// Compliance & Standards

CBAM Readiness

Understand your exposure to the EU carbon border regime and put the data pathway in place.

Assessment of CBAM exposure across your products and customers, embedded emissions data preparation, and the reporting pathway your EU importers require.

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// Context

Why this matters

The EU Carbon Border Adjustment Mechanism entered its definitive period on 1 January 2026. It covers cement, iron and steel, aluminium, fertilisers, electricity and hydrogen, and it prices the carbon embedded in those goods when they enter the EU.

The obligation sits with the EU importer, who must be an authorised CBAM declarant and surrender certificates against the embedded emissions of what they import. The first surrender deadline is 30 September 2027 for goods imported during 2026, with certificate sales beginning on 1 February 2027.

For Asian producers and exporters, that obligation arrives indirectly. The importer needs verified embedded emissions data at product level, and will source from suppliers who can provide it. Producers who cannot become commercially less attractive than those who can, regardless of their own carbon performance.

A mass threshold currently exempts small consignments below 50 tonnes of CBAM goods per year, and the scope has been subject to revision -- so applicability should be confirmed rather than assumed.

// The engagement

How CER helps

Product scope assessment against the CBAM goods list and CN codes
Exposure analysis across EU customers and export volumes
Threshold applicability review
Embedded emissions determination at product level, direct and where applicable indirect
Production process mapping and installation-level data requirements
Data collection design at the production installation
Carbon price paid assessment, where a domestic carbon price applies
Documentation prepared for importer and verifier requirements
Customer and importer engagement support
Internal capability building for ongoing reporting

// Deliverables

What you receive

CBAM exposure assessment across products and EU customers
Embedded emissions calculation at product level
Production and installation data collection framework
Documentation pack for EU importers
Gap assessment against verification requirements
Ongoing reporting process and internal handover

// Fit

Who this is for

Asian producers and exporters of iron and steel, aluminium, cement, fertilisers or hydrogen
Manufacturers whose EU customers have requested embedded emissions data
Trading and distribution businesses selling covered goods into the EU
Groups assessing CBAM exposure across a product portfolio

// Why CER

Practitioners, not report writers

CER works from Singapore with organisations across Asia, which matters for this service because requirements arriving from European regulators, regional supervisors and local listing rules do not align neatly.

Engagements run through to implementation: the data collection process, the documentation, the controls and the internal handover, so that the second cycle is cheaper than the first and can be run without us.

Where an organisation would be better served by building the capability internally, CER Academy delivers the same technical material as training.

Meet the people behind the work

// Our people

Expertise on this service

Raymond Cheung

Advisor & Lead Trainer

Over twenty years in actuarial science and risk management, working across ESG, sustainability and ESG investment.

Actuarial science · Risk management · ESG and sustainability

View Raymond Cheung’s profile

// Questions

Frequently asked

Does CBAM apply to us if we are not an EU business?

The legal obligation falls on the EU importer, not on you. In practice the requirement is passed to you, because the importer cannot meet their obligation without embedded emissions data from your production. Suppliers who cannot provide it become harder to buy from.

Which goods are covered?

Cement, iron and steel, aluminium, fertilisers, electricity and hydrogen, defined by customs codes rather than by product description. Scope has been revised since introduction, so classification should be confirmed against current legislation rather than an earlier summary.

What are embedded emissions?

The emissions released during production of the goods. Depending on the product category this covers direct emissions and, in some cases, indirect emissions from electricity consumed in production. The calculation is made at the level of the production installation.

What are the key dates?

The definitive period began on 1 January 2026. CBAM certificate sales start on 1 February 2027, and the first surrender deadline is 30 September 2027 covering 2026 imports. Because the regime has been amended, we verify current dates and thresholds against the legislation at engagement.

Does a carbon price paid at home reduce the obligation?

A carbon price effectively paid in the country of production can be taken into account, subject to evidence requirements. Whether and how it applies depends on the pricing mechanism in the production jurisdiction.

// Related