Article 1 · Scope
Applies to imports of cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. Definitive Phase requires verified embedded emissions for every consignment.
● CBAM first declarationFirst CBAM certificate surrender due
31 May 2027
First CBAM declaration 31 May 2027 · Quarterly XML filings mandatory · Verified actuals required now
● CBAM + PPWR, one platform
Embedded emissions. Verified. Before enforcement.
Your packaging team runs PPWR on Carbonorm. Your trade compliance team will run CBAM on the same supplier hub, same audit lineage, same dashboard. One audit ledger. Two regulations. Zero duplicate data entry.
● Sound familiar?
Three Definitive-Phase landmines.
01
Default values expire
After the Definitive Phase begins, customs default emission factors are gone. Verified actuals from every supplier in the chain, or your declaration is rejected.
02
Supplier Scope-3 silence
Your steel supplier ships actuals. Your aluminium supplier ships defaults. Your fertiliser supplier ships nothing. Mixed-quality evidence kills the entire bundle.
03
Two-tool fatigue
One tool for packaging, another for carbon border adjustment. Two supplier portals, two data models, two audit trails. CBAM declarations are quarterly with statutory penalties, and your suppliers are confused by the duplicate requests.
● One system, two regulations
Most tools handle PPWR or CBAM. Never both.
Carbonorm is architected from day one to share supplier dossiers, BoM data, and audit lineage across both regulations. No re-entry. No reconciliation gaps.
PPWR-only tools
Packaging only- Recyclability grading
- DoC generation
- No emissions data model
- Separate supplier portal needed for CBAM
CBAM-only tools
Emissions only- Embedded emissions tracking
- CBAM XML export
- No packaging compliance
- Separate system needed for PPWR
Carbonorm
PPWR Live + CBAM Nov 2026- Shared supplier hub for both regulations
- Single audit lineage across packaging + emissions
- One dashboard for your CFO
- Start PPWR today, add CBAM with zero migration
● Regulation coverage
CBAM Regulation 2023/956, article by article.
Every calculation references the regulation text it implements. Auditors see the clause, not a score.
Article 6 · CBAM declaration
Design for recycling
Authorized declarants must submit a yearly CBAM declaration by 31 May, covering total embedded emissions and CBAM certificates surrendered.
↳ RecyclabilityArticle 7 · Embedded emissions
Recycled content
Direct and indirect emissions per tonne of goods, calculated using approved methodologies. Actual data from installations preferred over defaults.
↳ PCRArticle 8 · Verification
Embedded emissions reported by third-country operators must be verified by an accredited verifier before inclusion in the CBAM declaration.
Article 26 · Penalties
Failure to surrender sufficient CBAM certificates: penalty of three times the average EU ETS price per tCO2. Repeat non-compliance triggers import restrictions.
● Workflow
From supplier dossiers to verified CBAM declaration.
01
Collect
Pull utility bills, supplier Scope-3 dossiers, and BoM emissions data into one workspace. Auto-detect missing fields before the quarter closes.
02
Reconcile
Per-product allocation across mass, energy, and emission factors. Flag mixed-quality evidence and default-value dependencies before they block your filing.
03
Verify
Route the reconciled dataset to your accredited verifier with full audit lineage attached. One click, not 14 spreadsheets.
04
Declare
Generate the CBAM XML your customs broker needs. Quarterly filings with audit hash and certificate-surrender tracking built in.
● Carbon border cost exposure
What CBAM costs per sector.
CBAM certificate prices track the EU ETS. The financial exposure varies by sector, carbon intensity, and whether you rely on default or verified values.
Cement
€62-€95
per tonne imported
Direct + indirect emissions
~0.6 tCO2/t clinker
Iron & Steel
€120-€180
per tonne imported
Direct emissions (BF-BOF route)
~1.8 tCO2/t crude steel
Aluminium
€200-€580
per tonne imported
Direct + indirect (smelting electricity)
~6.8 tCO2/t primary aluminium
Fertilisers
€85-€145
per tonne imported
N2O + CO2 from ammonia synthesis
~1.6 tCO2/t ammonium nitrate
Ranges based on EU ETS prices EUR 65-95/tCO2 (2024-2025 corridor). Actual exposure depends on installation-specific emission intensity and certificates already surrendered. Carbonorm calculates your exact exposure from verified actuals.
● One platform, two regulations
Already managing PPWR? Add CBAM to the same dashboard.
Your packaging team already uses Carbonorm for Article 6 grading and DoC generation. When CBAM launches in November 2026, the same supplier portal, the same audit lineage, and the same dashboard extend to cover embedded emissions. Zero migration. Zero duplicate data.
