Carbon Border Adjustment Mechanism (CBAM) is rewiring hard-to-abate industries
Updated: 2 days ago
Iron & Steel industry is no longer competing on cost, material of construction grades, and strength alone. It is now also competing on embodied carbon and emissions resulting from the production process followed.
With the European Union’s Carbon Border Adjustment Mechanism (CBAM) regulatory mandate having entered its financial phase from 1st January 2026, carbon intensity is becoming a measurable, reportable and ultimately payable variable in global trade. For steel exporters, this transforms decarbonization from a sustainability ambition into a balance-sheet consideration.
Setting the context
Carbon Border Adjustment Mechanism (CBAM) is a European Union policy instrument established under regulation (EU) 2023/956 (as amended by Regulation (EU) 2025/2083). It places a carbon price on goods imported into the EU that is equivalent to what EU producers pay under the EU Emissions Trading System (EU ETS). Its aim is to reduce global greenhouse gas emissions by incentivizing cleaner production methods and penalizing emissions intensive polluting production processes. The idea is to prevent companies from relocating production to countries with lax environmental standards, a phenomenon known as carbon leakage.
Under CBAM, exporters outside EU must provide accurate emissions data for each shipment, otherwise default values as defined by EU in the Annex I to IV of the implementing regulation would be applied for calculating total emissions, thus, raising compliance burden for the EU importers. EU importers may end up absorbing the cost or pass it back to their suppliers, which can erode supplier margins and market share in the EU.
Given the relatively higher emissions intensity of Non-EU steelmaking processes (such as usage of coal in blast furnaces for steel making), Indian steel exporters may face added levies or tightened pricing to remain competitive in international markets.
Therefore, understanding how CBAM works, its implications, and who bears the cost is essential for businesses and policymakers alike.
Key aspects of CBAM regulations include:
Carbon pricing: CBAM requires reporting and verification of embedded greenhouse gas emissions tied to the production of goods covered in its scope. Coverage is product-specific by CN (Combined Nomenclature) code - not sector-wide. Each product must be individually verified against Annex I of Regulation (EU) 2023/956. Then a cost is assigned to final emissions value to make a level playing field for all businesses involved. Refer this link to check if your exports fall into the scope of CBAM taxation or not.
Here’s a simple formula to remember: CBAM cost = quantity (metric tonnes) × total embedded emissions (CO2e / metric tonnes) × weekly EU ETS price
Border adjustments: CBAM certificate purchase costs apply to imports from January 2026 onwards. EU importers must get themselves registered with DG Taxud by 31st March 2026 as authorized declarants to continue importing material and surrender CBAM certificates covering 2026 imports with their first annual CBAM declaration, due in 2027. To be able to do this, they are asking their suppliers for providing emissions data embedded in the goods on a quarterly basis in 2026 (in most cases). The emissions data is important for estimating their approximate CBAM expenditure at the end of the year and thus affects business financials.
Who Must Register: EU importers (or their indirect customs representatives) importing more than 50 tonnes of covered goods (iron & steel, aluminum, cement, fertilizers, hydrogen, electricity) per calendar year.
Consequences of Non-Registration: A valid CBAM registration number will be required for customs clearance; without it, goods cannot be cleared.
Process: Applications for authorization must be submitted via the CBAM Registry.
CBAM certificate price: According to the European Commission, Carbon Border Adjustment Mechanism (CBAM) certificate prices for 2026 will be calculated on a quarterly basis. Each quarter’s price will be based on the average auction price of carbon allowances in the EU Emissions Trading System (EU ETS), ensuring that CBAM prices remain aligned with the EU’s domestic carbon market.
The first certificate price under CBAM was published by the EC on April 7 2026, second quarter certificate price was published by the EC on Jul 6, 2026 and third quarter price as published by thhe EC on Oct 5, 2026. Publication schedule for CBAM certificate prices in 2026 is as follows:
Applicable Period | First Quarter (Q1 2026) | Second Quarter (Q2 2026) | Third Quarter (Q3 2026) | Fourth Quarter (Q4 2026) |
Declaration Date | April 7 2026 | Jul 6 2026 | Oct 5 2026 | Jan 4 2027 |
Declared Price | €75.36 per tCO2e | €75.28 per tCO2e | €82.32 per tCO2e | |
Calculation basis | Based on weekly average of EU Emissions Trading System (EU ETS) auction clearing prices. | |||
Some pics from Leadership Group for Industry Transition (LeadIT) carbon markets experience sharing workshop held in collaboration with Bureau of Energy Efficiency, India and the Swedish Environment Protection Agency (SEPA) for sharing detailed insights on the carbon market schemes of India and Europe, on May 25-26, 2026 in New Delhi (India).
