules are not yet adopted. Suppliers should keep clean records of allowances surrendered and payments made, without promising EU buyers a specific deduction.

Prepare for a wider scope

In December 2025 the Commission proposed extending CBAM to around 180 steel- and aluminium-intensive downstream products and tightening anti-circumvention rules. The Council agreed a broader general approach in June 2026, and the European Parliament voted on its position in September 2026 9. This is not yet law, and the final product list will come out of negotiations. Still, makers of fasteners, components, machinery parts and similar goods in Asia should expect data requests to reach them within the next few years.

A practical sequence for the next six months

1. Map exposure. List CN codes shipped to the EU, volumes and customers, and identify which installations produce them.
2. Engage buyers. Agree whether each customer needs actual values for 2026 and how data should be shared.
3. Build the monitoring plan. Document boundaries, production routes and data sources in line with Implementing Regulation 2025/2547.
4. Close precursor gaps. Request embedded-emissions data from your own suppliers of clinker, pig iron, slabs, ingots or similar inputs.
5. Book verification. Secure an accredited verifier and prepare for a site visit.
6. Register in O3CI. Set up the operator account and test data sharing with one customer.
7. Keep evidence of carbon costs. Record any domestic carbon price paid, pending final EU rules.

For suppliers already running wider decarbonisation work, CBAM data becomes a baseline for reduction projects. Our guide to launching a supplier decarbonisation programme in China covers that broader context. If you are preparing installation data for EU customers or reviewing supplier data as an importer, talk to our team.

Sources

1. European Commission, Taxation and Customs Union, “CBAM definitive regime”. https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en
2. European Commission, Taxation and Customs Union, “Verification of CBAM emissions”. https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-verification_en
3. German Emissions Trading Authority (DEHSt), “CBAM Definitive Regime from 2026”. https://www.dehst.de/EN/Topics/CBAM/CBAM-definitive-regime-2026/cbam-definitive-regime-2026_node.html
4. International Carbon Action Partnership (ICAP), “EU CBAM enters compliance phase and outlines path ahead”. https://icapcarbonaction.com/en/news/eu-cbam-enters-compliance-phase-and-outlines-path-ahead
5. European Commission, Taxation and Customs Union, “CBAM Definitive Registry (from 2026 onwards)”. https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-registry-and-reporting_en
6. Official Journal of the European Union, “Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism”, 10 May 2023. https://eur-lex.europa.eu/eli/reg/2023/956/oj
7. International Carbon Action Partnership (ICAP), “EU adopts simplifications of CBAM rules ahead of the compliance phase starting in 2026”. https://icapcarbonaction.com/en/news/eu-adopts-simplifications-cbam-rules-ahead-compliance-phase-starting-2026
8. European Commission, Taxation and Customs Union, “Carbon price paid in Third Countries”, 13 May 2026. https://taxation-customs.ec.europa.eu/news/carbon-price-paid-third-countries-2026-05-13_en
9. European Parliamentary Research Service, “Extension of CBAM scope to downstream goods and anti-circumvention measures”, September 2026. https://eprs.europarl.europa.eu/contents/publications/EPRS/2026/09/EPRS_ATA(2026)791461.html
10. International Carbon Action Partnership (ICAP), “China officially expands national ETS to cement, steel and aluminum sectors”, updated 10 April 2025. https://icapcarbonaction.com/en/news/china-officially-expands-national-ets-cement-steel-and-aluminum-sectors