What Data Does Your EU Customer Need for CBAM? Supplier's Guide

If you supply steel, aluminium, cement, or fertiliser to an EU buyer, you'll get an email soon — maybe you already have. They'll ask for emissions data. They need it for CBAM.

This guide explains exactly what data they need, how to prepare it, and what happens if you can't provide it.

The Email You'll Get

It sounds something like this:

"As part of our CBAM compliance, we need to collect embedded emissions data for the products we import from you. Can you provide your production route, energy consumption, and emissions per tonne?"

CBAM's permanent phase started January 1, 2026. EU importers must now report the carbon emissions embedded in everything they import. They can't do that without data from their suppliers.

What Your EU Customer Needs

For every product they buy from you, they need this:

Data Category	Specific Data Points
Product identification	Product name, CN code (8-digit), quantity (tonnes)
Production route	BF-BOF, EAF, DRI-EAF, etc.
Direct emissions	CO₂ from fuel combustion on-site
Indirect emissions	CO₂ from purchased electricity
Energy consumption	Electricity (kWh), gas (m³), coal (kg), fuel (litres)
Country of origin	Where production happens
Carbon price paid	Any carbon tax or ETS paid in your country

Sector note on indirect emissions: For cement and fertilisers, both direct and indirect emissions are chargeable. For steel, aluminium, hydrogen, and electricity (Annex II sectors under Regulation 2023/956 Art. 7(1)), indirect emissions from electricity must be reported but do not affect the CBAM certificate cost. Your electricity source matters for reporting purposes only, not for the final chargeable amount.

The EU provides a standardised format for this called the Communication Sheet. It's not complicated — just a structured way to share the data above.

What Happens If You Don't Provide Data

Your EU customer has two options:

1. Use your actual emissions data — if you provide it
2. Use EU default values — if you don't

Default values are set deliberately high. They assume worst-case production methods. On top of that, they carry a markup that starts at +10% in 2026 and reaches +30% by 2028 (IR (EU) 2025/2621).

Scenario	Your Emissions	EU Default	Cost to Your Customer
You provide actual data (efficient production)	1.50 t CO₂/t	—	Baseline
You don't provide data	—	2.30 t CO₂/t	53% more expensive
Default value markup (2026)	—	+10% above benchmark	Even higher
Default value markup (2028)	—	+30% above benchmark	Much higher

Here's the business reality: your EU customer pays more when you don't provide data. Over time, they'll look for suppliers who do.

How to Prepare Your Data

Step 1: Find Your CN Codes

Ask your EU customer which CN codes they import from you. Common ones:

Product	CN Code
Steel rebar	7214
Steel flat products	7208-7212
Aluminium ingots	7601
Cement clinker	2523 10 00

Step 2: Document Your Production Route

For each product, answer:

• What furnace or process do you use? (BF-BOF, EAF, DRI-EAF)
• What fuel do you burn on-site? (coal, coke, natural gas, fuel oil)
• What electricity do you consume? (grid, dedicated plant, renewable PPA)

Step 3: Collect 12 Months of Energy Data

Data Source	What to Collect
Electricity bills	kWh consumed per month
Gas bills	m³ consumed per month
Fuel receipts	Litres or kg of fuel consumed
Coal or coke purchases	Tonnes purchased

Step 4: Calculate Emissions Per Tonne

Formula: Total emissions from all sources ÷ Total production in tonnes

Example for a steel producer:

• Total emissions: 2,250 t CO₂ per year
• Total production: 1,000 tonnes per year
• Emissions per tonne: 2.25 t CO₂ per tonne

Step 5: Share With Your EU Customer

Use the EU Communication Sheet format. Even a simple email with the data points works.

What If You Don't Have Data?

Many suppliers don't track emissions yet. Here's what you can do:

Option A: Estimate Using Your Production Route

If you know your production method, you can estimate:

Production Route	Typical Emissions Range (CBAM-chargeable)
Steel BF-BOF	1.85 – 2.30 t CO₂ per tonne
Steel EAF (scrap)	0.40 – 0.70 t CO₂ per tonne
Aluminium (direct only)	1.50 – 2.20 t CO₂ per tonne
Cement clinker	0.60 – 0.85 t CO₂ per tonne

Aluminium note: Under Annex II, only direct emissions from smelting are chargeable for CBAM. Indirect emissions from electricity are reported but excluded from certificate cost calculations. This means an aluminium smelter's electricity source (gas, hydro, coal) does not affect its CBAM obligation — only smelting technology (pre-bake vs Søderberg) matters. The 1.50–2.20 t CO₂/t range above reflects direct emissions only.

Option B: Tell Them What You Know

Even partial data helps:

• "We use a blast furnace with coal"
• "Our electricity comes from the national grid"
• "We produce 500 tonnes per year"

Your EU customer can work with this to produce a better estimate than using defaults.

Why This Matters for Both of You

You (Supplier)	Your EU Customer (Importer)
Lower CBAM cost for your products	Lower CBAM certificate obligation
Preferred supplier status	More accurate CBAM declarations
Competitive advantage	Reduced audit risk
Better customer relationship	Easier compliance

When you provide actual emissions data, both sides win. It's not just a compliance burden — it's a competitive advantage.

Key Takeaways

1. Your EU customer needs: CN code, production route, energy consumption, and emissions per tonne
2. Default values are deliberately expensive — providing data saves both of you money
3. You don't need a consultant to prepare this data
4. Even partial data helps more than nothing
5. Suppliers who respond quickly become preferred suppliers

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Frequently Asked Questions

Will my EU customer stop buying from me if I don't provide data?

Not immediately. But they'll pay more in CBAM costs for your products. Over time, they may shift to suppliers who provide data, because those suppliers are cheaper.

Is emissions data confidential?

You can share it directly with your EU customer through a secure channel. It doesn't get published publicly.

Do I need a consultant to calculate my emissions?

No. If you know your production route and energy consumption, you can calculate emissions in under an hour using free tools.

What format does my EU customer need?

The EU Communication Sheet format is standard, but even a simple email with the key data points works.

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Regulation Status

Field	Value
Last reviewed	2026-07-27
Based on	Regulation (EU) 2023/956, IR (EU) 2025/2621
Applies to	CBAM permanent phase (2026+)

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References

• EU Regulation 2023/956
• IR (EU) 2025/2621
• European Commission CBAM Q&A

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Last updated: July 27, 2026

Related: CBAM Compliance: What to Do Right Now | CBAM Certificate Cost Formula | CBAM for Gulf/MENA Exporters