Carbon at the EU border. Calculated, verified, reduced.

Advisory on CBAM (EU Carbon Border Adjustment Mechanism) for Chinese manufacturers exporting to Europe and for German and EU companies importing from China. We turn plant data into EU-compliant emissions figures, show where emissions can be cut and support you in reducing them.

Estimate your carbon toll

CBAM in brief

The importer pays. The plant’s data sets how much.

The EU Carbon Border Adjustment Mechanism has been in its definitive phase since 1 January 2026. Producers inside the EU buy allowances for every tonne of CO₂ they emit. So that imports carry the same cost, importers now buy CBAM certificates for the emissions embedded in their goods. In scope: steel, aluminium, cement, fertilisers, hydrogen and electricity.

Who pays

The EU importer is the declarant, files the declaration and buys the certificates. The emissions figure, however, comes from the plant in China, and the cost ends up in the price negotiation.

How much

Embedded emissions (t CO₂ per tonne of goods), minus the free allocation EU producers still receive (97.5 % of the EU benchmark in 2026, falling to zero by 2034), × certificate price. Everything above the benchmark counts in full from the first year. Without verified plant data the EU default value plus a markup applies. With verified actual data, your real figure applies.

When

Imports since 2026 are already being counted. The first annual declaration is due on 30 September 2027, certificate sales start in February 2027. The free allocation deducted falls from 97.5 % of the EU benchmark in 2026 to zero in 2034.

Services

One path from the data to the filed declaration.

Each stage builds on the one before it, and each can be booked on its own. Chinese manufacturers book it for their own plants. EU importers book it for their supplier base and for the filing on their side.

Pre-Check: what your data is worth

2 to 3 weeks · fixed price · nothing follows automatically

Start here Details

Send us what you have, unsorted. We read it against the CBAM monitoring rules and answer one question: does this data carry a calculation a verifier will accept? You get the gaps named and the effort to close them quantified. Importers send us their supplier data; plants send us their own.

Data collection

weeks to months · scope depends on the gaps

Only if the Pre-Check calls for it Details

We collect what is missing where it is produced: at the installation and at the supplier whose material carries most of the carbon. On site wherever records do not exist yet. This is the expensive stage, which is why it comes after the Pre-Check and not before.

Calculation

per installation · per CN code

You can start here Details

Embedded emissions for the CBAM goods: from production data where it holds, from EU default values where it does not yet. Installation level, electricity, and the Tier-2 and Tier-3 precursors that decide most of the number. The result is a figure the importer can file and the documentation standing behind it.

Reduction

one-off project or recurring

You can start here Details

Most providers stop at the report. We take the number apart and show where it can come down: measures ranked by effort against effect, quick wins separated from anything needing capital, the before-and-after calculated before anyone spends money.

Data structure

setup, then ongoing

You can start here Details

We separate what stays inside the company from what has to leave it. The plant keeps the internal layer with full production detail. Verifier and importer receive only the audit-relevant extract, structured the way the EU rules expect.

Annual compliance

per year · per installation or per importer

Every year Details

For the plant: quarterly data reviews and support through the verification. For the importer: the annual declaration and certificate planning. For both: the regulatory watch. Brussels publishes implementing acts continuously, and we say which of them move your number.

Not sure where to start? Get in touch for a first conversation.

Talk to us

Data holdsSkip the collection stage and go straight to the calculation. No plant visit needed.

Data too thinWe name what is missing and quantify the effort. Only then does collection make sense.

We calculate to the EU rules and prepare everything for verification. Anyone using actual plant values instead of the default values must have them confirmed by an accredited verification body. That is an EU requirement. We coordinate the verification with the verifier and see it through to the verification report.

Why carbontoll

A strong team with deep expertise.

Years of experience in accounting for and reducing emissions at European level.

