The EU’s Carbon Border Adjustment Mechanism, better known as CBAM, has entered a new phase. Since the definitive regime began on 1 January 2026, businesses producing certain carbon-intensive goods outside the EU have faced increasing pressure to provide accurate emissions data to their EU customers.
On 14 August 2026, the European Commission published ten new guidance documents designed specifically to help non-EU installation operators prepare for CBAM compliance. The guidance covers everything from core CBAM concepts and emissions calculations to sector-specific requirements for cement, iron and steel, aluminium, fertilisers, hydrogen and electricity.
For businesses exporting CBAM-covered goods into the EU, this is an important development. While the legal obligation to submit CBAM declarations sits with EU importers, non-EU producers play a critical role in supplying the verified emissions data those importers need.
What is CBAM and why does it matter to non-EU businesses?
CBAM is designed to put a carbon price on certain goods imported into the EU, helping to ensure that the carbon cost of imported products is comparable with goods produced under the EU Emissions Trading System.
The definitive CBAM regime applies from 1 January 2026 and currently covers selected goods in six sectors: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. EU importers bringing more than the 50-tonne threshold of CBAM goods into the EU must meet CBAM obligations, including obtaining authorised CBAM declarant status.
For non-EU manufacturers, the key point is that CBAM does not stop at the border. Importers need information about the embedded emissions generated during production, which means producers outside the EU increasingly need robust systems for monitoring, calculating and sharing emissions data.
What has the European Commission published?
The new guidance is made up of four general documents and six sector-specific guides. Together, they are intended to provide practical support for installation operators outside the EU, as well as authorised CBAM declarants and other stakeholders involved in the compliance process.
The four general guides cover:
- CBAM concepts and how the mechanism works
- A practical implementation guide for non-EU operators
- Methods for calculating emissions embedded in CBAM goods
- The free allocation adjustment used when calculating the number of CBAM certificates to be surrendered
The remaining six documents provide sector-specific guidance for cement, hydrogen, fertilisers, iron and steel, aluminium and electricity.
This matters because the requirements can vary significantly depending on the goods being produced and the emissions associated with their production.
The biggest change: more clarity on emissions calculations
For many non-EU operators, calculating embedded emissions is likely to be one of the most challenging aspects of CBAM.
The Commission’s new guidance provides more detail on the methodology that operators should use to monitor and calculate emissions associated with CBAM goods. This includes the information that needs to be collected at installation level and how emissions should be attributed to the goods produced.
The practical implication is that businesses can no longer treat carbon data as a broad, company-level reporting exercise. CBAM requires a more detailed understanding of emissions linked to specific installations and products.
For organisations that do not have reliable carbon accounting processes, this means establishing new data collection systems and working closely with production, procurement and sustainability teams.
Actual emissions data could become a competitive advantage
The Commission allows importers to use default values in certain circumstances, but businesses can also provide actual emissions data. Where actual values are used, the producer in the third country must provide verified emissions information covering the embedded emissions in the goods.
This could create an important commercial opportunity for lower-carbon producers.
Businesses that can accurately measure and verify their actual emissions may be better placed to demonstrate the carbon performance of their products, rather than relying on a standardised default value. Depending on the circumstances, this could make a meaningful difference to the CBAM liability associated with imported goods.
It also means carbon data is becoming increasingly important in supplier relationships. EU customers may begin asking more detailed questions about how emissions are measured, what evidence sits behind the figures and whether the data can be independently verified.
Verification is moving up the agenda
The Commission has also been developing the verification and accreditation framework for the definitive CBAM period.
CBAM verification takes place at the level of the installation where the goods are produced. Non-EU installation operators are responsible for monitoring and calculating embedded emissions in line with the CBAM methodology before providing the relevant information to an accredited verifier. The Commission expects the first accredited CBAM verifiers to be able to issue verification reports from January 2027.
On 24 August 2026, the Commission also published further guidance on CBAM verification and accreditation. This focuses on helping verifiers and accreditation bodies understand the requirements that apply during the definitive period, particularly for emissions reports covering goods imported from 1 January 2026.
For non-EU operators, the message is clear: businesses should start considering verification requirements now rather than waiting until their EU customers request a verified report, which is mandatory.
The CBAM Registry gives non-EU operators a more structured way to share data
The Commission has also introduced functionality within the CBAM Registry for operators of installations outside the EU.
The Operators of Third-Country Installations, or O3CI module, allows non-EU operators to upload and share installation and emissions data with reporting declarants. This can reduce the need to provide the same information separately to multiple EU customers and includes measures designed to protect commercially sensitive information.
For businesses supplying several customers in the EU, this could become an important part of managing CBAM compliance efficiently.
However, access to the system requires preparation. The Commission provides specific registration and access guidance for non-EU operators, including requirements around company information and supporting documentation.
What should non-EU operators do now?
The new guidance does not mean every non-EU business needs to build an entirely new compliance programme overnight. But it does make the expectations clearer.
Businesses exporting CBAM-covered goods into the EU should first understand exactly which products and installations fall within scope. From there, they should review whether they can currently collect the data needed to calculate embedded emissions accurately.
The next priority is to understand where there are gaps. This could include missing energy data, incomplete supplier information, uncertainty around emissions allocation or a lack of documented calculation methodologies.
Businesses should also speak to their EU customers. Importers remain responsible for their own CBAM declarations and certificate obligations, but producers need to understand what information customers will require, when they need it.
Finally, organisations should consider verification early. Building a robust emissions inventory is one challenge. Ensuring the underlying data, methodology and evidence can stand up to independent verification is another.
Key dates for businesses to be aware of
The definitive CBAM regime began on 1 January 2026. Under the Commission’s current timeline, the first CBAM declaration will cover imports made during 2026 and must be submitted by 30 September 2027, alongside the surrender of the relevant CBAM certificates. The Commission also expects the first verification reports for non-EU operators to become available from January 2027.
That means the data businesses are collecting today could directly affect their ability to support EU customers with their first definitive-period CBAM declaration.
CBAM is becoming a supply chain issue, not just an importer issue
The European Commission’s new guidance gives non-EU operators a clearer picture of what is expected of them, but it also highlights a broader shift.
CBAM is changing the relationship between carbon data and international trade. Producers outside the EU may not submit the CBAM declaration themselves, but they are increasingly responsible for providing the detailed, credible and potentially verified emissions information that sits behind it.
For businesses in CBAM-covered sectors, the time to understand these requirements is now. The strongest approach will be to treat CBAM as part of wider carbon management and supply chain strategy, rather than as a one-off reporting exercise.
Need support with CBAM and carbon reporting?
Understanding your CBAM data requirements is the first step. Positive Planet can help businesses monitor emissions, improve the quality of their carbon data and prepare for increasing sustainability and supply chain reporting requirements.
Speak to our team to understand how we can support your CBAM readiness.