PC : Verdantika
PC : Verdantika
PC : Verdantika
Who pays the CBAM cost on goods?
In case of a company importing Steel HRC or Aluminium rods into the European Union under CBAM rules,
Importers: Legally responsible for paying carbon price on the embedded emissions at the port of shipment.
Exporters: May indirectly bear costs if importers negotiate lower prices to offset the CBAM cost.
Consumers: Could face higher prices if importers pass on this additional burden on consumers.
This means:
Iron & Steel products produced from high-emission blast furnace process faces direct cost exposure.
Facility-level emissions data is no longer optional. CBAM requires plant-level, installation-specific emissions reporting. Corporate ESG disclosures, sustainability reports or industry averages are not accepted.
Electricity sourcing, process technology, and raw material mix directly influence trade competitiveness.
How embedded emissions are defined under CBAM compliance?
Embedded emissions are the total greenhouse gases released during the production of a good, measured in tCO₂e per ton of product (functional unit). They include:
a) Direct Emissions (Scope 1): Combustion of fuels (coal, gas, oil) at the production site; chemical process reactions (e.g., reduction of iron ore in a blast furnace; PFC emissions from aluminium electrolysis).
b) Precursor Emissions: Emissions embedded in raw material inputs - e.g., pig iron or coke used to make steel must carry their own carbon footprint into the steel calculation.
NOTE - For Iron & Steel and Aluminium: Only direct emissions count from 2026. Indirect emissions from grid electricity are NOT included for these two sectors. Hence, suppliers cannot reduce their embedded emission of goods through market-based instruments.
CBAM regulatory stack
Regulation | Areas being addressed |
Foundational law adopted on May 10, 2023 and entered into force on May 17, 2023 | |
Adopted on August 17, 2023, establishes the reporting rules for the CBAM during its transitional phase from October 1, 2023, to December 31, 2025. | |
Published on December 30, 2024. Laying down rules regarding the establishment of a CBAM registry that would contain data on authorized CBAM declarants, applicants filing a request to be granted the status of authorized CBAM declarant (‘applicants’), operators, and accredited CBAM verifiers. | |
Adopted on December 16, 2025. Lays down rules regarding the calculation of the free allocation adjustment for the number of CBAM certificates to be surrendered. | |
Adopted on December 16, 2025 and final notification released on Dec 31, 2025. Lays down rules regarding the establishment of default values, calculation of embedded emissions, monitoring methodology, treatment of indirect emissions, precursor materials. |
Some production capacity figures within the context of Large Indian Steelmakers
Major steel producers in India are expanding blast furnace installations across various sites and boosting finished steel capacity in downstream production. This raises questions as to how this anticipated increase will be absorbed by the Indian markets and what role exports will play under the EU CBAM regime as Indian steel production capacities quickly expand.
