The EU Carbon Border Adjustment Mechanism charges your EU customer for the emissions embedded in what you sell them. We calculate those emissions at installation level, package them the way your customers have to report them, and prepare you for accredited verification.
CBAM consulting for producers of aluminium, iron and steel, cement, fertilisers, hydrogen and electricity who sell into the EU, including UAE and GCC exporters: applicability and exposure review, installation-level embedded emissions calculation under the CBAM methodology, operator emissions reports and data packs for EU importers, and readiness for verification by an accredited CBAM verifier. ESGweise is not a CBAM verifier; verification is carried out by a verifier accredited in the EU.
What CBAM is, and who it reaches outside the EU
CBAM puts a carbon price on six kinds of goods imported into the EU: aluminium, iron and steel, cement, fertilisers, hydrogen and electricity. Its purpose is to charge imports broadly what EU producers already pay under the EU Emissions Trading System.
The definitive period began on 1 January 2026. The legal obligation sits with the EU importer, the authorised CBAM declarant, who declares the emissions embedded in its imports each year and surrenders certificates to cover them. Importers bringing in less than 50 tonnes of CBAM goods a year are exempt, except for hydrogen and electricity, so the mechanism now falls on serious industrial buyers.
A producer outside the EU has no direct obligation. What it has is a customer who can only use real emissions figures if the producer supplies them, calculated to the CBAM rules and verified. That makes CBAM a commercial question for exporters in the UAE, the wider GCC and everywhere else, and it applies whether you ship direct, sell through a trader or supply a precursor to another producer whose goods end up in the EU.
What an EU importer now needs from a non-EU producer
Your customer chooses between two bases for its CBAM reporting. Which one it can use depends on you.
- Actual embedded emissions: your installation's own figures per tonne of each good, calculated under the CBAM methodology for the calendar year and verified by an accredited CBAM verifier. Only you can produce these.
- Default values: country-specific figures set by the Commission, used when verified actual data is not available. For goods other than electricity they carry a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 (1% for fertilisers), so they are designed not to understate emissions.
For a producer whose real emissions are lower than the default, verified data is a price advantage your customer can see on every tonne. One rule makes this urgent: for goods imported in 2026, the reporting period is fixed by law as 2026. If there are no verified actual emissions for your installation for 2026, your customer must use default values for everything it imported from you this year.
What the exporter has to put in place
The Commission's guidance for non-EU operators sets out the work. It is closer to EU ETS monitoring than to a corporate carbon footprint, and the boundaries differ from the GHG Protocol and ISO 14067.
Monitoring boundary and production processes
Define the installation boundary and group your CN codes into production processes, so emissions can be attributed to each good you export.
Direct emissions per product
Fuels and process materials, by the calculation or measurement method the rules allow, plus attribution of measurable heat between processes. Primary aluminium has its own method for PFC emissions.
Indirect emissions where they count
Electricity consumed in each process, with the right emission factor. These count for cement and fertilisers; for iron and steel, aluminium and hydrogen, only direct emissions are in scope today.
Precursors
The embedded emissions of CBAM goods you use as inputs, such as alumina, pig iron or clinker, taken from your suppliers' verified reports or from default values where they cannot supply them.
Free allocation and carbon price data
The data needed to calculate the free allocation adjustment, and evidence of any carbon price effectively paid in your country, certified independently, since only an evidenced price can reduce your customer's obligation.
Monitoring plan, controls and verification
A written monitoring plan in English with data flow controls, an annual operator emissions report in the Commission's template, and verification by an accredited CBAM verifier, normally with a site visit.
The CBAM timeline that matters to exporters
- October 2023 to December 2025: transitional period. Quarterly reporting by importers, no payment.
- October 2025: Regulation (EU) 2025/2083 simplifies CBAM and introduces the 50 tonne annual threshold.
- 1 January 2026: definitive period begins. Liability accrues on every tonne imported, and 2026 imports are measured against your 2026 data.
- From September 2026: EU accreditation bodies accredit the first CBAM verifiers.
- Early 2027: first verification reports on 2026 data.
- 1 February 2027: certificate sales open. 2026 imports are priced at each 2026 quarter's average EU ETS auction price; the Commission published EUR 82.32 for the third quarter on 5 October 2026.
- 30 September 2027: first annual CBAM declaration and certificate surrender, covering 2026 imports. The same deadline applies every year after.
- 2034: free allocation for EU producers in these sectors ends and CBAM covers embedded emissions in full.
