CBAM compliance for US exporters.
CBAM never sends a bill to an American company — it obliges your EU customers to declare, and pay for, the embedded emissions in the steel, aluminum, cement, fertilizer and hydrogen products they import from you. The definitive regime has been running since 1 January 2026, so the data requests reaching US plants are no longer voluntary surveys: Regulation (EU) 2023/956 defines exactly what your buyer must file. This page is the US edition of our CBAM for exporters hub — what CBAM compliance for US exporters actually involves, what to send, and how to stay the easy supplier.
Does CBAM apply to US companies?
Three facts settle most of the confusion about CBAM and US companies.
Regulation (EU) 2023/956 puts every legal CBAM duty — declarant status, the annual declaration, certificates, penalties — on the EU importer, the authorised CBAM declarant. A US producer is an operator of an installation and faces no requirement under the Regulation itself.
Your EU customer cannot file their declaration without emissions data for your goods. The Regulation and its implementing acts define exactly what they must collect from you — installation-level, product-specific and verifiable. It is not a questionnaire they invented.
Without your numbers, importers fall back on Commission default values set by Implementing Regulation (EU) 2025/2621 — carrying a 10% mark-up on 2026 imports, 20% in 2027 and 30% from 2028. Verified actual data carries no mark-up, which is why suppliers who provide it win the order.
Which US exports CBAM covers.
| CBAM goods (Annex I) | What it means for a US producer |
|---|---|
| Iron and steel | Primary and semi-finished steel, plus a limited set of downstream products already listed in Annex I — screws and bolts among them |
| Aluminum | Unwrought aluminum and aluminum products, including certain precursors |
| Cement | Cement and clinker shipments to EU buyers |
| Fertilizers | Fertilizers and certain precursors |
| Hydrogen | Hydrogen exported to the EU market |
| Electricity | In scope under the Regulation, though rarely a practical US-to-EU trade route |
Annex I, Regulation (EU) 2023/956 as amended. The proposed downstream extension (below) would broaden the finished-goods list from 2028 — still under negotiation.
Your EU customer asks because the law requires it.
Since 1 January 2026, CBAM has applied under its definitive regime. Only authorised CBAM declarants may import CBAM goods above the de-minimis threshold, and they must file an annual CBAM declaration — the first is due 30 September 2027, covering 2026 imports — and surrender certificates priced from EU ETS auction averages. Certificate sales open on 1 February 2027 and apply retroactively to the 2026 import year; the first quarterly price for 2026, EUR 75.36, was published on 7 April 2026. Your customers are provisioning that cost right now, product line by product line.
That is why an EU customer asking for CBAM emissions data is not running a sustainability survey. The declaration they sign requires embedded-emissions figures at installation level, calculated under the Commission's methodology. The EU built two channels specifically for you as a non-EU operator: the free CBAM communication template for installations, an Excel workbook for calculating and passing data to importers, and the operator module of the CBAM Registry, where a non-EU installation registers once and shares its data with every declarant that buys from it. Our plain-language walkthrough of the calculation itself is at how to calculate embedded emissions for CBAM goods.
Two nuances work in your favor. First, an EU importer bringing in less than 50 tonnes of CBAM mass goods — iron and steel, aluminum, fertilizers, cement — per calendar year is exempt, so some smaller EU customers may need nothing from you at all. Second, declarants may legally use default values instead of your data; your numbers only have to beat the default-plus-mark-up route to make you the cheaper supplier. And where actual values are declared, the data must be verified — which is a monitoring-and-records problem long before it becomes an audit problem.
In December 2025 the Commission proposed extending CBAM to a broad list of downstream, mainly steel- and aluminum-intensive product categories from 1 January 2028, with anti-circumvention measures alongside. The Council agreed its general approach on 12 June 2026, the European Parliament adopted its mandate on 15 September 2026, and as of late 2026 the file is in trilogue — the final product list is still open. If you export fabricated metal products, components or machinery rather than raw steel or aluminum, this proposal, not today's Annex I, will decide your exposure. We track it at CBAM downstream extension 2028.
A CBAM consultant for US manufacturers.
Habitat works remotely with exporters across the Balkans, Turkey and the United States — same regulation, same templates, same deadlines. For a US plant the engagement usually looks like this.
Behind the engagement sits Karbon360°, our own platform for turning energy and production data into structured, auditable greenhouse-gas inventories — built on the GHG Protocol, with the country- and installation-specific factors CBAM work demands.
Frequently asked.
Does CBAM apply to US companies?
Not directly. Every legal obligation under Regulation (EU) 2023/956 — declarant status, the annual declaration, buying and surrendering certificates, penalties — sits on the EU importer, the authorised CBAM declarant. A US manufacturer participates as an operator of an installation: the Regulation defines what data your EU customers must obtain about your goods, so the practical obligation reaches you through their purchase orders rather than through EU law.
Our EU customer is asking for CBAM emissions data. What exactly do they need?
Installation-level embedded emissions for each CBAM good they buy from you, calculated under the Commission's methodology — not a company-wide carbon footprint and not an estimate per dollar of revenue. The standard vehicles are the Commission's CBAM communication template for installations and, in the definitive period, the operator module of the CBAM Registry. If you already keep a GHG Protocol scope 1 and 2 inventory, much of the input data exists; allocating it per product and per installation the CBAM way is the part most plants need help with.
How does CBAM Registry registration work for a non-EU operator?
The CBAM Registry has a dedicated operator module, built exclusively for non-EU operators of installations. You register your installation once and can then share installation and emissions data with every authorised declarant that imports your goods — instead of emailing a different spreadsheet to each customer. Habitat handles the registration and keeps the data current as your production mix changes.
Do we need an accredited verifier for our CBAM data?
It depends on the route your customers take. If they declare actual values based on your data, that data must be verified; if they fall back on Commission default values, no verification is needed, but the figures carry a mark-up — 10% for 2026 imports, 20% in 2027, 30% from 2028. In practice the choice is commercial: verified actual data usually makes your goods cheaper to import. Our job is making sure your monitoring and records would pass verification before anyone books a verifier.
Will CBAM cover finished goods from 2028?
That is the proposal, not yet the law. The Commission proposed in December 2025 to extend CBAM to downstream, mainly steel- and aluminum-intensive product categories from 1 January 2028, together with anti-circumvention measures; the Council and Parliament fixed their negotiating positions in June and September 2026 and trilogue talks are under way. Nothing is adopted and the product list is still moving — treat 2028 as a planning scenario, and watch it if you sell fabricated or finished metal goods into the EU.
Answer the next CBAM request in days.
Tell us what you make, which CN codes you ship and who buys from you in the EU. We come back with scope, timeline and price in writing — a fixed-fee quote within 48 hours.