Since 1 January 2026, the EU Carbon Border Adjustment Mechanism (CBAM) has been in its definitive phase. Importers of cement, iron and steel, aluminium, fertilisers, hydrogen and electricity now pay for the carbon embedded in what they bring into the EU. For most companies the difficult part is not the payment. It is the reporting behind it, and that is exactly the part Global Alliance Register takes off your desk.
Why CBAM Reporting Matters Now
CBAM puts a carbon price on imported goods equal to what EU producers pay under the EU Emissions Trading System. The importer pays, but the information the price is based on comes from the producer: the specific embedded emissions of each product, calculated for the installation that made it, using the EU methodology, and checked by an accredited verifier.
Where that information is missing, default values apply. They are set conservatively and now include a mark-up that increases from 2027 onwards. Credible, verified actual data is therefore usually the cheaper option, and it is quickly becoming a condition of doing business with EU buyers.
Which Sectors and Organisations Are Covered?
CBAM applies to goods listed by Combined Nomenclature (CN) code in Annex I of the CBAM Regulation. If your product’s CN code is on the list, CBAM applies, regardless of the industry you describe yourself as. Select a sector below to see the covered goods, the data that matters and the immediate steps Global Alliance Register takes to get you ready.
Iron & steelCO₂ · direct emissions only
- Covered goods
- Pig iron, DRI, crude and semi-finished steel, flat and long products, pipes and tubes, structures, tanks, screws, bolts, nuts and other fasteners.
- CN codes
- CN 2601 12 00 · Chapter 72 (except most ferro-alloys) · 7301–7311 · 7318 · 7326
- Key data
- Production route (BF-BOF, EAF or DRI), fuels, electrodes, ore, scrap and purchased precursors such as pig iron, DRI or crude steel.
How we get you ready
- We map every product you export to the EU to its CN code and confirm which customers and tonnages fall under CBAM.
- We identify the installation and production route (BF-BOF, EAF or DRI) behind each product and trace every purchased precursor.
- We collect your 2026 fuel, electricity, ore, scrap, alloy and production data using our templates, on site if needed.
- We obtain embedded emissions from your precursor suppliers, or apply default values where they cannot provide them.
- We calculate your specific embedded emissions, prepare the report and book the accredited verification visit before the 2027 rush.
AluminiumCO₂ and PFCs · direct emissions only
- Covered goods
- Unwrought aluminium, powders, bars, profiles, wire, plates, foil, tubes, structures, containers and other aluminium articles.
- CN codes
- CN 7601 · 7603–7614 · 7616
- Key data
- Primary (smelting) or secondary (remelting) route, anode consumption, anode effects (PFCs), scrap share and purchased unwrought aluminium.
How we get you ready
- We map your aluminium products to CN codes and identify the EU customers that need your data.
- We confirm whether each product is made by primary smelting or secondary remelting and trace where every precursor comes from.
- We collect your fuel, anode, PFC monitoring and production data for 2026.
- We obtain embedded emissions from your suppliers of unwrought aluminium.
- We calculate your embedded emissions, prepare the monitoring documentation and arrange accredited verification.
CementCO₂ · direct and indirect (electricity) emissions
- Covered goods
- Calcined clays, cement clinker, Portland, white, aluminous and other hydraulic cements.
- CN codes
- CN 2507 00 80 · 2523 10 00 · 2523 21 00 · 2523 29 00 · 2523 30 00 · 2523 90 00
- Key data
- Clinker production and clinker-to-cement ratio, kiln fuels including alternative fuels, raw meal calcination and electricity consumption.
How we get you ready
- We separate your clinker and cement products and confirm their CN codes.
- We collect kiln fuel, raw meal, clinker and cement production data for 2026, including alternative fuels.
- We document your electricity consumption and its source, because indirect emissions count for cement.
- We trace any purchased clinker and its origin.
- We calculate your embedded emissions and schedule the accredited verification visit around your kiln operations.
FertilisersCO₂ and N₂O · direct and indirect emissions
- Covered goods
- Nitric acid, ammonia, potassium nitrate, nitrogen fertilisers such as urea and ammonium nitrate, and mixed fertilisers.
- CN codes
- CN 2808 00 00 · 2814 · 2834 21 00 · 3102 · 3105 (except 3105 60 00)
- Key data
- Natural gas use as fuel and feedstock, N₂O from nitric acid production, electricity, and purchased ammonia or nitric acid.
How we get you ready
- We list your fertiliser products by CN code and EU customer.
- We map how your ammonia, nitric acid and finished-product units are linked.
- We collect gas, electricity, N₂O monitoring and production data for 2026.
- We obtain embedded emissions for any purchased ammonia or nitric acid.
- We calculate your embedded emissions, prepare the documentation and arrange accredited verification.
HydrogenCO₂ · direct emissions only · no 50-tonne threshold
- Covered goods
- Hydrogen produced by steam methane reforming, electrolysis or other routes.
- CN codes
- CN 2804 10 00
- Key data
- Production route, natural gas or electricity input, and any carbon capture.
How we get you ready
- We confirm the volumes you export to the EU, as the 50-tonne threshold does not apply to hydrogen.
- We document your production route and energy inputs.
- We collect your 2026 monthly production and input data.
- We calculate your embedded emissions, prepare the documentation and arrange accredited verification.