Company Name | Current domestic crude steel capacity | Target capacity by 2030 | Recent expansions and planned additions |
JSW Steel | 32.4 million tons/ annum | 50 million tons/annum | BF upgrades at Vijayanagar plant to boost capacity from 3 MTPA to 4.5 MTPA |
TATA Steel | 26.6 million tons/ annum | 40 million tons/annum | Capacity increase of 5 MTPA at Kalinganagar plant in Sep 2024. Finished steel capacity to increase at Meramandali (Odisha) by 2.5 MTPA. |
Steel Authority of India Limited (SAIL) | 20 million tons/ annum | 35 million tons/annum | Hot metal capacity at Bokaro to be increased to 7.55 MTPA from 5.25 MTPA. Doubling capacity at Rourkela steel plant to 9.8 MTPA by 2030. |
Jindal Steel | 12.6 million tons/ annum | 15.6 million tons/annum by Q4 of 2026. | Near term plans to raise capacity at Angul steel plant from 9 MTPA to 12 MTPA. |
Arcelor Mittal Nippon Steel (AM/NS) India | 9 million tons/ annum | 15 million tons/annum by second half of 2026 | Long term capacity target of 40 MTPA. Expanding automotive steel manufacturing facilities. |
Source: Argus Report 2026
Indian Steel Capacity Additions and Strategic Directions (2025-2026)
Company | Location | Project Type | Capacity (MTPA) | Technology Route | Investment (INR) | Status (2026) | CBAM Risk |
Hi-Tech Valley, Ludhiana (Punjab) | Greenfield | ~0.75 | The state-of-the-art facility will use 100% steel scrap as raw material, sourcing ~40% scrap from the Company’s steel recycling plant in Rohtak, Haryana | ~₹3,200 Cr | Commissioned (Mar 2026) | Aligned. Designed to achieve CO₂ emissions < 0.3 tonnes per tonne of steel. | |
Anakapalli, (Andhra Pradesh) | Greenfield | ~17.8 (Ph-I - 7.3 MTPA Ph-2- 10.5 MTPA) | Blast Furnace- BOF (initially) | ~₹1.35 lac Cr (Phase-I - 55,964 Cr Phase-2 - 80,000 Cr) | Foundation Stone laid (Mar 2026) | High CBAM exposure (future retrofits needed) | |
Hazira (Gujarat) | Expansion phase | To scale up from existing 9 MTPA to 15 MTPA | Blast Furnace- BOF Post completion of the Essar Steel acquisition in Dec 2019, AM/NS executed a $0.8-billion debottlenecking project to realize the Hazira plant’s 9 MT nameplate capacity. | ~60,000 Cr | Commissioned a new continuous galvanizing line (CGL) in 2025, which can produce AHSS with strength levels up to 1180 MPa for evolving automotive applications | High CBAM exposure (future retrofits needed) | |
(also known as Vikram Ispat (formerly), Welspun Maxsteel (formerly), was incorporated by JSW Steel in 2024). | Salav, Murud, (Raigarh, Maharashtra) | ~10 MTPA | EAF / DRI; Iron other/unspecified. Investing to create a 4 MTPA plant, expanding from its current 0.9 MTPA Direct Reduced Iron (DRI) capacity to meet global demand for low-carbon steel, particularly for the EU market. | ₹50,000–60,000 Cr | Announced / Early execution | Medium. CBAM hedge. | |
Dolvi (Maharashtra) | Ph-3 Brownfield Expansion | To scale up from existing 10 MTPA to 15 MTPA | Blast Furnace (BF-BOF) As part of an integrated plant (approx. 5-10 MTPA capacity), the facility utilizes Conarc Technology and compact strip production (CSP) for high-efficiency HRC production. A new 4.5 MTPA blast furnace is planned for 2026. | — | Scheduled for completion in 2027 | High CBAM exposure (future retrofits needed) | |
Gadchiroli, Chamorshi (Maharashtra) | Greenfield | ~25 MTPA | Blast Furnace (BF route) Planned as a large-scale integrated steel plant, which traditionally involves a Blast Furnace (BF) or Direct Reduced Iron (DRI) facility combined with a Basic Oxygen Furnace (BOF) | ~₹1 lakh Cr | Land acquisition / early stage | High CBAM exposure (future retrofits needed) | |
Gadchiroli (Maharashtra) | Greenfield | Not disclosed yet | Likely BF/DRI hybrid, rolling mill and captive power | ~₹10,000 Cr | Approvals stage Foundation stone laid, public hearings completed, phased execution underway | High risk | |
Chandrapur (Maharashtra) | Iron ore mining & Integrated steel expansion | ~0.36 MTPA (Sponge Iron) + 4 MTPA pellet plant + 1.2 MTPA ISP | State-of-the-art wire rod mill with 1.2 MTPA capacity with Automatic Storage and Retrieval System (ASRS) for Wire Rod Coils, which will ensure damage-free handling, controlled storage environment and enhanced traceability. | Not disclosed | Commissioned (Sep 2025) + Ongoing + Ongoing (~2028) | Indirect CBAM exposure (The iron ore will be transported to the pellet plant through slurry pipelines, thus reducing the carbon footprint in the value chain) | |
Chamorshi, Gadchiroli (Maharashtra) | Integrated steel expansion | 4.5 MTPA blast furnace | DRI (coal-based) | Approvals stage | High CBAM exposure (future retrofits needed) | ||
Ranchi, Jharkand | Pilot under National Green Hydrogen Mission (NGHM) | ~3200 TPD | Vertical shaft based hydrogen-based Direct Reduced Iron (DRI) pilot plant. SAIL has partnered with Primetals Technologies for a hydrogen gas injection system at the Bokaro plant and signed an MoU with John Cockerill India to advance green steel technologies. | Supported by ₹347 crore in Govt funding under NGHM | Likely be commissioned by 2027 or 2028 | Aligned. Likely lesser exposure to CBAM. |
Key industrial cases that prove decarbonization has now become a trade strategy
In anticipation of CBAM, major steelmakers across Japan, Europe, the United States, and South Korea have accelerated capital deployment into electric arc furnaces (EAFs), hydrogen-based direct reduction (H2-DRI), renewable power integration, and advanced process control systems. Over the past few years, several initiatives have moved beyond announcements and entered commercial execution. These projects are not experimental. They are structural responses to CBAM risk, and supply-chain decarbonization pressure from automotive and industrial segment buyers.
