CBAM | Basic Understanding of the EU Carbon Tariff Inspection, Audit, Factory Inspection and Certification Services

2026年1月26日

The EU Carbon Border Adjustment Mechanism (CBAM, commonly known as the "carbon tariff") has entered its transitional period since October 1, 2023, and will officially come into effect in 2026. This mechanism aims to impose fees based on the carbon emissions of specific high-energy-consuming products imported into the EU, marking a substantial increase in the green threshold of global trade. For Chinese export enterprises involved in this, it is not only an environmental issue but also an imminent compliance and cost challenge. Companies must act immediately, establish reliable carbon emission data management capabilities, and ensure the international credibility of the data through authoritative verification and certification.
I. Core Mechanism and Coverage of CBAM: Setting Compliance Goals
The core concept of CBAM is to ensure that imported products bear the same carbon emission costs as domestic products in the EU to prevent "carbon leakage". Its coverage is closely linked to the EU Emissions Trading System (EU ETS).
Covering industries and substances:
Initial products: Clearly cover specific products in six major industries including steel, aluminum, cement, fertilizers, hydrogen, and electricity.
Future expansion: The EU has planned to expand its scope in the future to cover more industries such as organic chemicals and plastics.
Emission of gases: The accounting objects include carbon dioxide (CO₂), as well as nitrous oxide (N₂O) and perfluorocarbons (PFCs) generated during the production process.
Accounting boundaries (including direct and indirect emissions):
Direct emissions: Refers to the carbon emissions generated during the production process of the product (such as in steel smelting furnaces, electrolytic aluminum production, etc.). This is the primary focus of the initial accounting under the CBAM.
Indirect emissions: These refer to the emissions generated during the production process when the purchased electricity used in production is consumed. Currently, except for some products that are already covered by the EU electricity price cost compensation mechanism, most CBAM products do not account for indirect emissions. However, they are very likely to be included in the future.
II. Key Timeline and Core Obligations of the Enterprise: From Reporting to Payment
The enterprise must clearly identify the key milestones from the transitional period to the full implementation and fulfill the corresponding obligations.
Phase Time Period Core Obligation Responsibility Entity Data Requirements Key Points
Transition Period October 1, 2023 - December 31, 2025 Quarterly Report: Report the implicit carbon emissions of imported products. EU Importers Requires including total emissions, direct emissions, indirect emissions, and the carbon costs already paid in the country of origin.
Formal Implementation Period Starting from January 1, 2026 Annual Compliance: Purchase and submit CBAM certificates, pay the corresponding carbon tariffs. EU Importers Must submit a verification report issued by an EU-recognized official verification agency.
First Node Before January 31, 2024 Submit the first CBAM quarterly report for the fourth quarter of 2023. EU Importers The exporting enterprise needs to prepare the basic data in advance for the importer to fill in.
Quota Cancellation Period 2026 - 2034 EU ETS Free Quotas are gradually phased out, and the coverage proportion of CBAM certificates increases year by year to 100%. / The carbon costs borne by the exporting enterprise will increase significantly year by year.
III. Core Response Strategies for Exporting Enterprises: Establish a Trustworthy Data and Verification System
To smoothly enter the EU market and manage future costs, exporting enterprises must elevate CBAM compliance to a strategic management level. The core lies in establishing a carbon emission data management system that can withstand international scrutiny.
Take the initiative to conduct carbon emission data inventory and accounting
Enterprises should immediately conduct a comprehensive carbon emission inventory for each production facility of products subject to CBAM in accordance with the EU-recognized accounting methodologies. This is not a one-time task; rather, it requires regular and meticulous management.
The key is to thoroughly examine every emission source in the production process, accurately collect data on activity levels (such as fuel consumption, raw material input, electricity purchase, etc.), and apply the correct emission factors for calculation.
Obtain authoritative third-party verification and certification
Annual verification is a mandatory requirement: During the official implementation period, the annual emission reports submitted by importers must be accompanied by a verification statement issued by an EU-recognized verification agency. Therefore, export enterprises seeking to have their reports verified by a third-party institution with international qualifications in advance is the key to gaining the trust of importers and ensuring smooth customs clearance.
Enhancing the international credibility of data: An authoritative verification report serves as a "certification" label for a company's carbon emission data, effectively preventing trade disputes or penalty risks caused by data disputes. This is more persuasive than the data submitted by the company itself.
Integrating the CBAM factors into supply chain and production management
Promoting carbon management in the supply chain: The CBAM accounting may trace back to the upstream raw materials. Enterprises need to impose carbon data management requirements on key suppliers, and even consider conducting "green factory inspections" on suppliers to assess their energy consumption and emission management levels, in order to control the entire carbon footprint of their products.
Internal production process optimization: By inspecting and diagnosing the production process, potential emission reduction points can be identified. Investing in energy-saving technologies, using green energy, or improving processes to reduce carbon emission intensity at the source is the fundamental way to cope with the cost pressure of CBAM.
IV. Professional Services Empowerment: Ensuring Compliance and Competitiveness
In the face of complex international carbon regulations, professional service providers can offer end-to-end solutions for enterprises:
Carbon data accounting and management system construction service: Assist enterprises in establishing a data monitoring, reporting and verification system that complies with the requirements of CBAM.
Third-party verification and certification services: Conducted by a team with international qualifications, on-site inspections and data verification are carried out, and legally binding verification reports are issued.
Supply Chain Carbon Audit and Factory Inspection Services: Assist enterprises in inspecting and evaluating the carbon emission performance of their supply chains, ensuring the reliability of upstream data.
Conclusion
The implementation of the EU's CBAM marks the arrival of a new type of international trade rule centered on carbon. For export enterprises, the transitional period is a valuable window for data collection and capacity building. Passively waiting will lead to a huge compliance and cost crisis after 2026. Actively establishing a carbon emission management system that can withstand tests, obtaining authoritative verification and certification, and using this to drive the green transformation of production are not only strategic investments to meet compliance requirements, but also strategic choices to shape long-term advantages in the global green trade competition. It is recommended that relevant enterprises immediately initiate internal evaluations and actively seek collaboration with professional institutions to lay a solid foundation for future market access.