ElectricityCO₂ · specific rules for electricity · no 50-tonne threshold
- Covered goods
- Electricity imported into the EU.
- CN codes
- CN 2716 00 00
- Key data
- Generation source, interconnection and transmission arrangements.
How we get you ready
- We review how your electricity reaches the EU and who files the CBAM declaration.
- We assess whether actual emission values can be documented for the electricity you supply.
- We prepare the supporting data and coordinate with your counterpart in the EU.
EU importers of more than 50 tonnes a year (authorised CBAM declarants), indirect customs representatives acting for them, and the non-EU operators and installations whose emissions data the declaration relies on. Traders and distributors in between must pass that data along.
Importers below 50 tonnes a year (not for hydrogen or electricity); goods originating in Iceland, Liechtenstein, Norway, Switzerland and the territories Büsingen, Heligoland, Livigno, Ceuta and Melilla; and goods used for military activities.
Key CBAM Dates
Definitive period begins. Above 50 tonnes a year, only authorised CBAM declarants may import CBAM goods.
Accredited verifiers begin registering in the CBAM Registry. The Commission confirms the 50-tonne threshold.
Quarterly holding requirement applies: at least 50% of the certificates for goods imported that year must be held at the end of each quarter.
CBAM certificate sales open for authorised declarants, including certificates covering 2026 imports.
First annual CBAM declaration and certificate surrender for 2026 imports, then every year by 30 September.
Who Needs CBAM Reporting Support?
Companies that file the annual CBAM declaration, buy and surrender certificates and must meet the quarterly holding requirement. They need reliable, verified data from every supplier.
Manufacturers in Türkiye and elsewhere that must provide their EU customers with installation-specific embedded emissions, calculated under the EU methodology and independently verified.
Default Values or Verified Data?
Relying on default values
- Set conservatively, based on high-emitting producers
- Carry a mark-up that rises from 2027
- Usually mean more certificates to buy
- Make the supplier less attractive to EU buyers
Reporting verified actual emissions
- Reflect the real performance of your installation
- Usually reduce the certificates your customer must buy
- Give EU buyers a reason to keep or choose you
- Reward efficiency and decarbonisation investments
How GAR Handles CBAM Reporting, Step by Step
Our process follows the logic of the CBAM rules. You stay informed at every stage, while GAR does the technical work.
We map your products to CBAM CN codes, check the 50-tonne threshold, identify the declarant and the installations involved, and agree the reporting scope.
Output: CBAM scope summaryWe provide simple templates and collect production volumes, fuels, electricity, process inputs and precursors directly from the installation, with on-site support where needed.
Output: complete activity data setWe define installation boundaries and production processes and calculate direct and, where relevant, indirect specific embedded emissions per tonne of product, including precursors.
Output: embedded emissions per productWe prepare the monitoring documentation and the emissions communication your EU customers need, in the format required for their CBAM declarations.
Output: CBAM emissions reportWe arrange verification by an accredited CBAM verifier from GAR’s partner network, including the site visit, and coordinate any findings until verification is complete.
Output: verification statementFor EU importers we consolidate supplier data, estimate certificate needs and quarterly holdings, and prepare the information for the annual declaration in the CBAM Registry.
Output: declaration-ready dataWhat We Need From You
- A contact person at each installation or supplier
- Production quantities for the CBAM goods
- Fuel, energy and electricity records
- Raw material and precursor information
- Existing emissions, energy or ISO 14064 reports
- Customer requests and CN codes, if available
Why Clients Choose GAR for CBAM
From scoping to verified report, instead of separate consultants, auditors and verifiers.
Formal verification statements issued by verifiers in our partner network accredited for that scope.
Support for installations in more than 140 countries, wherever your supply chain is.
Steel, aluminium, cement, fertilisers and other energy-intensive industries through our inspection, testing and certification work.
Through ESG360, GAR’s ESG business, the same data supports ISO 14064, Scope 3 and CSRD-driven customer requests.
Carbon price deductions, Türkiye’s ETS pilot and the planned downstream extension are built into our approach.
Frequently Asked Questions
Does CBAM apply if we import less than 50 tonnes a year?
Importers whose CBAM goods total 50 tonnes or less a year (excluding hydrogen and electricity) are exempt from CBAM obligations. The Commission reviews the threshold every year and confirmed it in September 2026.
We are not in the EU. Why should we report anything?
You are not the declarant, but your EU customers need your installation’s verified emissions to avoid default values. Suppliers who can provide verified data make CBAM cheaper for their buyers and are easier to keep as partners.
Who verifies the emissions data?
Verification is carried out by verifiers accredited for CBAM. GAR arranges and coordinates the verification through accredited partners in its network; the formal verification statement is issued by the accredited verifier.
How long does the process take?
It depends on the number of products and installations and on how much data already exists. A single installation with good records can usually be scoped, calculated and prepared for verification within a few weeks.
Can carbon prices paid in Türkiye be deducted?
CBAM allows a deduction for carbon prices effectively paid in the country of production, but the detailed rules are still being finalised. Türkiye’s emissions trading system is in its 2026–2027 pilot phase, and we track both developments for our clients.
CBAM REPORTING
Let Global Alliance Register take care of your CBAM reporting.
From scoping and data collection to accredited verification, one team coordinates every step, so your EU customers receive data they can rely on.
- 01Verified data
- 02Lower CBAM costs
- 03One point of contact