Actual data
Installation-specific emissions, verified by an accredited third party. You pay for the real carbon, which rewards a supplier who actually decarbonised.
Regulation (EU) 2023/956 · CBAM · Definitive regime from 1 Jan 2026
The border put a price on your carbon.
Cement, steel, aluminium, fertilisers, electricity, hydrogen. Import them into the EU and you pay for the carbon baked in, the same price a European plant pays. Reporting since 2023. Certificates from 2026.
The problem
Burned abroad. Billed at the border.
A tonne of steel carries its carbon in it, emitted in a furnace you do not own, an ocean away. A European mill pays for that carbon under the EU ETS. An importer used to pay nothing. From January 2026 the EU charges the carbon at the border, the same price a European plant pays, and the bill lands on the importer of record.
The emissions are made in someone else's plant, an ocean away. The only place the real number lives is that installation, and it has to travel all the way to the customs declaration.
6carbon-intensive sectors the border now prices
100%of the ETS carbon price importers pay by 2034, free passes gone
167 MtCO2 reported embedded in EU imports in 2024 alone
0free passes left at the finish. The price follows the goods in
Carbon leakage occurs when companies move carbon-intensive production abroad to countries with less stringent climate policies, or when EU products get replaced by more carbon-intensive imports.
European Commission · DG TAXUDThe flow
One declaration, built from a hundred installations.
The number you owe is scattered across every plant that made your goods. Bindu builds it in seven moves.
01 · Ask
Ask each installation for its real emissions.
Bindu reaches every third-country installation behind a shipment and asks for the activity data: direct emissions, the electricity behind them, any carbon price already paid.
activity datadirect emissionsindirect (power)carbon price paid
02 · Normalise
Map goods to CN codes and installations.
Every line maps to its Annex I CN code and the installation that made it. The declarant, the goods and the plant tie together under one EORI.
Annex I CN codeinstallation IDEORIauthorised declarant
03 · Verify
Verify with actual data, not a default.
An accredited verifier signs off the installation's emissions. Actual data beats the Commission's default values, which are set high on purpose.
accredited verifieractual > defaultAnnex IV method
04 · Calculate
Calculate the embedded emissions per tonne.
Per Annex IV: direct emissions, plus indirect for cement and fertilisers. Then deduct any carbon price already paid at origin (Article 9).
tCO₂e / tonnedirect + indirectorigin-price credit
05 · Declare
Declare it to the CBAM Registry.
The annual CBAM declaration goes to the central Registry. Only an authorised declarant may file, or a third party holding your EORI.
CBAM Registryannual declarationauthorised declarant
06 · Certificates
Buy the certificates. Hold 50% as you go.
One certificate per tonne of embedded CO2, priced off the EU ETS auction. Hold at least 50% of the running total each quarter, surrender the rest once a year.
1 cert / tonneETS-linked price50% quarterly hold
07 · Report
Surrender once a year. Keep the trail.
The declaration and surrender for a year fall due the following 30 September. Every figure stays traceable to the installation that emitted it.
surrender 30 Sepaudit trailper-installation
The scan
What the border prices, sector by sector.
CBAM covers six carbon-intensive sectors, each defined by CN code in Annex I. Some carry indirect emissions too. Pick a sector.
CementDirect + indirect emissions
CementClinker, cement, binders
CementIndirect: the electricity counts
Iron & steelAbout 478 CN codes in scope
Iron & steelDirect emissions only
Iron & steelBeams, tubes, screws, bolts
Iron & steel102.5 Mt reported in 2024
AluminiumAbout 56 CN codes in scope
AluminiumDirect emissions only
AluminiumUnwrought, bars, profiles, wire
Aluminium38.4 Mt reported in 2024
FertilisersAbout 25 CN codes in scope
FertilisersDirect + indirect emissions
FertilisersAmmonia, nitric acid, urea
Fertilisers18 Mt reported in 2024
ElectricityEmbedded emissions are direct
ElectricityPriced by interconnector
ElectricityDefault or country factor
HydrogenDirect emissions only
HydrogenThe newest sector in scope
HydrogenCarbon-intensive to produce
Cement and fertilisers carry indirect emissions, the electricity behind them; steel, aluminium and hydrogen count direct only. Iron and steel alone was 102 million tonnes of reported CO2 in 2024.
Granularity
Actual, default, or credited?
Your bill is only as honest as your emissions data. Where the number comes from is the whole cost question.
Default values
The Commission's published defaults, used where actual data is missing. Set conservatively, so the fallback almost always costs you more.
Origin credit
Any carbon price already paid where the goods were made is deducted from what you owe (Article 9), so the same tonne is never charged twice.
From 2027 the default is the exception, not the rule. Actual, verified installation data is what keeps the bill honest, and the calculation method is fixed in Annex IV.
The calendar
The clock is already running.
Reporting has run since 2023. The money starts in 2026, the first real bill lands in 2027, and the free passes run out in 2034. Two of these dates are where it gets real.
1 Oct 2023
The transitional period begins: quarterly reports on the embedded emissions of imported goods, with no payments yet.
20 Oct 2025
The Omnibus simplification (Reg (EU) 2025/2083) takes effect. A 50-tonne threshold exempts about 182,000 importers while over 99% of the emissions stay in scope.
1 Jan 2026Definitive regime
The definitive regime begins. Only an authorised CBAM declarant may import, the financial obligation starts, and the EU ETS free allowances begin to phase out.
1 Feb 2027
The first CBAM certificates go on sale on the common central platform.
30 Sep 2027First bill
The first annual CBAM declaration and certificate surrender fall due, covering 2026 imports.
2034
Free allocation to CBAM sectors is fully gone. Importers pay for 100% of embedded emissions.
The loop
The point is a level playing field.
A European plant already pays for its carbon under the EU ETS. Without a border price, the cheapest dodge was to make the steel somewhere with no carbon price and ship it in.
That is carbon leakage: the emissions do not fall, they move. CBAM closes the gap by charging imports the same carbon price, and it phases in exactly as the free ETS allowances phase out. The flip side is a reward: a clean producer abroad now undercuts a dirty one on the same shelf.
- production moves abroad
- dirtier imports undercut
- EU carbon price dodged
- emissions just relocate
How it's built
How Bindu files it.
CBAM is emissions accounting with a customs deadline. Bindu is that pipeline: installation data in, a declaration and the right certificates out. Pick a piece.
The source data
Installation collector
Reaches every third-country installation behind a shipment and gathers the activity data and any carbon price paid, in the format they keep it.
- Activity data
- Supplier outreach
- Carbon-price paid
Who files it
Report since 2023. Pay from 2026. Start now.
Bindu collects the installation data, computes the embedded emissions to Annex IV, files the declaration, and manages the certificates, so the first real bill in 2027 is a number you can defend.
Report since 2023the transitional clock is already running
Actual dataverified installation emissions, not defaults
50% heldcertificate balance tracked every quarter
Origin creditcarbon paid abroad, deducted (Article 9)
Audit trailevery figure traced to its installation