● CBAM FAQ
Common questions about CBAM compliance.
What is CBAM and who does it affect?+
The Carbon Border Adjustment Mechanism (EU Regulation 2023/956) applies to EU importers of cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. If you import any of these goods into the EU, you need to report embedded emissions and, from 2026, purchase CBAM certificates.
When do CBAM certificates become mandatory?+
The Definitive Phase starts January 2026. From that date, importers must purchase CBAM certificates corresponding to the embedded emissions in their imports. Prices track the weekly EU ETS auction average.
What happens if I rely on default emission values?+
During the Transitional Phase, default values from the European Commission are accepted. After the Definitive Phase, default values are progressively restricted. Verified installation-specific data reduces your certificate cost and avoids penalty surcharges.
How does Carbonorm handle both PPWR and CBAM?+
Both regulations share supplier dossiers, BoM data, and audit lineage in a single workspace. Your PPWR packaging compliance data is already in the system. When CBAM launches, the same supplier portal extends to collect embedded emissions data without re-onboarding suppliers.
Can I start with PPWR and add CBAM later?+
Yes. Most customers start with PPWR (live now) and activate the CBAM module when it launches in November 2026. Your supplier relationships, data models, and audit trails carry over automatically.
What is the penalty for non-compliance?+
Under Article 26, failure to surrender sufficient CBAM certificates triggers a penalty of three times the average EU ETS price per unreported tonne of CO2. Repeat non-compliance can result in restrictions on import authorizations.
Which sectors have the highest CBAM exposure?+
Primary aluminium (6-8 tCO2 per tonne) and iron/steel via blast furnace (1.5-2.0 tCO2 per tonne) carry the highest embedded emissions intensity. Cement and fertilisers follow. The exact exposure depends on your supplier installations and their energy mix.
Does Carbonorm generate the CBAM XML for customs brokers?+
Yes. After reconciliation and verification, Carbonorm generates the quarterly CBAM XML in the format required by the EU CBAM registry. Your customs broker receives a ready-to-submit file with full audit lineage attached.
We manufacture outside the EU — say in Turkey — and export through an EU subsidiary. Who carries the CBAM obligation?+
The CBAM declarant is the authorised declarant on the EU side — typically your importing subsidiary or an indirect customs representative — which files the declaration and surrenders the certificates. But the embedded-emissions data has to come from the third-country installation that actually produced the goods. So the obligation splits: the EU entity is accountable to the authorities, while your non-EU plant has to measure and supply verified emissions per consignment. The practical task is building that data bridge — production data from the Turkish (or Indian, or Chinese) facility, mapped to the EU declarant's filing. Carbonorm collects installation-level actuals upstream and hands the EU declarant a verifier-ready dataset, so default values and their surcharges can be replaced with real numbers.
● CBAM Resources
Go deeper on carbon border compliance.
Regulatory deep dives, sector analyses, and practical guides for teams navigating CBAM alongside PPWR.
Guide
CBAM Definitive Phase: what changes in January 2026
A plain-language breakdown of what the Transitional-to-Definitive shift means for importers, customs brokers, and their suppliers.
Read the guide →Deep Dive
PPWR + CBAM overlap: where packaging meets carbon
Companies importing packaged goods face both regulations simultaneously. This analysis maps the overlapping data requirements and shared compliance workflows.
Read the analysis →Playbook
Supplier Scope-3 data collection playbook
Step-by-step guide to requesting, validating, and reconciling embedded emissions data from third-country suppliers. Includes email templates and escalation framework.
Get the playbook →Calculator
CBAM exposure estimator
Estimate your annual CBAM certificate cost based on import volumes, sectors, and emission intensities. Uses current EU ETS price corridors.
Calculate exposure →Tracker
EU ETS price and CBAM certificate tracker
Weekly updated EU ETS auction prices with CBAM certificate cost projections through 2034 free-allocation phase-out.
View tracker →Checklist
CBAM readiness checklist for importers
12-point self-assessment covering authorized declarant registration, supplier data gaps, verification pipeline, and IT system readiness.
Download checklist →CBAM first declaration · 31 May 2027
Your steel supplier still owes you a Scope-3 dossier. until first CBAM certificate surrender.
Calculate your CBAM exposure on real data. Start with PPWR today and lock in the supplier relationships and audit lineage you will need when the CBAM module launches in November.
● Definitive Phase ready● EU data residency● Dual PPWR + CBAM
PPWR Article 6
Applies from 31 May 2027
Default factors banned
2026
Quarterly XML due
Q1
Free allocations end
2034
Certificate price tracks
ETS