CBAM readiness checklist for Indian exporters

By CarbonDocket · Last reviewed 2026-10-18

Short answer: work through six steps: check scope, talk to your buyers, collect installation data, calculate with evidence, plan verification, and know the dates. The checklist below is free, and you can download it as a one-page PDF.

1. Check scope

• List every product you export to the EU, directly or through traders.
• Find the 8-digit EU CN code for each product (EU TARIC database).
• Check each code against the CBAM list (Annex I, Regulation (EU) 2023/956).
• Note whether your products could fall under the proposed downstream extension (about 180 steel- and aluminium-intensive products, proposed to apply from 1 January 2028).

2. Talk to your EU buyers

• Ask what data they need, in what format and by when.
• Confirm who the importer of record and authorised CBAM declarant is.
• Ask whether they plan to use default values or your verified actual data.

3. Collect data for each installation

• Production quantity per product, per reporting period.
• Fuel purchase and consumption records, with invoices.
• Electricity bills and meter readings (counted for cement and fertilisers; keep for all).
• Raw-material purchases and precursor data (for example scrap, pig iron, alumina).
• Production route used (for example blast furnace, electric arc, induction).
• Heating or cooling bought from outside the installation.

4. Calculate and keep evidence

• Calculate embedded emissions per 8-digit CN code using the Commission's methodology.
• Use the same reporting period across production, fuel and electricity data.
• Link every figure to a source document so each number can be checked.

5. Plan verification

• Identify an independent verifier accredited by an EU or EEA national accreditation body.
• Remember verification is done per installation and is needed to use actual values instead of defaults.
• Operators started monitoring in January 2026; verifiers' first reports are due from January 2027.

6. Know the dates and costs

• 1 January 2026: definitive period began.
• 1 February 2027: CBAM certificate sales start.
• 30 September 2027: first CBAM declaration due (covers 2026 imports).
• Default values carry a mark-up: 10% in 2026, 20% in 2027, 30% from 2028 (1% for fertilisers).

Regulatory details change. This page is general information, not legal advice. Check the official EU sources: European Commission CBAM page. Reviewed 2026-10-18.