What is EU CBAM and who does what?

By Ahmed Medhat · Published11 April 2026 · Updated 30 September 2026

What is EU CBAM and who does what?

The Exporter’s Guide to Supply Chain Roles & Responsibilities

Under the EU's Carbon Border Adjustment Mechanism (CBAM), EU importers surrender CBAM certificates for the emissions embedded in the goods they import (Regulation (EU) 2023/956, Article 22).

Non-EU exporters need to understand the roles and legal responsibilities of every party in the CBAM chain: the factory, the intermediary, the verifier and the buyer.

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1. CBAM in One Minute: The Exporter’s View

CBAM addresses the greenhouse gas emissions embedded in the goods listed in its Annex I on their importation into the EU, "in order to prevent the risk of carbon leakage" (Regulation (EU) 2023/956, Article 1(1)).

• The Transitional Phase (Oct 2023 – Dec 2025): The focus is strictly on quarterly reporting of embedded emissions without any financial payments.
• The Definitive Regime (Jan 1, 2026 onwards): Importers must become "Authorised CBAM Declarants" if they wish to import goods above the minimum threshold. They transition to annual reporting and must purchase and surrender CBAM certificates based on the embedded emissions of the goods they import. The first certificate surrender is due by September 30, 2027, covering goods imported in 2026 (Article 22(1)).

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2. The Producer / Installation (Your Role)

As a non-EU operator supplying in-scope goods, you hold the data from which actual embedded emissions are determined. You do not pay the EU; where your buyer declares your actual emissions, your data sets what it surrenders.

If your buyer is to declare actual emissions for your goods:

• Calculation: You calculate your installation's emissions under Implementing Regulation (EU) 2025/2547 — direct emissions, indirect emissions where the good counts them (Article 7(1), Annex II), and the embedded emissions of relevant precursors.
• Methodology: The calculation follows those monitoring rules, not a generic life-cycle assessment.
• Verification: Those emissions must be verified by an accredited verifier (Article 8(1)); in the first year of verification the verifier must visit the installation in person, and may replace that with a virtual site visit only where serious, extraordinary and unforeseeable circumstances prevent a physical one (IR (EU) 2025/2546, Articles 3 and 4).

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3. The Importer / Authorised CBAM Declarant (Your Buyer)

Your EU-based buyers are the legally liable entities under CBAM. They declare the embedded emissions of the goods they import and surrender CBAM certificates for them (Regulation (EU) 2023/956, Articles 6 and 22).

Their core responsibilities include:

• Registration & Reporting: Above the Article 2a threshold, they hold authorised CBAM declarant status and submit their CBAM declaration through the CBAM registry (Articles 4 and 6).
• Certificates: From 2027, at the end of each quarter they hold certificates covering at least 50% of the embedded emissions imported so far that year (Article 22(2)). Each year they surrender certificates for the previous year's declared embedded emissions, with the Article 31 adjustment for free allocation (Article 22(1)).
• Supplier Selection: A declarant's CBAM cost depends on the embedded emissions of the goods it imports, so the data its suppliers provide shapes that cost.

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4. The Accredited Verifier

Actual emissions count only once they are verified (Article 8(1)).

• Site visits: In the first year of verification the verifier must visit the installation in person; only where serious, extraordinary and unforeseeable circumstances prevent a physical visit may it be replaced by a virtual one (IR (EU) 2025/2546, Articles 3 and 4).
• Accreditation: Verifiers are legal persons accredited by a national accreditation body (Article 18(2)).

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5. Traders, Intermediaries, and Downstream Entities

Global trade rarely flows directly from a single factory to a single European buyer. Intermediaries between the two are part of the CBAM chain too.

• Traders and Intermediaries: The CBAM declaration is submitted by the authorised CBAM declarant: the importer, or an indirect customs representative acting as declarant (Regulation (EU) 2023/956, Articles 5(1), 5(1a), 5(2) and 6(1)).
• Downstream producers: A producer that makes complex goods from yours may need your data for its own embedded-emissions calculation.

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6. How DeCarbonPro Empowers Exporters and Installations

To work across these roles, installations need their CBAM data in one place. DeCarbonPro offers non-EU producers:

• Precursor and Process Data Organization: Structure your activity data, precursor inputs, and production routes in line with Implementing Regulation (EU) 2025/2547.
• Installation-Level Emissions Modeling: Calculate embedded emissions and free-allocation benchmarks at the installation level.
• Emissions reports: Produce your Operator's Emissions Report and the Operator's Summary Emissions Report from the same data.