CBAM Checklist

1. Obligation Check — Are You Affected by CBAM?

Identify CN (Combined Nomenclature) codes for your export products Check whether your products fall under CBAM categories: steel/iron, cement, aluminium, fertilisers, electricity, hydrogen Determine whether you export directly to the EU or indirectly (through an intermediary) Identify your EU importer or representative (CBAM declarant) Check whether any exemptions apply (e.g. de minimis thresholds)

2. Calculation of Embedded Emissions

Identify all direct emissions in the production process (Scope 1) Collect energy consumption data (electricity, gas, fuel oil) per production line Calculate emissions for each CBAM good using the EU methodology Identify indirect emissions (electricity) if relevant for your sector Document all data sources and calculation methodology Validate data internally or through external verification

3. Documentation and Systems

Establish a system for continuous emissions monitoring (not just once a year) Implement a process log for recording emissions data Create a documentation retention system (min. 5 years) Designate a responsible person/team for CBAM compliance in your company Train operational teams on data monitoring requirements

4. Coordination with EU Importer

Establish contact with your EU buyer/importer regarding CBAM obligations Clarify who the CBAM declarant is — you or the EU importer Agree on format and deadlines for submitting emissions data Review contracts with the buyer — who bears the CBAM cost? Prepare a standardised form for submitting emissions data

5. Deadlines and Reporting

Register in the CBAM registry (EU importer obligation, but coordinate) Ensure Q1 data is submitted by 31 January Ensure Q2 data is submitted by 30 April Ensure Q3 data is submitted by 31 July Ensure Q4 data is submitted by 31 October From 2026: annual CBAM report by 31 May

6. Strategy for Reducing CBAM Costs