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EU CBAM 2026: New Guidance for Non-EU Manufacturers and What Exporters Should Do Now

The EU has issued ten new CBAM guides for non-EU producers. Learn what exporters should prepare on embedded emissions, default values, verification and customer data.

Industrial production facility supplying carbon-intensive goods to the European market

Photo: LOGILEE · AI Generated

Key Takeaways

The European Commission published a new package of ten CBAM guidance documents for installation operators outside the European Union on 14 August 2026.

The documents provide practical guidance for the definitive phase of the Carbon Border Adjustment Mechanism, including embedded-emissions calculations and sector-specific guidance for cement, hydrogen, fertilisers, iron and steel, aluminium and electricity.

The Commission also published corrected CBAM default values on 10 August following targeted corrections introduced by Commission Implementing Regulation (EU) 2026/1740.

For non-EU manufacturers supplying covered products to European customers, these updates are important because EU importers increasingly need reliable emissions information from their overseas suppliers.

Why the August 2026 Guidance Matters

CBAM has moved from its transitional reporting phase into its definitive regime.

During the transitional phase, the focus was primarily on reporting embedded emissions. Under the definitive framework, CBAM certificates create a financial consequence linked to the embedded emissions of covered imports.

This makes the quality of emissions data increasingly important for both EU importers and their non-EU suppliers.

Exporters that cannot provide usable installation and emissions information may leave their EU customers dependent on applicable default values or additional compliance work.

What Did the European Commission Publish?

On 14 August 2026, the Commission published ten guidance documents designed specifically to help installation operators outside the EU.

The package includes:

  • An introduction to CBAM concepts
  • A quick guide for non-EU operators
  • Guidance on calculating embedded emissions
  • Guidance on the free allocation adjustment
  • Sector guidance for cement
  • Sector guidance for hydrogen
  • Sector guidance for fertilisers
  • Sector guidance for iron and steel
  • Sector guidance for aluminium
  • Sector guidance for electricity

For exporters, the sector-specific documents are particularly useful because emissions calculations can differ significantly depending on the production process and product concerned.

Which Products Are Covered by CBAM?

CBAM currently covers specified goods in carbon-intensive sectors including:

  • Iron and steel
  • Aluminium
  • Cement
  • Fertilisers
  • Hydrogen
  • Electricity

Coverage is determined by the tariff classifications listed in the applicable CBAM legislation. Exporters should therefore verify the CN code used by their EU customer rather than relying solely on a general product description.

What Non-EU Manufacturers Need to Provide

Although the EU importer is generally responsible for CBAM obligations at import, much of the underlying production information originates with the manufacturer outside the EU.

Depending on the product and production route, customers may request information relating to:

  • Installation identification
  • Production processes
  • Direct emissions
  • Relevant indirect emissions where applicable
  • Production quantities
  • Embedded emissions calculations
  • Supporting monitoring data

The exact information required depends on the applicable CBAM methodology and product sector.

Do Not Use Old Default Values Without Checking

Another important August update concerns CBAM default values.

The Commission published corrected default values on 10 August 2026 following targeted corrections introduced by Commission Implementing Regulation (EU) 2026/1740.

Businesses using spreadsheets, internal databases or consultant templates containing earlier values should therefore verify that their reference data has been updated.

The Commission notes that the legally binding values are those established in the relevant implementing regulation, while the downloadable Excel file is provided for information purposes.

Why Actual Emissions Data Matters

For many exporters, CBAM is becoming a commercial issue as well as a regulatory one.

An EU buyer comparing suppliers may increasingly consider not only the purchase price but also the carbon cost associated with imported goods.

Manufacturers that can provide reliable emissions information may therefore be in a better position to help customers calculate their CBAM exposure accurately.

This is particularly relevant for steel and aluminium supply chains, where different production routes can have substantially different emissions profiles.

What Exporters Should Do Now

1. Confirm Product Scope

Verify whether products supplied to EU customers fall within CBAM tariff classifications.

2. Identify the Manufacturing Installation

Determine which facility produces the goods and which production processes contribute to their embedded emissions.

3. Review the New Sector Guidance

Use the Commission's August 2026 sector-specific guidance relevant to your product.

4. Check Emissions Data

Determine whether the installation already collects the production and emissions data required by the CBAM methodology.

5. Update Default-Value References

If internal systems or customer calculations use CBAM default values, verify that they reflect the corrected values published in August 2026.

6. Coordinate With EU Customers

Ask customers which data format and reporting cycle they require. Providing technically correct information in an unusable format can still create operational delays.

A Practical Supplier Checklist

  • Confirm the CN code of products sold into the EU.
  • Determine whether the product falls within CBAM scope.
  • Identify the relevant manufacturing installation.
  • Download the applicable August 2026 Commission guidance.
  • Map the production process used for the exported goods.
  • Confirm available emissions and production data.
  • Review the applicable calculation methodology.
  • Check whether default values used internally are current.
  • Agree on data exchange procedures with EU customers.
  • Keep supporting records for verification and future reporting.

CBAM Is Becoming Part of Supplier Management

CBAM should no longer be treated solely as an EU importer's customs problem.

The importer may hold the legal reporting obligation, but the quality of the declaration depends heavily on data originating at the manufacturing installation.

As a result, emissions information is increasingly becoming part of ordinary supplier documentation alongside specifications, certificates of origin, invoices and other trade-compliance records.

Conclusion

The European Commission's August 2026 guidance gives non-EU manufacturers a more detailed roadmap for operating under the definitive CBAM regime.

For exporters of steel, aluminium, cement, fertilisers, hydrogen and other covered products, the priority should now be to confirm product scope, understand the sector methodology, collect reliable installation-level data and establish a repeatable data exchange process with EU customers.

Companies should also review calculations that rely on default values following the Commission's August corrections.

CBAM compliance is increasingly becoming part of the commercial relationship between EU importers and global manufacturers, making early data readiness a practical competitive advantage.

FAQ

What did the EU publish on CBAM in August 2026?

On 14 August 2026, the European Commission published ten guidance documents for installation operators outside the EU, including general methodology and sector-specific guides. Corrected default values were also published on 10 August.

Do non-EU exporters have CBAM responsibilities?

The EU importer generally carries the relevant import-side CBAM obligations, but overseas manufacturers are an important source of the production and emissions information required for compliance.

Which industries have dedicated guidance?

The August package includes sector-specific documents for cement, hydrogen, fertilisers, iron and steel, aluminium and electricity.

Were CBAM default values changed?

The European Commission published corrected default values on 10 August 2026 following targeted corrections under Commission Implementing Regulation (EU) 2026/1740.

Should exporters use actual emissions or default values?

The appropriate method depends on the applicable CBAM rules and circumstances. Exporters should consult the current Commission methodology and coordinate with their EU customer rather than assuming that a default value can always be used.

Official References

This article provides general trade and regulatory information and does not constitute legal, environmental or customs advice. CBAM requirements vary according to tariff classification, production process, emissions methodology and supply-chain circumstances. Businesses should consult the current EU legislation and European Commission guidance when determining their obligations.