CBAM Core Rules and Recent Changes

　　1. Policy PositioningCBAM (Carbon Border Adjustment Mechanism) is a "carbon tariff" imposed by the EU on the embodied carbon emissions of imported goods, aiming to prevent carbon leakage and promote global emission reduction. Covered industries: In 2025, it will cover six major industries: steel, aluminum, cement, fertilizer, electric power, and hydrogen, and it is planned to add chemical, plastic and other industries from 2026. Timeline: Transition period (2023.10-2025.12): Only need to submit carbon emission reports on a quarterly basis, no need to pay fees. Official period (from January 2026): Importers need to purchase a CBAM certificate, which is linked to the EU carbon price (currently about 146 euros/ton CO₂).
　　2. Key adjustment exemption threshold in 2025: Exemption obligation for steel, aluminum and other products with an annual import volume of less than 50 tons (covering 90% of small and medium-sized enterprises, but regulating 99% of carbon emissions). Simplified process: Non-EU companies can upload emissions data directly through the CBAM platform, reducing duplication of submissions in the supply chain. Declaration status: From 2025, it is necessary to apply for the qualification of "authorized declarant", which will be mandatory in 2026.

First, the detailed explanation of the whole process of CBAM data filling and the analysis of difficulties

　　1. Registration and Authentication ProcessEU Account Registration: a. Visit the EU registration page (link) to create an account, verify your email address and set a strong password. b. Download the EU Login mobile app and complete two-factor authentication (biometric or PIN). Authorized declarant qualification application: From 2025, the enterprise trade qualification certificate and historical export data must be submitted, and it will become mandatory in 2026. Difficulty: The credit code of Chinese enterprises needs to be prefixed with the country (such as CN914000001MOXF00T), otherwise the review may fail due to the wrong format.
　　2. Data collection and accounting requirementsCarbon emission accounting scope: direct emissions: fuel combustion, chemical reactions, etc. (such as steelmaking coke consumption). Indirect emissions: Purchased electricity (using the country of origin grid factor or EU defaults, e.g. China 0.5703tCO₂e/MWh). Supply chain traceability: If the carbon emissions of raw materials (such as steel and aluminum ingots) account for ≥20%, supplier verification data must be provided, and the default value is prohibited. Case: An aluminum products company was taxed by the EU at the default value (higher than the actual 15%) because it did not trace the data of electrolytic aluminum suppliers, and the cost increased by 10%.
　　3. Filling and Submission Operation Filling Template: Using the EU "CBAM communication template", it contains four sub-tables: Sub-table A: enterprise information, production routes, and raw material sources; Sub-Table B: Direct Emissions Classification by Fuel Type; Sub-Table C: Calculation of indirect emissions (with indication of power source and factor); Sub-Table D: Production and Emission Allocation Logic (Allocation by Weight or Process) Sub-Table E: Precursor Product Data, Embodied Carbon of Raw Materials System filling: Log in to the CBAM platform to upload the template, and the system automatically verifies the data format and generates a unique report number. Difficulty: The XML file needs to accurately match the EU CN code (8 digits), which is different from the global HS code (10 digits). For example, the CN code for cold-rolled steel plate is 7209.15.00, while the HS code is 7208.10.00.
　　4. Submission time requirement transition period (2025): quarterly reports must be submitted within 1 month after the end of each quarter (e.g. Q1 reports must be completed before April 30). Official period (from 2026 onwards): Annual report must be submitted by May 31 of the following year, with a fine of 10-50 euros/tonne CO₂ for overdue.

Second, key challenges and countermeasures

　　1. Compliance risk and cost pressure: The gap between China's carbon price (estimated 200 yuan/mt in 2030) and the EU's (146 euros/mt) will drive up export costs. For example, the cost of steel exports may increase by 900 yuan/ton, and profits will fall by 13.7%. Anti-circumvention clause: Strictly investigate the split order, false data reporting and other behaviors, and the offender will be fined 10-50 euros/ton CO₂.

　　2. Data transparency for supply chain management and technology upgrading: Establish a carbon data sharing mechanism for suppliers, and give priority to green electricity certified suppliers. Low-carbon technologies: Invest in electric furnace steelmaking, green hydrogen production, and apply for international green power certification (such as I-REC) to hedge carbon tariffs. 3. Risks of extending long-term policy uncertainty: In the second half of 2025, the EU will assess the feasibility of including chemicals, plastics, and indirect emissions (e.g. electricity for transport). International linkage: Similar policies are brewing in other regions, and multiple carbon barriers may squeeze market share.