Project / Initiative | Company | Country | Technology | Milestones | Reason for success |
HYBRIT fossil-free steel | SSAB / LKAB / Vattenfall | Sweden | Hydrogen-based DRI + EAF | First fossil-free steel delivered to Volvo (2021 -2023) | End-to-end hydrogen value chain integration with commercial-grade output. |
Yawata 340t Consteel EAF with with GE Vernova Direct Feed | Nippon Steel + Tenova + GE Vernova | Japan | Record-breaking 340 ton EAF installation with advanced power integration. | Nippon Steel has selected Tenova, in partnership with GE Vernova, to supply a new electric arc furnace for its Yawata Works in Feb 2026. | Integrated power stability + high virgin iron unit blending capability. |
Port Talbot EAF Transition | Tata Steel | United Kingdom | BF-to-EAF conversion | Tata Steel signed £500 million Grant Funding Agreement with UK Government for £1.25 billion green steel project in Port Talbot in 2024. | Strong public funding support and clear decarbonization roadmap |
Big River Steel Expansion | U.S. Steel | United States | Advanced EAF steelmaking | Proved EAF viability for high-end steel markets | |
Advanced Automotive EAF Rollout | Nucor | United States | High-grade EAF steel production | Automotive OEM-grade supply scale-up Nucor supplies steel for vehicle manufacturing, with General Motors (GM) named as their first customer for 'Econiq' NZ carbon steel. | Commercial adoption by automotive sector. Attracts companies seeking sustainable, LEED-certified building materials. |
H2FUTURE Electrolysis Pilot | Voestalpine | Austria | Green hydrogen production for steelmaking | Industrial-scale hydrogen testing with grid integration | |
SALCOS Programme | Salzgitter AG | Germany | Hydrogen DRI + EAF + Renewable PPAs | Integrated hydrogen and power sourcing strategy. As an important component of SALCOS®, Salzgitter is currently constructing a 100 MW electrolysis plant on the factory premises. | |
HyREX Demonstration Design | POSCO | South Korea | Hydrogen reduction technology | Indigenous hydrogen-based ironmaking technology innovation | |
Low-Carbon EAF and CCS Studies | ENEOS Corporation + JFE Steel Corporation | Japan | EAF expansion + hydrogen/CCS feasibility | Structured capital deployment toward transition technologies. |
As per April 2026 report from World Steel Dynamics, India emerged as the most exposed under CBAM (post 2026 Q1 results), with a penalty of ~€104/t, significantly higher than peers like Indonesia (~€77), Vietnam (~€70) and even China (~€47). In contrast, countries with greater usage of scrap (EAF) or gas-based DRI would face substantially lower carbon costs, while EU producers are largely neutralized due to existing ETS coverage. DDP margins of Indian & Turkish mills have effectively closed out to a difference of merely €30/t w.r.t European Mills EXW pricing under current scenario.
