CBAM for Indian exporters: what your EU buyer will ask you for in 2027
The data your EU buyer needs before the first CBAM declaration on 30 September 2027, and why default values will cost you.
- The EU’s Carbon Border Adjustment Mechanism (CBAM) has charged for embedded emissions since 1 January 2026. Your EU buyer pays, but they need your data to do it.
- Their first annual CBAM declaration is due on 30 September 2027. Expect data requests in the months before that.
- Without your verified data, your buyer must use EU default values, which carry a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028. That makes your product more expensive than a competitor’s that has real data.
- Get your emissions monitored, calculated and verified now. Buyers will favour suppliers who make CBAM cheap and easy.
What changed on 1 January 2026
From 2023 to 2025, CBAM was a reporting exercise. EU importers filed quarterly reports and paid nothing. That ended on 1 January 2026, when the definitive period began.
Now, an EU importer bringing in iron and steel, aluminium, cement, fertilisers, hydrogen or electricity must be an authorised CBAM declarant. Each year they buy and surrender CBAM certificates equal to the emissions embedded in those goods. The only exception is small importers: under the 2025 simplification rules, an importer bringing in less than 50 tonnes a year of these goods (hydrogen and electricity excluded) is exempt.
In practice, that means the cost of carbon now travels with your invoice. The more carbon in each tonne you ship, the more your buyer pays on top of your price.
Indian exporters have already felt it. According to the Global Trade Research Initiative (GTRI), India’s steel and aluminium exports to the EU fell 24.4% in FY2024-25, with iron and steel down 35% to USD 3.05 billion, as buyers grew cautious ahead of CBAM.
CBAM deadlines for 2026 and 2027
- 2023–2025Transitional period: reporting only, no cost
- 1 Jan 2026Definitive period: imports carry a CBAM cost
- 1 Feb 2027CBAM certificates go on sale
- 30 Sep 2027First annual declaration for 2026 imports
- 2028Default-value mark-up reaches 30%
- 2034EU free allocation ends: full CBAM cost
| Date | What happens |
|---|---|
| 1 Jan 2026 | Definitive period starts. Imports from this date carry a CBAM cost |
| 31 Mar 2026 | Deadline to apply for authorised declarant status and keep importing while the application is processed |
| 1 Feb 2027 | CBAM certificates go on sale, priced on EU carbon market (EU ETS) prices |
| 30 Sep 2027 | First annual declaration and certificate surrender, covering all 2026 imports |
| Each quarter-end from 2027 | Importers must hold certificates for at least 50% of emissions imported so far that year |
Your buyer’s 2026 bill is calculated from 2026 shipments. So the data they need from you covers goods you are shipping now.
What data EU importers need from Indian exporters
CBAM measures emissions at the level of your installation (your plant) and each product you make there. Expect requests for:
- Installation details: name, address, coordinates and the production routes you use (for example, electric arc furnace or blast furnace).
- Direct emissions: from fuels and processes on your site.
- Indirect emissions: from the electricity you consume.
- Specific embedded emissions: tonnes of CO2 per tonne of each product, by CN code.
- Precursors: emissions embedded in inputs you buy in, such as billets, slabs or primary aluminium.
- Carbon price paid in India, if any.
- A verification report from an accredited verifier.
The EU has set up a portal inside the CBAM Registry where installation operators can register, upload this data and share it with their EU buyers directly. It saves you emailing spreadsheets to every customer.
CBAM default values vs actual data: why it matters to your price
If you cannot supply verified actual data, your buyer can fall back on default values that the European Commission publishes for each country and product. They are deliberately conservative, and the mark-up on them rises every year:
| Year | Mark-up on default values |
|---|---|
| 2026 | 10% |
| 2027 | 20% |
| 2028 onwards | 30% |
Fertilisers carry a lower mark-up.
So a supplier who relies on defaults hands the buyer a bigger bill than one who provides real, verified figures. For an EU procurement team comparing two quotes, that difference is now part of the price.
Verification: a new step for most exporters
Actual emissions data must be checked by a verifier accredited in the EU, and this includes site visits. Default values do not need verification, which is why some exporters are tempted to skip it. But that choice carries the mark-up above.
Verifier capacity is limited in the first year. Plan early.
The cost goes up every year
EU producers of the same goods still receive some free carbon allowances. CBAM only charges importers for the share EU producers pay. As free allocation is phased out, the CBAM charge rises:
| Year | Share of free allocation EU producers keep |
|---|---|
| 2026 | 97.5% |
| 2027 | 95% |
| 2028 | 90% |
| 2030 | 51.5% |
| 2034 | 0% |
The charge is small today and grows sharply after 2028. Reducing your emissions per tonne now protects your pricing later.
What about the India–EU trade deal and India's carbon market?
The India–EU Free Trade Agreement, concluded on 27 January 2026, does not exempt Indian goods from CBAM. India did secure an assurance that any flexibility the EU gives other countries will also apply to India, plus technical cooperation.
CBAM lets importers deduct a carbon price already paid in the country of origin. The EU’s rules for this were still in draft in mid-2026. It is not yet clear whether India’s Carbon Credit Trading Scheme, an intensity-based scheme where many plants pay nothing, will qualify. Don’t budget for a deduction yet.
What's coming next
In December 2025 the Commission proposed extending CBAM to about 180 downstream steel and aluminium products, such as fasteners and parts, from 2028. The EU Parliament and Council have since backed wider versions of the proposal. This is a proposal, not law, but if you make downstream products, start preparing now.
What to do now: a five-step checklist
- Check your products. Match your CN codes against the CBAM list. Our CBAM checker does this in seconds.
- Ask your buyers what they need and when. Most will want 2026 data well before 30 September 2027.
- Set up monitoring. Meter fuel, electricity and production by installation and product.
- Calculate your embedded emissions using the EU’s CBAM method, including precursors.
- Book verification early and register on the EU operator portal.
FAQs
Do I, as an Indian exporter, pay CBAM?
No. The EU importer pays. But your data decides how much they pay, and that shapes whether they keep buying from you.
We export less than 50 tonnes a year. Are we exempt?
The threshold applies to each importer, not each exporter. If your buyer imports more than 50 tonnes of CBAM goods in total from all suppliers, they still need your data.
Can we just let our buyer use default values?
You can, but the defaults are high and carry a mark-up of up to 30%. That makes your goods more expensive than a competitor’s with verified data.
Sources
- European Commission: CBAM definitive regime
- Regulation (EU) 2025/2083 (CBAM simplification)
- DEHSt: CBAM certificates, dates and holding rule
- ICAP: CBAM enters compliance phase (default value mark-ups)
- European Commission: CBAM verification
- European Commission: CBAM Registry and operator portal
- European Commission: carbon price paid in third countries (draft, May 2026)
- European Parliament Research Service: CBAM extension to downstream products
- Ministry of Commerce: India–EU FTA concluded
- Argus: EU–India FTA leaves CBAM untouched
- Alcircle / GTRI: India's steel and aluminium exports to the EU
Facts checked on 28 Sep 2026. Rules change often; we update this article when they do.