CBAM for non-EU suppliers: what your EU customer needs from you in 2026

If you make steel, aluminium, cement or fertiliser products and sell them into the EU, you have probably received a request for your “CBAM data”. This article explains where that request comes from, what exactly to send, and what it costs your customer if you do not.

Who has the obligation

The Carbon Border Adjustment Mechanism moved into its definitive period on 1 January 2026.1 The legal duties sit with the EU importer, who must be an authorised CBAM declarant, buy CBAM certificates for the embedded emissions of the goods and surrender them with an annual declaration. For goods imported in 2026, certificate sales start on 1 February 2027 and the first declaration and surrender are due by 30 September 2027.2

Under Regulation (EU) 2025/2083, importers whose CBAM goods total no more than 50 tonnes net mass in a calendar year are exempt from these duties; hydrogen and electricity do not count towards the threshold.2 The threshold is per importer, across all of their suppliers.

Why the importer needs you

Embedded emissions can be declared in two ways: actual values from the producing installation, or the Commission's default values. Defaults are set conservatively and, from 2026, include a mark-up that rises each year; the Luxembourg CBAM authority cites 10% for 2026, 20% for 2027 and 30% from 2028 for steel, aluminium and cement.3 With a certificate price of €82.32 in the third quarter of 2026,1 a higher emission value translates directly into a higher landed cost of your product.

Actual values must be determined under the CBAM methodology and verified by an accredited verifier.1

What to send

The Commission's communication template for installation operators is the common format. It covers:

1. Installation and operator details, with location.
2. Products by CN code, production route and reporting period.
3. Direct emissions from fuels and processes.
4. Indirect emissions from electricity (counted for cement and fertilisers).
5. Relevant precursors and their embedded emissions, such as wire rod for screws.
6. The resulting specific embedded emissions per tonne of product.

A practical sequence

• List your products that fall under CBAM by CN code.
• Collect monthly production, fuel and electricity data with invoices and meter readings.
• Ask your precursor suppliers for their embedded emission values.
• Calculate, fill the template, and prepare the evidence for the verifier.
• Share the same file with every EU customer instead of answering each one separately.

Compass keeps this in one supplier file that you release per customer.