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What is CBAM and which goods does it cover?
CBAM was set up by Regulation (EU) 2023/956 to put a price on the carbon emitted when certain goods are produced outside the EU, matching the price paid by EU producers under the EU Emissions Trading System[1]. It covers cement, iron and steel, aluminium, fertilisers, hydrogen and electricity. After a reporting-only transitional period from October 2023 to the end of 2025, the definitive regime began on 1 January 2026[2].
What changed in 2026?
| Item | Rule |
|---|---|
| Who is covered | EU importers bringing in more than 50 tonnes a year of cement, iron and steel, aluminium and fertilisers |
| Importer status | Only authorised CBAM declarants may import above the threshold |
| Annual declaration | Due by 30 September of the following year; the first, for 2026 imports, by 30 September 2027 |
| Certificates | Sold from February 2027, with prices linked to the EU ETS |
| Verification | Actual emissions data must be verified by an accredited verifier; default values need no verification |
Source: Regulation (EU) 2025/2083 amending the CBAM Regulation[2][3].
What data does a MENA exporter need to provide?
The EU importer declares the emissions embedded in each good, and those numbers come from the producing installation. That means direct emissions from fuels and processes, electricity used in production, emissions in key precursor materials and production volumes, calculated with the EU method[3]. The data builds on the same records as a company's Scope 1 and 2 accounting; see the guide on Scope 1, 2 and 3 emissions. Where an exporter cannot provide data, the importer must use default values, which are set conservatively.
How should an exporter prepare, step by step?
- Confirm which products fall under CBAM, by their customs (CN) codes.
- Ask EU customers what data they need, in which format and by when.
- Set up monitoring of fuels, process emissions, electricity and production at installation level.
- Calculate embedded emissions with the EU method, product by product.
- Have actual emissions data verified by an accredited verifier.
- Record any carbon price paid in the country of production, which can reduce the certificates the importer must surrender[1].
Where independent support helps
An emissions specialist sets up the monitoring plan, calculates embedded emissions and prepares the data for an accredited verifier. Otibara supports industrial companies with installation-level carbon accounting and energy audits.
Common questions
Does CBAM apply to exporters in Lebanon and the wider MENA region?
Yes, for covered goods exported to the EU. Only a few countries linked to the EU Emissions Trading System, such as Norway and Switzerland, are exempt[1].
Who pays the CBAM cost?
The EU importer buys and surrenders CBAM certificates. In practice the cost is reflected in prices and contracts, so lower verified emissions can be a commercial advantage for the exporter.
What are default values?
Values published by the European Commission for each product and country, used when actual data is missing. They are set conservatively, so verified actual data is usually more favourable[3].