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CBAM for North Macedonia's steel exporters.

Iron and steel account for the largest share of North Macedonia's CBAM-covered exports to the EU — and they are produced with significant coal input. Since 1 January 2026 the EU's carbon border mechanism has applied in its definitive regime, so the emissions-data request from your EU customer is written into Regulation (EU) 2023/956, not into their goodwill. Here is what that means for Macedonian producers, and how it fits the wider Western Balkans picture.

The exposure

Where North Macedonia meets CBAM.

Germanwatch's Eurostat-based analysis ranks North Macedonia, together with Bosnia and Herzegovina, among the most CBAM-affected countries in the region. The reason is one sector above all.

Steel carries the weight

Iron and steel make up the largest share of the country's CBAM-covered exports to the EU. Annex I of Regulation (EU) 2023/956 covers the basic products plus listed precursors and a limited set of downstream items such as screws and bolts.

Electricity has no threshold

CBAM also covers electricity as a sector — and the 50-tonne de-minimis does not apply to it. Any power sold into the EU market is declared, whatever the volume.

→ Coal input decides the number

Steel produced with significant coal input carries high embedded emissions. Whether your buyer declares verified actual values or marked-up defaults is the one variable you control.

How it works

From buyer's email to accepted data.

STEP 01ScopeMatch your CN codes against Annex I of Regulation (EU) 2023/956 and map which of your EU customers are authorised declarants.
STEP 02MeasureCalculate installation-level embedded emissions using the Commission's CBAM communication template for installations.
STEP 03ShareRegister in the operator module of the CBAM Registry and pass the data to your declarants in the form they must declare.
STEP 04DefendKeep the calculation trail ready for verification, so your buyers can use actual values instead of marked-up defaults.
The legal line

Who actually owes what.

Every CBAM obligation sits on the EU side. Your customer — the authorised CBAM declarant — must hold an authorisation to import CBAM goods above the de-minimis threshold, must file the first annual declaration by 30 September 2027 for 2026 imports, and must buy certificates once sales open on 1 February 2027. The penalties for failing to surrender certificates sit on the declarant too: EUR 100 per tonne of CO2e as the base penalty under Article 26. A Macedonian operator has no legal obligation under the Regulation at all.

What you have instead is a regulation-shaped commercial reality. Regulation (EU) 2023/956 defines exactly what your customer must declare for your steel, so they cannot legally do without the data — only replace it with Commission default values under Implementing Regulation (EU) 2025/2621, marked up 10% for 2026 imports, 20% for 2027 and 30% from 2028. Verified actual emissions carry no mark-up. If the arithmetic of embedded emissions is new territory, start with our readable walkthrough on how to calculate embedded emissions; where companies want the dataset maintained rather than rebuilt every year, our platform Karbon360° keeps it live.

Dates

The deadlines your buyers are working to.

DateWhat happens
1 January 2026Definitive regime applies; only authorised CBAM declarants may import CBAM goods above the de-minimis threshold.
1 February 2027Certificate sales open on the common central platform, covering 2026 imports retroactively.
30 September 2027First annual CBAM declaration due — for 2026 imports — and certificates surrendered.
From 2028 (proposed)Downstream scope extension to mainly steel- and aluminium-intensive products — in trilogue, not adopted.

Dates per Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083.

Your buyer's declaration is only as good as the data you send them.

FAQ

Frequently asked.

Does CBAM apply to steel exporters in North Macedonia?
The legal obligation applies to your EU customer, the authorised CBAM declarant — not to you. But because iron and steel are Annex I goods, every tonne you ship into the EU must be declared with its embedded emissions, and Regulation (EU) 2023/956 defines what your customer must ask you for. In practice, Macedonian steel exporters are fully inside the mechanism through their order book.
Can my EU customer just use default values instead of asking us?
Yes — in the definitive period declarants may use Commission default values instead of actual verified emissions. But defaults used in lieu of actual data carry a mark-up: 10% for 2026 imports, 20% for 2027 and 30% from 2028, under Implementing Regulation (EU) 2025/2621. Verified actual values carry no mark-up, which is why suppliers who provide them are cheaper to buy from.
Do we need to register anywhere as a non-EU producer?
There is no registration duty. There is a channel: the operator module of the CBAM Registry exists exclusively for non-EU installation operators to register and share installation and emissions data with declarants. Most producers also use the Commission's free CBAM communication template for installations as the working format.
Is there a threshold below which CBAM doesn't apply?
The de-minimis is 50 tonnes net mass of CBAM goods per importer per calendar year — iron and steel included. Note two things: it is measured on your buyer's side, per importer, and it does not apply to electricity or hydrogen at all.
What about electricity exports to the EU?
Electricity is an Annex I sector in its own right, and the 50-tonne exemption does not cover it. Any electricity sold into the EU market falls under the declarant's CBAM obligations regardless of volume.
Talk to Habitat

Send steel data your buyer can actually declare.

One screening call tells you which CN codes are exposed and which customers will ask first. From there we build the installation dataset — with a fixed-fee quote within 48 hours.