Your Country’s CBAM Exposure

What an Article 9 deduction actually requires

The reduction may be claimed only if the carbon price has been effectively paid in a third country.

Reg. (EU) 2023/956, Art. 9(1) (as amended by Reg. (EU) 2025/2083)

It is a claim an authorised CBAM declarant makes in one declaration, about a price actually paid on the emissions being declared — not a status a country holds. There is no Commission approval of a national scheme anywhere in Article 9.

Any rebate, free allocation or other compensation available in that country is taken off first (Art. 9(1)). A scheme that allocates its allowances free leaves little or nothing that was effectively paid.

The documentation must be certified by a person independent of both the declarant and the third-country authorities, with evidence of the actual payment (Art. 9(2)).

That route is open only where embedded emissions are determined on ACTUAL emissions. Where they rest on default values, the claim may be made only by reference to yearly default carbon prices, which the Commission may determine and publish for such countries from 2027 (Art. 9(4)).

A country shown as paying nothing is not disqualified from anything: there is simply no price paid for a declarant to deduct — and in every case the emissions must be determined on actual, verified data before the question arises at all.

Emissions are per installation; the deduction can be either

CBAM reports emissions per installation: two exporters in the same country can face different costs if their production routes and emission factors differ.

The deduction is the other way round. On actual emissions it follows the price your buyer’s declarant can evidence as paid; on default values it may be claimed only by reference to the yearly default carbon price for the country, which is a country-level figure (Art. 9(4)).

The country-level default values shown here are what applies when verified actual data is not provided. A verified actual value carries no mark-up.