Higher blast furnace/ coal based DRI furnace capacity additions by Indian mills which is already in progress is one emerging solution to maintain price competitiveness (with possibilities of future retrofits to H2 / CCUS), however, gradual phase out of free allocations under CBAM from next year onwards will start eating into profit margins. This will eventually erode India’s cost competitiveness in flat steel exports to Europe, repositioning lower-carbon producers as preferred suppliers despite potentially higher base production costs + marred by stringent EU TRQ limits that have taken effect from 1 July, 2026 (import quotas reduced by 47% and out of the quota duty doubled from 25% to 50%). The European Commission officially published the country-by-country allocation of tariff-rate quotas totaling 18.345922 million metric tons across 26 steel product categories under its new steel trade regime, which aims to limit the adverse effects of global overcapacity on the EU steel market. The new quota system will apply during the period from 1 July to 31 December 2026. Imports exceeding the allocated quotas will be subject to an additional 50% customs duty.
Source : World Steel Dynamics (WSD), June 2026 report
Looking at July 2026 report from World Steel Dynamics, steel import prices despite softening have failed to revive buyer's interest:
Chinese HRC export prices have fallen by $10/t in June to $495-500/t FOB, weighed down by weak demand, with further downside risk as iron ore prices decline and energy costs are expected to ease following de-escalation in the Middle East.
Arbitrage margins for imports from key origins stand at €30–40/t, which offers little incentive for buyers compared with the historical average of €60–70/t. However, shipments from Indonesia could deliver margins of €80–90/t.
Turkish HRC offers have lost $10-15/t on a FOB basis to $610-615/t, pressured by weaker competitor pricing, itself driven by lower iron ore and scrap costs.
Indian HRC offers have also slipped by $10-20/t to $575-585/t FOB.
Amid US-Iran peace deal and sudden violation of ceasefire news, brent crude oil prices trending at ~$77.50/bl (as on July 8, 2026).
The downward trend in import prices is expected to continue in the coming months on the back of lower raw materials, energy and freight costs. While Tariff Rate Quotas (TRQ)-bound imports have stalled and are likely to show a year-on-year decline in Q2, the main pressure on the market this quarter comes from TRQ-exempt HRC shipments from Indonesia and Malaysia.
Source : WSD April 2026 report, HRC Offers (Mar, 2026)
Source : WSD June 2026 report, HRC Offers (Jun, 2026)
Also to mention the SteelRadar’s weekly quota assessment, based on European Commission data which shows initial quotas for various steel product categories were fully utilized within the first 10 days of Q1 2026, bringing the "remaining quota" to zero. China, Türkiye, and India in Q1 achieved 100% utilization rates in multiple product categories.
European Commission data for the Q2 2026 quota period (April 1 to June 30) reveals that initial import allocations for several steel categories were entirely exhausted or exceeded by the end of the quarter, mirroring the rapid depletion trends from Q1. Türkiye exceeded its country-specific allocations for non-alloy and alloy hot-rolled sheets and hollow sections. Sizable volumes were left waiting at EU ports at the close of the quarter. India fully exhausted its specific allocations, including non-alloy and alloy hot-rolled sheets pushing remaining balances down to zero. In addition to India and Türkiye, heavy exporters like South Korea and China entirely depleted their designated limits across multiple high-demand categories.
Flat vs. Long Divergence: High demand for flat steel products accelerated early-quarter utilization, while long steel products experienced a slower pace of uptake. Industry assessments from EUROMETAL noted that flat-rolled import quotas neared absolute exhaustion early in Q2. Conversely, long steel saw a slower uptake as European buyers relied more heavily on domestic supply amid construction uncertainties.
Future of CBAM and global impact
As climate policies evolve, carbon trade regulations like CBAM are expected to become more integrated. They represent a shift towards adding environmental costs into global trade, thus, promoting sustainable development.
Potential future developments include:
A. CBAM expansion to more sectors: By 2028, the CBAM scope will widen to downstream sector goods such as automotive parts, refrigerators, washing machines etc. The European Parliament’s Environment Committee (ENVI) in a vote passed on 6 July 2026, has backed extending the carbon levy further down the value chain to 180 steel- and aluminum-intensive downstream products to prevent 'carbon leakage' & close existing import loopholes.
Anti-circumvention measures: ENVI has introduced compliance rules to block importers from evading the levy:
Modification Bans: The definition of 'slightly modifying' a product to escape CBAM categorization has been broadened to target minor physical processing.
Origin Enforcement: The European Commission is authorized to enforce harsh default emissions values based on the true country of origin if a loophole scheme is detected.
