A CBAM readiness assessment evaluates your company\x27s preparedness for the EU Carbon Border Adjustment Mechanism. Indian exporters of steel, cement, aluminium, fertilisers, hydrogen, and electricity to the EU face financial obligations from January 2026. A readiness assessment identifies gaps in emissions data, reporting processes, and compliance infrastructure before penalties apply.

EU CBAM covers six carbon-intensive product categories: cement (CN 2523), iron and steel (CN 72/73), aluminium (CN 76), fertilisers (CN 28/31), electricity (CN 2716), and hydrogen (CN 2804). India is heavily exposed in steel, aluminium, and cement exports to the EU.

Not yet. India\x27s Carbon Credit Trading Scheme (CCTS) compliance market rules were notified by BEE in June 2025, and the voluntary market is operational. However, CCTS credits are not currently recognised for CBAM carbon price deduction under EU Regulation 2023/956 Article 9. Indian exporters currently face 100% CBAM liability with no carbon price credit.

The EU Omnibus Simplification Regulation (EU) 2025/2083 adopted on 26 February 2025 introduced significant CBAM modifications: simplified reporting for small importers importing less than 150 tonnes CO2e per year, extended use of EU default emission values beyond the original 2028 deadline, and adjusted authorised declarant registration thresholds.

CBAM allows two approaches: actual facility-level data (measured at the installation producing the goods) or EU default values from Implementing Regulation (EU) 2023/1773 Annex III. Default values are typically higher, so exporters with cleaner production benefit from reporting actual data. The Omnibus Regulation 2025/2083 extended the deadline for mandatory actual values.

The first annual CBAM declaration covering 2026 calendar year imports is due by 31 May 2027. Authorised CBAM declarants must report quantities imported, embedded emissions per product, CBAM certificates surrendered, and any carbon price already paid in the country of origin.

At current EU ETS prices (~EUR 62/tCO2), Indian hot-rolled steel exports face approximately EUR 3,300 per 1,000 tonnes in 2026 (2.5% coverage) rising to approximately EUR 130,000 per 1,000 tonnes at full phase-in in 2034 (100% coverage). Mid-size Indian steel exporters face annual exposure of INR 15-40 crore at full implementation.

EU importers must apply to their national competent authority for authorised CBAM declarant status. The process requires: an EORI (Economic Operators Registration and Identification) number, proof of economic activity in the EU, a declaration of no serious customs or tax infringements, and financial capacity to purchase CBAM certificates. Indian exporters themselves do not register \x97 their EU importers do.

Key documents include: CBAM declarant authorisation (EU importer), CN code product classification, embedded emissions data (actual facility measurements or EU default values), emission factor sources and methodology documentation, carbon price payment receipts from country of origin (if applicable), quarterly and annual CBAM declaration forms, and verification reports from accredited verifiers.

CBAM coverage increases annually as EU free allocation to domestic producers is phased out: 2.5% (2026), 5% (2027), 10% (2028), 22.5% (2029), 48.5% (2030), 61% (2031), 73.5% (2032), 86% (2033), and 100% (2034). This means CBAM liability roughly doubles every 2-3 years through the transition period.