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What is EU CBAM and who does what?

Getting you quickly up to speed with roles & responsibilities

Updated over 2 months ago

CBAM in one minute

The Carbon Border Adjustment Mechanism (CBAM) is the EU’s tool to put a fair price on the carbon emitted during the production of carbon-intensive goods entering the EU, preventing carbon leakage and encouraging cleaner production globally. The transitional phase (1 October 2023 – 31 December 2025) focuses on quarterly reporting of embedded emissions without financial payments. From 1 January 2026, the definitive regime begins: importers must become authorised CBAM declarants (if above the threshold), report annually, purchase and surrender CBAM certificates based on embedded emissions, with the first surrender due by 30 September 2027 for 2026 imports.

Who is responsible

  • Importer / Authorised CBAM Declarant: Registers imports, reports embedded emissions (quarterly until end-2025, annually from 2026), and from 2026 manages CBAM certificates (obligation to purchase from 2027, hold minimum quarterly, surrender annually). Indirect customs representatives may act on behalf of non-EU importers.

  • Producer / Installation (non-EU): Calculates and provides installation-level emissions data to importers, using EU-aligned methodology and must be verified in early 2027 over 2026 data

How CarbonChain helps business manage their CBAM compliance

CarbonChain for Importers (Declarants)

  • Actual emissions validation: Replace default values with supplier-specific emissions data that reflects real production routes and reduces CBAM cost exposure.

  • Automated supplier outreach: Request, track, and manage CBAM data from dozens or hundreds of suppliers in one place, without email chains or manual follow-ups.

  • Benchmark comparisons and scenario modelling: Understand how each supplier compares to peers and model CBAM cost exposure under different benchmarks and carbon price assumptions.

  • Clean audit trail: Maintain a clear, defensible record of data requests, submissions, assumptions, and calculations to support internal review and future verification.

  • Reporting aligned with EU requirements: Generate CBAM reports that follow EU templates and methodologies, reducing the risk of rework or non-compliance as enforcement tightens.

CarbonChain for Producers (Installations)

  • Precursor and process data organisation: Structure raw activity data, precursor inputs, and production routes in a way that meets CBAM rules and customer expectations.

  • Installation-level emissions modelling: Calculate embedded emissions at installation level using consistent methodologies, rather than ad hoc spreadsheets.

  • Verification-ready data packages: Prepare datasets that are structured, traceable, and ready for pre-verification, reducing audit risk and last-minute firefighting.

  • Benchmark and competitor comparisons: See how your emissions intensity compares to peers and identify where carbon cost is helping or hurting your competitiveness.

  • Support for tenders and commercial positioning: Use credible CBAM data to respond faster to customer requests, support EU tenders, and differentiate low-carbon production.

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