CBAM for Indian steel exporters: your data or the default.
Your EU buyer now pays for the carbon embedded in the steel you sell them. Without your installation's verified data, they must use the EU's default value for India, whose mark-up rises from 10% in 2026 to 30% from 2028. Here is what that difference costs, per tonne, at the latest certificate price of €82.32 (Q3 2026).
What CBAM means for an Indian exporter
Since 1 January 2026 the EU's Carbon Border Adjustment Mechanism is in its definitive period. An EU company importing iron and steel goods must surrender CBAM certificates for the emissions embedded in them, less a free allocation adjustment. It declares each year's imports by 30 September of the following year; certificates go on sale in February 2027.
The importer carries the cost, so the emissions behind your steel become part of the price conversation. An importer whose imports of iron and steel, aluminium, cement and fertiliser goods total no more than 50 tonnes (net mass) in a calendar year is exempt and buys no certificates; it states the exemption in its customs declaration. Imports of electricity and hydrogen are not covered by this exemption.
Quarterly averages of EU ETS auction prices, published by the European Commission; weekly prices from 2027.
India's default values
Without verified data from your installation, the importer must use the default value for the product and its country of origin, from the India table of Implementing Regulation (EU) 2025/2621, Annex I. The default carries a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 onwards.
| Product (CN code) | Base value | 2026 | 2027 | 2028 |
|---|---|---|---|---|
| Billets 7207 11 14 | 4.270 | 4.697 +10% | 5.124 +20% | 5.551 +30% |
| Hex bolts 7318 15 82 | 5.720 | 6.292 +10% | 6.864 +20% | 7.436 +30% |
Tonnes of CO2 equivalent per tonne of product, with the year's mark-up applied.
Two worked examples
Both installations are fictional; their data packs are our published samples. Certificates per tonne are the embedded emissions less the specific embedded free allocation (Implementing Regulation (EU) 2025/2620), on actual data and on India's defaults.
| Per tonne of product | Actual data | India default, 2026 |
|---|---|---|
| Embedded emissions (t CO2e) | 0.626 | 4.697 |
| Certificates to surrender | 0.43 | 3.37 |
| Per tonne of product | Actual data | India default, 2026 |
|---|---|---|
| Embedded emissions (t CO2e) | 5.565 | 6.292 |
| Certificates to surrender | 4.08 | 4.96 |
An estimate: certificates are due on the tonnes your buyer imports into the EU, at the price of their period, and only if its imports of iron and steel, aluminium, cement and fertiliser goods exceed 50 tonnes (net mass) in the year. Actual values count only with a verifier's report.
What actual data takes
Your installation's direct emissions for the reporting period, from the fuels and process inputs it uses, and the precursors it buys (such as pig iron or wire rod) with their own embedded emissions, from your suppliers or at default values where they have none. For iron and steel, emissions from the electricity you use do not count. They are set out in the EU's communication template, which you send your buyer, and checked by an accredited verifier.
Our CBAM data packfills the official communication template and the operator's summary emissions report (Implementing Regulation (EU) 2025/2547, Annex IV) from your installation data, and a named person reviews both before release. It prepares the data your verifier checks; it is not itself a verification.
Frequently asked questions
Does CBAM apply to Indian exporters directly?
The obligation sits with the EU importer, the authorised CBAM declarant, who declares the embedded emissions of the goods and surrenders certificates for them. The exporter's part is the data: without your installation's verified emissions, the importer has to use the EU's default value for India.
What happens if I give my buyer no data?
The importer uses the default value for your product and India, with the year's mark-up, and the default free allocation. For most installations that means more certificates per tonne than their own data would give; the two worked examples above show the difference for a steel mill and a bolt maker.
Which of my products are covered?
Iron and steel goods listed in Annex I of Regulation (EU) 2023/956, from pig iron and semi-finished products to some downstream goods such as screws and bolts. Aluminium, cement, fertilisers, hydrogen and electricity are covered too; our data pack covers iron and steel today.
Do I need a verifier?
Yes, for your own values to count. Actual embedded emissions are accepted only with a report from an accredited verifier; without one, the importer must use default values.
What does the CBAM data pack cost?
The founding price for the first ten exporters is Rs 49,999 per installation for the first year (list price Rs 75,000), excluding GST, invoiced. It prepares your data and the official EU template for your buyer and your verifier; it is not itself a verification.
Give your buyer your own numbers, in their template.
Founding price for the first ten exporters: Rs 49,999 per installation for the first year (list price Rs 75,000), excluding GST.
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