The EU’s Carbon Border Adjustment Mechanism entered its definitive regime on 1 January 2026, requiring importers of covered goods to report embedded emissions and buy and surrender corresponding certificates. Small exporters outside the EU are not directly subject to those importer obligations, but their customers may ask them for compliance information.
CBAM covers selected goods in cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. UK government guidance for exporters says exporters may be asked for emissions data and evidence of a carbon price paid under the UK Emissions Trading Scheme. Exporters may be asked for emissions data and evidence of a carbon price paid under the UK Emissions Trading Scheme.
The 50-tonne threshold applies to an EU importer’s annual CBAM imports, not to each supplier’s shipments. An exporter shipping less than 50 tonnes may still need to provide information if its EU customer imports more than that amount annually. The exemption for EU companies below the threshold does not cover hydrogen or traded electricity.
The European Commission says importers or their indirect customs representatives bringing in more than 50 tonnes of CBAM goods must apply for authorised declarant status. Importers can deduct a carbon price already paid during production if they can prove it was paid. Non-EU installation operators can also upload installation and emissions data to the CBAM Registry for sharing with importers.
ESG Times says India will fully cover CBAM and EU deforestation certification costs for eligible micro and small exporters, with graded support for others, under its Export Promotion Mission. A Commission proposal published on 17 December 2025 to strengthen CBAM was still undergoing the legislative process, according to the UK guidance.
