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CBAM for Indian exporters: what your EU buyer will ask you for

By Jai Nischal Verma · Prices checked 31 Oct 2026 · EU law guide

CBAM Guide for Indian Exporters: What your EU buyer will ask you for

Law last checked: 31 October 2026. Figures below are copied from the EU texts linked in Sources. This is general information, not legal, tax or customs advice. Rules and prices change; confirm them before you import.

If you melt steel in India and sell it to a buyer in the EU, CBAM usually lands on your customer, not on a filing you make in Delhi. The person who imports the goods into the EU is the one who needs authorised declarant status, buys the certificates and files the declaration[3][1]. Your job is the number they will ask you for, and the paperwork that makes it believable.

When it becomes your problem anyway

It becomes your problem in three ordinary ways.

First, the buyer prices it in. A certificate bill on their side is a reason to reopen the contract. On the example shipment below, that line is €370.44 in 2026 before any Indian carbon price is deducted. It is an illustration, not a quote for Indian steel.

Second, they need your emissions. Actual emissions have to be calculated under the CBAM methods and, where you use them, verified[3]. If you can’t supply that, the declarant falls back on default values, which the regulation allows only on its own terms. Defaults are not printed on this page. The Commission publishes them separately, and we have not copied a default into a sentence where a reader might treat it as your mill.

Third, you might be the importer. If the Indian company is the importer and it is not established in an EU country, the indirect customs representative has to be an authorised CBAM declarant even when the shipment would have sat under the 50-tonne exemption[3]. Read that twice if you ship DDP or otherwise stay the importer of record. The declarant guide is the EU-side version of the same rule.

What an EU buyer of this example shipment would pay in 2026 on the simplified reading: €370.44 at the Q3 price, before any carbon price already paid in the country of production.Example cost split, simplified 2026 reading100 tonnes × 1.8 tCO2e/t is an example you replace. It is not an EU default value.Free-allocation factor, 2026: 97.5%175.5 of the 180 tCO2e are the slice the simplified reading does not charge in 2026.You pay 2.5%: 4.5 certificates × €82.32 = €370.44Q3 2026 published price. Carbon already paid abroad in this picture: €0.00.The legal adjustment uses a CBAM benchmark × the CBAM factor × the CSCF, not this flat percentage.Electricity is different again: its free-allocation adjustment is zero.Open the certificate cost calculator and type your own tonnes, emissions and price.
What an EU buyer of this example shipment would pay in 2026 on the simplified reading: €370.44 at the Q3 price, before any carbon price already paid in the country of production.

What this costs you

Same arithmetic as the steel page, seen from the mill: 100 tonnes, 1.8 tCO2e per tonne typed in as an example, Q3 2026 price €82.32, 2026 paid share 2.5%. The EU buyer’s simplified certificate line is €370.44[2][4].

Article 9 lets that buyer claim a reduction for a carbon price effectively paid in India, but only if it was really paid, and only after knocking off rebates or other compensation that reduced it[3]. Where default emission values are used, the reduction has to go through yearly default carbon prices, not a one-off receipt[3]. We are not publishing an Indian carbon-price figure. We did not find a single official euro amount that we could drop in as “the” price India charges, and a guessed rupee rate would be worse than a blank.

Iron and steel in Annex I count direct emissions only[3]. Send your buyer the direct figure, and say so. A footprint that folds in purchased electricity will not match what the declaration is allowed to use for those codes.

For the dates your buyer is working to, use the timeline. For the published certificate prices, use the price tracker. For a tonne figure of your own, use the calculator.

Sources

Every dated figure on this page is taken from the EU texts below. Where a shipment example uses 100 tonnes and 1.8 tCO2e per tonne, that pair is an illustration, not a published default. Law last checked 31 October 2026. See our methodology and editorial policy. General information, not legal, tax or customs advice.

  1. [1] European Commission: CBAM definitive regime (from 1 January 2026): https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en (checked 31 Oct 2026)
  2. [2] European Commission: Price of CBAM certificates (quarterly table): https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/price-cbam-certificates_en (checked 31 Oct 2026)
  3. [3] Regulation (EU) 2023/956, consolidated 20 October 2025 (CBAM Regulation): https://eur-lex.europa.eu/eli/reg/2023/956/2025-10-20/eng (checked 31 Oct 2026)
  4. [4] Directive 2003/87/EC, consolidated (EU ETS), Article 10a(1a) CBAM factor: https://eur-lex.europa.eu/eli/dir/2003/87 (checked 31 Oct 2026)
  5. [5] Commission Implementing Regulation (EU) 2025/2548 (certificate price method): https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32025R2548 (checked 31 Oct 2026)
  6. [6] Commission Implementing Regulation (EU) 2025/2620 (free-allocation adjustment): https://eur-lex.europa.eu/eli/reg_impl/2025/2620/oj/eng (checked 31 Oct 2026)
  7. [7] European Commission Guidance No. 4 on the free-allocation adjustment (CBAM factor table, including 2034 at 0%): https://taxation-customs.ec.europa.eu/document/download/3aa2c730-4f1b-4524-8f71-d9cfe4880ac7_en?filename=Guidance+No.+4+-+CBAM+calculation+of+the+free+allocation+adjustment+to+the+number+of+CBAM+certificates+to+be+surrendered.pdf (checked 31 Oct 2026)