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FREQUENTLY ASKED QUESTIONS

Frequently Asked Questions About CBAM

We've collected the questions we hear most often about CBAM. If you can't find what you're looking for, get in touch.

Who does CBAM apply to?

CBAM applies to non-EU producers exporting iron & steel, aluminium, cement, fertilizer, electricity, or hydrogen products to the EU, and to the companies that import those products into the EU. Clarifying whether your exports fall within scope is the first step.

Our overall CBAM guide

What are the 6 sectors CBAM covers?

Iron & steel, aluminium, cement, fertilizer, electricity, and hydrogen. Each sector has its own emissions sources and calculation approach.

Our cement sector guide

Are small-volume exports exempt from CBAM?

CBAM regulation does provide for an exemption for low-value, small-volume consignments. However, the thresholds and their scope can change over time, so we'd recommend confirming the current exemption conditions against the current CBAM regulation.

What are the penalties for CBAM non-compliance?

EU CBAM regulation provides for penalties in cases such as incomplete or inaccurate declarations and failure to acquire the required certificates. We'd recommend checking official EU sources for current penalty amounts — giving a specific figure here could be misleading.

Who is an Authorised CBAM Declarant (ACD), and who needs to apply?

ACD status authorizes a party to import CBAM-covered goods into the EU; the application is usually filed by the EU-based importer. As the exporter, though, being ready with the right data and documentation makes your importer partner's application considerably easier.

Our registry and ACD guide

Who carries out CBAM verification?

Verification is carried out by independent bodies accredited to the EN ISO/IEC 14065 standard with greenhouse gas verification authorization.

Our verification process guide

What do I need to use actual values?

For actual values to be accepted by the EU, your facility's emissions data needs to be verified by an accredited verifier. Unverified data may have to fall back on default values instead.

Actual value vs. default value comparison

Is using default values a disadvantage?

Usually, yes — EU-set default values tend to come out higher than your actual production data, which can mean a higher certificate cost.

Our worked cost case study

How are CBAM certificates purchased, and how is the price set?

Certificates are purchased through a central EU registry system, with pricing updated on a periodic basis. Pricing is set with reference to the EU Emissions Trading System (ETS).

Our certificate prices and calendar guide

Is a monitoring plan mandatory?

Yes — the monitoring plan is the foundation of reporting and verification. Without this document, which defines what data is collected, how, and how often, running a sound reporting process isn't really possible.

Our monitoring plan guide

Is there a special calculation method for aluminium exporters?

Yes — PFC emissions from aluminium production are calculated using the overvoltage method rather than standard approaches. This requires sector-specific technical expertise.

Our aluminium SEE calculation guide

Are indirect emissions also reported for the iron & steel sector?

While reporting in the iron & steel sector focuses mainly on direct emissions, correctly separating out indirect emissions matters for energy-intensive routes like electric arc furnaces.

Our iron & steel sector guide

What does my EU buyer (importer) expect from me?

Your EU importer will expect product-level emissions data from you — ideally verified actual values — plus supporting documentation. Not being able to provide this means extra cost for your importer and a competitive disadvantage for you.

Our EU importer's perspective guide

How should I prepare for a CBAM audit or verification?

Assembling your documentation (monitoring plan, production data, energy invoices) ahead of time, reviewing your internal controls, and reaching out to your verifier early are the most important steps.

Our audit preparation checklist

How much could CBAM cost me?

This varies significantly by product group, export volume, and whether you use actual or default values. To see the calculation logic through a concrete example, take a look at our worked cost case study.

Our cost calculation case study

What exactly changes in 2026?

2026 is the year CBAM moves into its definitive period. ACD status becomes central during this period, and the infrastructure for certificate purchasing is put in place; the actual certificate purchase and surrender obligation becomes operational in 2027.

Our pillar guide

Is CBAM reporting the same thing as the EU ETS?

No, they're different mechanisms. The ETS is a carbon pricing system covering producers within the EU; CBAM aims to subject imports from outside the EU to a comparable cost. CBAM certificate pricing is set with reference to ETS prices.

How does B2Z Advisory support the CBAM process?

We provide end-to-end consulting — from impact analysis to emissions calculation, monitoring plan preparation, and the reporting and verification process.

Our services

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