E-Commerce Loophole: Individual parcel exemptions will be replaced with a single weight-based threshold per seller to prevent companies from splitting shipments into small packages to dodge reporting.
Temporary Decarbonisation Fund (TDF) : To ease the financial shock on affected industries, ENVI voted in favor of establishing a €630 million fund.
Use of International Carbon Credits to Offset CBAM cost : The European Commission previously outlined how Art 6.2 ITMOs could factor in to offset the cost under CBAM. ENVI's latest draft proposal sought to completely strip out provisions granting the EU Commission the power to recognize international carbon credits (such as Article 6 of the Paris Agreement) for reducing CBAM liability.
Provision of CBAM Suspension Mechanism: The draft also targeted the removal of 'Article 27a', a clause intended to allow the temporary pausing or adjustment of CBAM on certain goods in 'serious and unforeseen circumstances'.
Next Steps : EU Council is already aligned with these latest developments and the full European Parliament is expected to vote on the ENVI draft report during the 14–17 September 2026 plenary session. Once approved, these formal 'trilogue' negotiations between the Parliament, Council & Commission will become the law.
Read full press release here :
CBAM certificates sales and purchase timelines: The European Commission has launched a public consultation on a draft implementing regulation under Regulation (EU) 2023/956, establishing detailed rules governing the sale and repurchase of CBAM certificates, the operation of the common central platform, applicable fees and the interaction between the platform and the CBAM Registry.
The start of official CBAM certificate sales is legally set for 1 February 2027. In 2027, importers will retroactively purchase certificates to account for their total embedded emissions for the calendar year 2026.
The first annual CBAM declaration is due on 30 September 2027.
Quarterly registry balance requirements were slashed. Declarants only need to hold 50% of their embedded emissions in certificates at the end of each quarter (down from the initially planned 80%).
The CBAM Registry will function as the electronic system for submitting CBAM declarations and managing the issuance, holding, surrender, and cancellation of CBAM certificates.
A common central platform will be responsible exclusively for financial transactions related to the purchase and repurchase of CBAM certificates, including payment processing and settlement. The operation of the common central platform will be financed through fees paid by authorized CBAM declarants. A fixed fee of €0.05 per CBAM certificate sold will apply regardless of the certificate price or the member state involved. The fee will be collected at the time of purchase and, during the initial procurement contract, transferred monthly to the European Commission. Certificates will only be created in the declarant’s CBAM account after the common central platform confirms receipt of payment.
Member states will sell and repurchase CBAM certificates solely through their designated competent authorities.
Unlike the EU Emissions Trading System (EU ETS), the CBAM will not operate as a cap-and-trade system. Therefore, there will be no restriction on the number of certificates member states may sell, and they will not be allowed to delay or limit sales. Each certificate will be uniquely assigned to the purchasing declarant, carry a unique identification number, and will not be transferable or tradable.
All purchase and repurchase payments must be made exclusively in 'EURO'.
Read full draft out for consultation here:
B. Adoption of regional Emissions Trading Systems:
One example is India's emerging CCTS mechanism. Refer to our detailed coverage on India's newly launched Carbon Market Portal at this blog post link.
In APAC region, Vietnam launched a pilot Emissions Trading System (ETS) running through 2028, with a fully operational national carbon market scheduled for 2029. The initial cap-and-trade phase regulates thermal power, steel and cement sectors, capping emissions at 243.08 million tCO₂e. Hanoi Stock Exchange (HNX) handles trading & order matching. On the first day of the launch i.e. June 30, 2026, more than 1,200 tCO2e traded, generating total transaction value of approx. $6,144 as carbon credit prices climbed up as high as $5.17 per tCO2e.
C. Innovation: In financing instruments as well as the low-carbon technologies they are investing into.
D. Enhanced transparency: Improved tracking and reporting of facility and product level emissions with AI going to play a big role in this space. Verification and third party assurance services will pick up demand as CBAM timeline matures.
Businesses that adapt early will benefit from reduced risks and new opportunities while maintaining competitiveness in international markets.
Verdantika continues to closely track latest developments in supply chain decarbonization and advanced technology space, hence, companies are welcome to engage with us for any technical and strategic CBAM accounting or pre-verification / assurance related support.
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