Resource
CBAM checklist for exporters
Minimum questions and data exporters should prepare before answering a European importer.
Who it is for
Why it matters
CBAM entered its definitive phase in January 2026. A European importer of cement, steel, aluminium, fertilizers, electricity or hydrogen needs verified embedded emissions for each product from its supplier; without them, it applies higher, more expensive default values. This checklist organizes what data to prepare before that conversation.
Embedded emissions
You need direct and indirect emissions per tonne of product, calculated at installation level following the CBAM Implementing Regulation methodology.
Installation data
Prepare plant identification, production routes, energy consumption and the emission factors of the precursors used.
Threshold and timeline
There is a 50-tonne annual de minimis exemption per importer; certificate-purchase obligations apply from 2027.
What it includes
- Questions European importers usually ask
- Minimum embodied-emissions data per product
- Documentation and evidence to prepare
- Points that delay the commercial response
- How to structure your response package
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