Resource
CBAM checklist for exporters
Minimum questions and data exporters should prepare before answering a European importer.
Who it is for
Are you ready to answer the CBAM requirements of your European customers?
Why it matters
Use this checklist to verify whether you hold the minimum information a European Union importer may request in order to comply with the Carbon Border Adjustment Mechanism (CBAM).
CBAM entered its definitive phase in January 2026. A European importer of cement, steel, aluminium, fertilizers, electricity or hydrogen needs verified embedded emissions for each product from its supplier; without them, it applies higher, more expensive default values. This checklist organizes what data to prepare before that conversation.
Embedded emissions
You need direct and indirect emissions per tonne of product, calculated at installation level following the CBAM Implementing Regulation methodology.
Installation data
Prepare plant identification, production routes, energy consumption and the emission factors of the precursors used.
Threshold and timeline
There is a 50-tonne annual de minimis exemption per importer; certificate-purchase obligations apply from 2027.
What the resource covers
1. Product identification
- Tariff code (HS Code / TARIC)
- Commercial product description
- Country of origin
- Plant where it was manufactured
- Production period reported
2. Production process information
- General process diagram
- Main raw materials
- Auxiliary inputs
- Fuel consumption
- Electricity consumption
- Total output for the period
3. Carbon emissions
- Direct emissions (fuels, furnaces, boilers, processes)
- Indirect emissions (electricity)
- Methodology used
- Documented emission factors
- Evidence behind the calculations
4. Energy consumption
- Natural gas
- Diesel
- Fuel oil
- Coal
- Biomass
- Purchased electricity
- Self-generation
5. Documentary evidence
- Energy invoices
- Production records
- Consumption records
- Internal measurements
- Calculation procedures
- Named technical owner
6. Data quality
- The data is traceable
- There is documentary evidence
- Units are consistent
- The data covers the whole period
- It has been reviewed internally
7. Relationship with European customers
- Have you already received a CBAM questionnaire?
- Do you know the format requested?
- Do you have an internal owner?
- Can you answer within the deadline requested?
Result
If you answered “yes” to most questions Your company most likely holds the basic information needed to answer CBAM requests from European customers.
If you answered “no” to several questions It is worth setting up a data collection and validation system now, to avoid delays, follow-up requests or commercial risk.
What it includes
- Questions European importers usually ask
- Minimum embodied-emissions data per product
- Documentation and evidence to prepare
- Points that delay the commercial response
- How to structure your response package
Request the resource
We will send this resource as soon as it is available; in the meantime we coordinate your technical assessment
Prefer to talk it through?
Request a technical assessment and we will tell you which environmental data to prepare first