The short answer
Since 1 January 2026 CBAM has been in its definitive phase: anyone importing more than 50 tonnes a year of iron and steel, aluminium, cement, fertilisers or hydrogen into the EU must be an authorised CBAM declarant and buy certificates matching the embedded emissions of the goods. The cost depends on data from the production installation in China: without verified data, default values apply, and these are usually more punitive. For a Chinese manufacturer, supplying accurate data has become a competitive advantage.
Who this guide is for
Steelworks, foundries and producers of aluminium, cement, fertilisers and hydrogen in China, plus traders and exporters selling these materials, and the downstream products listed in Annex I (such as screws, bolts and certain semi-finished goods), to European customers.
Who pays and who supplies the data
The legal obligation falls on the EU importer, who submits the annual declaration and surrenders the certificates. But embedded emissions are calculated at the installation that produced the goods: it is the Chinese manufacturer that has to collect the data and pass it on, usually using the communication template provided by the European Commission. Installations outside the EU can also register in the CBAM Registry, so that they can share verified data with several importers.
How embedded emissions are calculated
The method is the EU one: it covers direct process emissions, emissions from precursors (for example clinker in cement or pig iron in steel) and, for cement and fertilisers, indirect emissions from electricity as well. A product carbon footprint calculated under other standards is not enough: system boundaries, allocation rules and monitoring data must follow the CBAM methodology, and in the definitive phase the data must be verified by an accredited verifier.
Carbon price paid in China
The regulation allows the importer to reduce the number of certificates to surrender by the carbon price actually paid in the country of origin. China's national emissions trading scheme covers the power sector and, since 2025, steel, cement and aluminium too: properly documenting the costs incurred in China can therefore lower the bill for the European customer.
Deadlines
Definitive phase from 1 January 2026; sale of CBAM certificates from 1 February 2027; first annual declaration, covering 2026 imports, by 31 August 2027. Free allowances under the EU ETS are being phased out gradually until 2034, so the financial weight of CBAM will grow every year.
Step by step
- 01Identify the CN codes of the products you sell in the EU that fall within CBAM
- 02Map installations, production processes and purchased precursors
- 03Set up a monitoring plan in line with the EU methodology
- 04Collect precursor data from your own suppliers
- 05Have the data verified by an accredited verifier
- 06Send the emissions communications to importers and agree data, timing and costs in your contracts
Mistakes to avoid
- Relying on default values: they cost your customer more and weaken your offer
- Using a carbon footprint calculation that does not follow the CBAM methodology
- Delivering data after the importer's deadlines
How we help
From our Shanghai office we work directly with installations: we set up monitoring, collect and check the data, and prepare the documentation for verification and for the communication to the importer. From Rome we handle the European side, with the importer and the declaration.