Sustainability & Carbon
Sectors in scope: cement, iron & steel, aluminium, fertilisers, electricity, hydrogen
Penalty for unsurrendered CBAM certificates
First annual CBAM declaration and certificate surrender deadline
Regulation Overview
CBAM is the EU’s carbon border pricing mechanism and a central pillar of the European Green Deal. For supply chain and compliance teams, the primary obligation is collecting verified embedded emissions data from non-EU suppliers and purchasing CBAM certificates to cover those emissions.
CBAM currently covers six sectors: cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. The EU Commission proposed expanding scope to downstream steel and aluminium products from January 2028. Importers placing CBAM goods on the EU market must obtain authorised declarant status, report embedded emissions annually, and surrender certificates priced at the EU ETS allowance rate.
CBAM compliance requires installation-level emissions data—direct and indirect—from every non-EU production facility. Without verified supplier data, importers default to conservative emission values that significantly increase certificate costs.
Key Components / Sub-Frameworks
EU importers of CBAM goods exceeding 50 tonnes annually (cumulative net mass)
Indirect customs representatives acting as authorised CBAM declarants
Non-EU manufacturers and exporters supplying emissions data to EU importers
Distributors and traders placing CBAM-covered goods on the EU market
Companies importing downstream products containing CBAM materials (from 2028)
UK importers of CBAM goods (UK CBAM from January 2027)
Key Thresholds
You import steel from 40 installations across 8 countries. CBAM requires installation-level emissions data—direct and indirect—for each production facility. Fifteen suppliers don’t track emissions. Ten provide data in incompatible formats. Without actual verified data, you default to the highest emission intensity values published by the Commission. Your certificate costs increase by 30-50%.
CBAM certificate prices track EU ETS allowance prices—currently above €60/tonne and projected to rise as free allocations phase out through 2034. Every tonne of emissions you cannot verify with actual supplier data costs you the default rate. The financial gap between verified and unverified data compounds with every shipment.
Embedded emissions must be calculated per installation using EU-approved methodologies. Each supplier needs to report production routes, fuel inputs, process emissions, and electricity consumption. Precursor emissions from upstream materials add another layer. Your compliance team cannot validate 200 supplier submissions manually against Commission benchmarks.
The EU CBAM is live. The UK CBAM launches January 2027. Carbon pricing mechanisms are emerging globally. Each jurisdiction has different scope, calculation methods, and reporting formats. Managing parallel carbon border compliance programs with spreadsheets and email is not sustainable at scale.
Certivo In Action
CBAM Workflow
Industrial & Heavy Equipment
Pain Point
Steel and aluminium inputs from global supply chains; complex precursor emissions
Automotive Manufacturing
Pain Point
High steel and aluminium content; hundreds of non-EU suppliers; downstream scope expansion
Construction Materials
Pain Point
Cement and steel imports; large volumes triggering high certificate costs
Energy & Infrastructure
Pain Point
Electricity and hydrogen imports; direct and indirect emissions complexity
Electronics Manufacturing
Pain Point
Aluminium in enclosures and heatsinks; steel in chassis and structural components
Aerospace & Defense
Pain Point
High-grade aluminium and specialty steel alloys; stringent supply chain documentation
Chemical Manufacturing
Pain Point
Fertiliser sector in scope; potential chemicals and polymers expansion
Consumer Goods
Pain Point
Steel and aluminium in packaging and product components; high SKU volumes
From Default Values to Verified Data
CORA collects and validates actual installation-level emissions data. Verified data consistently reduces certificate obligations compared to the Commission’s conservative default values.
Annual Declaration Acceleration
Generate complete, audit-ready CBAM declarations with certificate calculations in hours—not the months of manual compilation across suppliers and installations.
Proactive CBAM Compliance Assurance
When the Commission expands CBAM scope to downstream products or updates default values, Certivo reassesses your import portfolio instantly. Know your exposure before declaration deadlines—not after.
Key Statistics
Frequently Asked Questions
Which goods are currently in scope of CBAM?
CBAM covers six sectors: cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. Goods are identified by their Combined Nomenclature (CN) codes listed in Annex I of the CBAM Regulation. The EU Commission proposed extending scope to downstream steel and aluminium products from January 2028. Certivo tracks current and proposed scope expansions and alerts you when new CN codes affect your imports.
What are the penalties for CBAM non-compliance?
Importers who fail to surrender sufficient CBAM certificates face a penalty of €100 per tonne of CO₂ equivalent, adjusted for inflation—on top of the certificate cost itself. During the transitional phase, fines ranged from €10 to €50 per tonne of unreported emissions. Persistent non-compliance can result in suspension of authorised declarant status and loss of EU market access for CBAM goods.
How does the de minimis exemption work?
Importers whose total annual net imports of CBAM goods (excluding electricity and hydrogen) fall below 50 tonnes cumulative net mass are fully exempt from CBAM obligations, including reporting, authorisation, and certificate purchase. Certivo tracks your import volumes against the threshold and alerts you if cumulative imports approach the 50-tonne limit.
How does Certivo reduce CBAM certificate costs?
Certivo automates the collection of verified, installation-level emissions data from non-EU suppliers. Actual emissions data almost always results in lower certificate obligations than the Commission’s deliberately conservative default values. CORA validates supplier data against Commission calculation methodologies, identifies gaps, and models the cost impact of verified vs. default scenarios per installation.
How does EU CBAM relate to the UK CBAM?
The UK will introduce its own CBAM from January 2027, covering similar goods but using a tax-return model rather than the EU’s certificate mechanism. Scope and calculation methods differ. Certivo validates supplier emissions data against both EU and UK CBAM requirements simultaneously, eliminating the need for separate data collection campaigns.