Two things are still moving. In December 2025 the Commission proposed extending CBAM to some downstream steel and aluminium products and tightening the anti-circumvention rules; that proposal is still with the Parliament and Council. And whether any GCC carbon pricing instrument would count as a deductible carbon price is not settled; we set out the argument in CBAM or a GCC carbon price.
How ESGweise helps CBAM exporters
Applicability and exposure review
Which of your CN codes are in scope, which customers it affects, how your likely emissions compare with the default values, and a fixed quote for the rest.
Embedded emissions calculation
Boundary, production processes, direct and indirect emissions, precursors and free allocation data, calculated to the CBAM methodology and documented in a monitoring plan your team can run every year.
Data packs for EU customers
The operator emissions report in the Commission's template, help registering in the CBAM Registry if you choose to, and plain answers for the customers and traders asking you for data.
Readiness for verification
A pre-verification review of your data, evidence and controls, then support through the accredited verifier's document review, site visit and findings.
- ESGweise: AED 3,000 per consultant day, quoted as a fixed scope after the initial review
- Verification: carried out and charged separately by a CBAM verifier accredited in the EU, which you appoint. ESGweise is not a CBAM verifier.
CBAM data sits alongside the rest of your carbon work, and the same installation data can feed a product carbon footprint or a decarbonisation plan. For an example, see our ASI and CBAM work with a GCC aluminium and recycled metals manufacturer, and for the regional picture, what the definitive regime means for GCC aluminium and steel exporters.
CBAM Compliance: questions we hear most
What is CBAM?
CBAM, the EU Carbon Border Adjustment Mechanism, puts a carbon price on certain goods imported into the EU so that importers pay broadly what EU producers pay under the EU Emissions Trading System. It covers cement, iron and steel, aluminium, fertilisers, hydrogen and electricity. The reporting-only transitional period ran from October 2023 to the end of 2025, and the definitive period began on 1 January 2026. EU importers now declare the emissions embedded in what they bring in each year and surrender CBAM certificates for them.
Does CBAM apply to UAE exporters?
Not as a direct legal obligation. The obligation sits with the EU importer, the authorised CBAM declarant. There is no exemption for the UAE or the other GCC states, though, and the importer can only use your real emissions if you, the producer, monitor them under the CBAM rules and have them verified. If you cannot supply that, your customer has to use the Commission's default values, which carry a mark-up. So the obligation is legal for your customer and commercial for you. It also reaches you indirectly if you sell through traders or supply a precursor to another producer whose goods go to the EU.
What data does my EU customer need from us for CBAM reporting?
For each installation and each type of good: the quantity produced in the calendar year, the specific direct emissions per tonne, indirect emissions from electricity where they are in scope (cement and fertilisers; for iron and steel, aluminium and hydrogen only direct emissions count), the embedded emissions of any precursors you used, the data needed to calculate the free allocation adjustment, any carbon price effectively paid in your country with evidence, and a verification report from an accredited CBAM verifier. Where actual emissions are used, the Commission's operator emissions report template is mandatory.
What are CBAM default values?
Default values are the emissions per tonne the Commission has set for each CBAM good, by country of origin, for use when verified actual data is not available. They are published in Implementing Regulation (EU) 2025/2621, corrected in July 2026. Default values for goods other than electricity are increased by a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028, with a lower 1% mark-up for fertilisers. The Commission says it should in most cases be better for importers to use actual values where they exist, which is why a low-emitting producer gains from measuring.
When does CBAM start charging?
The liability has accrued on imports since 1 January 2026, but no certificate can be bought until sales open on the common central platform on 1 February 2027. Importers must then buy and surrender certificates for their 2026 imports by 30 September 2027, the same day the first annual CBAM declaration is due. Certificates for 2026 imports are priced at the average EU ETS auction price of the quarter in which the goods were imported. From 2027, importers must hold certificates covering at least 50% of the year's embedded emissions at the end of each quarter. The charge also starts small, because it phases in as free allocation for EU producers phases out, reaching full coverage in 2034.
Do we need our CBAM emissions verified?
Yes, if your customer is to use your actual emissions rather than default values. Verification must be done by a verifier accredited for CBAM by a national accreditation body in the EU, for your sector, and the first verification normally includes a physical site visit to your installation. The first accreditations were expected around September 2026 and the first verification reports in early 2027. ESGweise is not a CBAM verifier. We build the monitoring plan, calculations and evidence a verifier will test, and the verifier must be independent of that work.
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