CBAM compliance services for exporters to the EU

CBAM puts a carbon price on the emissions embedded in certain goods imported into the EU, so that imports carry the same carbon cost as goods made inside the EU under the EU Emissions Trading System (EU ETS). From October 2023 to the end of 2025 it ran in a transitional phase, in which importers filed quarterly reports on embedded emissions but paid nothing. Since 1 January 2026 the definitive regime applies, and with it a financial obligation.

Importers of CBAM goods, or their indirect customs representatives, that import more than 50 tonnes a year must apply for the status of authorised CBAM declarant. They buy CBAM certificates from the national competent authority in their EU country. The certificate price follows the auction price of EU ETS allowances: a quarterly average in 2026 and a weekly average from 2027. Each year they declare the emissions embedded in their imports and surrender the matching number of certificates. If a carbon price has already been paid during production, the corresponding amount can be deducted.

The scope may widen. In December 2025 the European Commission proposed extending CBAM to certain downstream goods and adding anti-circumvention measures (proposal COM(2025) 989). It is a proposal, not yet law, but makers of steel and aluminium products have reason to start collecting data now.

Under CBAM the legal obligation sits with the EU importer, but the importer cannot measure the emissions of a furnace or a kiln it does not run. For each declaration it has two options: report actual emissions, verified, or use the default values published by the EU.

Actual emissions are monitored and calculated by the operator of the installation outside the EU, following the CBAM methodology. They are then checked by an independent verifier accredited by an EU national accreditation body, and verification is done at the level of the installation where the goods are made. Default values are set by the EU per product and do not reflect how your own plant performs. If your installation is cleaner than the default, verified actual data is how your buyer can show it, and how you stay competitive against other suppliers.

So that operators do not have to send the same data to every customer, the CBAM Registry has a portal for operators of installations outside the EU (O3CI). Operators register, upload their installations and emissions data once and share it with declarants, with confidential treatment of business-sensitive data. Declarants then pull the verified figures into their declarations.

Whether you sell steel to a distributor in Rotterdam or aluminium to a manufacturer in Germany, the groundwork is the same. Start with the products, then the plant, then the handover to your buyers.

Our team takes exporters through the process, and CBAM declarations can be drafted with Formist, our AI agent. The work follows four steps.

Our CBAM work in China is run from our Shanghai office, and it is tied into the platforms that Chinese exporters and the authorities around them already use.

In July 2024 WeCarbon's cross-border green compliance services went live on the Shanghai Green and Low-Carbon Supply Chain Public Service Platform, which the Baoshan District government built with the CN100 green and low-carbon supply chain alliance. Companies on that platform can reach WeCarbon directly from its carbon reduction section.

In September 2024 Shanghai E&P International, which develops and operates the Shanghai Digital Port Infrastructure, named WeCarbon a whitelisted service provider for cross-border green trade compliance on the Shanghai Electronic Port. Together we released a self-assessment tool that screens a company's exports against green trade rules in the EU, the US, the UK, Australia and other markets, with carbon border measures such as CBAM as a focus, and suggests next steps.

Aluminium, iron and steel, fertilisers and cement are all CBAM goods, so producers in the UAE and the wider Gulf that sell them into the EU receive the same data requests as anyone else. The rules do not change by country of origin: the EU importer declares, and the operator of the installation supplies embedded emissions verified by an EU-accredited verifier, or the importer uses the default values.

The deduction for a carbon price applies where a carbon price has actually been paid during production, so check what applies in your country before counting on it.

Our Dubai office is at DIFC Innovation One. Gulf exporters work with us through the same process described above, with a team in their own time zone.

CBAM declarations and other trade compliance forms can be drafted with Formist, our AI form agent. If your team prefers to prepare filings in-house with software, start there. If you want people to do the work with you, that is the service described on this page.