CBAM Could Make Your Products More Expensive
CBAM (Carbon Border Adjustment Mechanism) is an EU measure that puts a cost on the carbon emitted when producing certain imported goods: iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. Its definitive phase began on 1 January 2026. EU importers carry the legal obligation, but Thai exporters are asked for carbon data and may face pricing pressure.
What Is CBAM and Why Did the EU Introduce It?
The EU Emissions Trading System (EU ETS) gives European factories a carbon cost. CBAM is designed so that carbon-intensive imports carry a similar cost to goods made inside the EU, preventing production from shifting to countries without carbon pricing.
In simple terms, the more carbon a product emits during production, the more the EU importer pays, and that cost is likely to flow back into the price paid to exporters.
CBAM Timeline Exporters Should Know
- Oct 2023 – Dec 2025: Transitional phase. EU importers reported emissions quarterly with no payment required
- 1 Jan 2026: Definitive phase began. Goods imported from this date start accruing CBAM costs
- 1 Feb 2027: CBAM certificate sales open on the EU central platform
- 30 Sep 2027: Deadline for the annual declaration and certificate surrender covering 2026 imports
Although no certificates are purchased in 2026, carbon data for goods shipped this year will be used to calculate costs in 2027.
4 Things Thai Exporters Need to Understand
1. Carbon Reporting
EU importers must report the embedded emissions in their goods. That data has to come from the producing factory, so Thai exporters are often asked for energy use and production process information.
2. Higher Costs on the EU Side
CBAM certificate prices follow EU ETS allowance prices. If your products have high emissions, buyers may negotiate lower prices or switch to lower-carbon suppliers.
3. Covered Goods
CBAM currently covers iron and steel, aluminium, cement, fertilisers, hydrogen and electricity, including certain products made from these materials, such as bolts, screws and steel structures. Check your product's CN code to confirm. The EU has also proposed extending the scope to more downstream products, which exporters should monitor.
4. Supplier Data
If importers cannot obtain verified actual emissions data, they may need to use EU default values, which are usually higher than actual emissions and raise costs. Exporters who provide complete data quickly gain a competitive advantage.
Who Is Responsible for CBAM?
The legal obligation sits with the EU importer or its indirect customs representative. Importers bringing in more than 50 tonnes of CBAM goods per year must hold authorised CBAM declarant status, while those at or below 50 tonnes per year are exempt (electricity and hydrogen excluded).
Thai exporters do not file with the EU directly, but in practice importers pass data requirements and costs back to suppliers through data request forms, contract terms or price negotiations.
How Thai Exporters Should Prepare
- Check whether products shipped to the EU fall under CBAM based on their customs codes
- Ask your importer what data they need, in what format and by when
- Start collecting energy, raw material and production process data from your factory
- Consider having carbon data checked by an accredited verifier
- Assess the impact on selling prices and prepare contract terms
- Make sure product details and codes are consistent across all export documents to avoid issues at EU customs
How CBAM Connects to Logistics
CBAM is tied to the customs declaration when goods enter the EU. Customs codes, product descriptions, weights and country of origin in export documents must be accurate and consistent with the data importers use for CBAM. Mismatches can cause delays or require document corrections later.
With over 50 years of logistics experience, Transpo Logistics provides international freight, export documentation and customs clearance, helping keep product information in your documents accurate and ready for export to the EU.
Frequently Asked Questions About CBAM
What is CBAM?
CBAM, the Carbon Border Adjustment Mechanism, is an EU measure requiring importers to pay a cost based on the carbon emitted in producing certain imported goods, so imports face a carbon cost comparable to goods made in the EU.
When does CBAM take effect?
The definitive phase began on 1 January 2026. CBAM certificate sales open on 1 February 2027, and the annual declaration and certificate surrender for 2026 imports is due by 30 September 2027.
Which products are covered by CBAM?
CBAM currently covers iron and steel, aluminium, cement, fertilisers, hydrogen and electricity, including certain products made from these materials. Check your product's customs code to confirm.
Do Thai exporters have to pay CBAM directly?
No. The EU importer is responsible, but Thai exporters will be asked for product carbon data, and costs may be passed back through price negotiations or contract terms.
What happens if actual carbon data is not available?
Importers may have to use EU default values, which are usually higher than actual emissions. This increases CBAM costs and may lead buyers to choose suppliers that provide complete data.
Exporting to the EU and want your export documents ready for new regulations? Get a free consultation with Transpo Logistics. Call 02 105 8651, email sales@transpologistics.com or visit www.transpologistics.com
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