Dr. Chujun Zong

China operations · on-site data · AI

Details

Dr.-Ing., TU Munich, doctorate on uncertainty modelling and dynamic life-cycle assessment. Before that Siemens Energy, M.Sc. Resource-Efficient Building and B.A. Architecture at TUM. Native Mandarin, fluent German and English. Runs plant access, supplier work and data collection in China.

chujun.zong@carbontoll.com

Dr. Hannes Harter

Data & AI

Details

Managing director of vesta sustainability consulting. Dr.-Ing., TU Munich, doctorate on life-cycle assessment with semantic 3D city models, then postdoc at NTNU Trondheim on EU Green Deal projects. Before that M.Sc. Sustainable Energy Technology and B.Sc. Renewable Resources. Builds the data and AI toolchain behind the calculations.

hannes.harter@carbontoll.com

Dr. Michael Vollmer

LCA & method

Details

Managing director of vesta sustainability consulting. Dr.-Ing., TU Munich, doctorate on the ecological footprint of buildings after seven years of research at the TUM chair. Before that building-physics engineer at Müller-BBM and B.Eng. Building Physics. DGNB auditor. Owns method, system boundaries and verification readiness.

michael.vollmer@carbontoll.com

Portraits: real photographs, edited with AI.

Behind carbontoll

carbontoll is the CBAM practice of vesta sustainability consulting, Munich. Vesta works on life-cycle assessment, building physics and energy modelling for European clients, including university research projects and DGNB certification. Same methods, applied at the EU border.

What CBAM costs. Per year.

Rough estimate for one product flow. Set sector, volume, verified intensity, certificate price and year, then compare default values with verified plant data. The bill shown is what that year’s imports incur after the free-allocation deduction, paid with the declaration in the following year. The full amount from 2034 sits underneath.

SectorAnnual EU import volume (tonnes)20,000 t

Verified actual intensity (t CO₂e / t)0

0 = no verified data, default-value cost onlyCBAM certificate price (€/t CO₂)€ 82.32

Year of importfree allocation deducted: 97.5% of the EU benchmark (1.364 t CO₂e/t) · default value 3.169 t CO₂e/t plus 10% markup

CBAM cost due in 2026€3,549,249

On default values€3,549,249

At full phase-in, from 2034

On default values€6,782,214

Estimate, not audit-grade. Default values for China from Implementing Regulation (EU) 2025/2621 as corrected by 2026/1740, markup as legislated. Free allocation deducted per Regulation (EU) 2025/2620: CBAM benchmark (Column B, production route of the Chinese default table) × free share of the year × correction factor 1.0. The same deduction is applied to plant data as a simplification. With verified data it is calculated along the plant’s own process chain (Column A plus precursors) and can differ somewhat. Certificates for 2026 imports are bought from February 2027 and surrendered with the first declaration by 30 September 2027. A carbon price paid in China is not deducted. Legal status 15 October 2026.

Show example calculation

Worked example: 20,000 t of steel slabs a year

Default value for Chinese slabs 3.169 t CO₂e/t against an illustrative verified plant figure of 2.0 t CO₂e/t, certificate price €82.32. On both routes CBAM deducts the free allocation EU producers still receive: 97.5 % of it in 2026, falling to zero by 2034. On default values that is the EU benchmark for the whole chain, 1.364 t CO₂e/t. With verified plant data it is calculated per process step plus precursors, which gives a similar but not identical figure. The example applies the same deduction to both sides as a simplification. The gap between default value and plant data therefore counts nearly in full from the first year and grows only with the markup. What the phase-out changes is the base underneath.

Year	Free allocation	Markup	On default values	On verified data	Difference
2026	97.5%	+10%	€3,549,249	€1,103,253	€2,445,996
2028	90%	+30%	€4,761,093	€1,271,679	€3,489,414
2030	51.5%	+30%	€5,625,684	€2,136,270	€3,489,414
2034	0%	+30%	€6,782,214	€3,292,800	€3,489,414

Amounts due in the year after the free-allocation deduction. A carbon price paid in China is not deducted. Estimate, not audit-grade.

Who we work for

CBAM has two ends: the plant in China where the emissions occur, and the importer in the EU who files and pays. We work at both.

Chinese manufacturers

You export steel, aluminium, cement or fertiliser products to the EU. Your customer is asking for verified emissions data, or will be. We build the number, prepare it for verification and show what brings it down.

German and EU importers and manufacturers

You import CBAM goods or process them further. You need actual data from your suppliers instead of default values, a defensible calculation, and a declaration that survives an audit. We get the data from the plants, in Mandarin, and prepare the filing on your side.

Consultancies and audit firms

You serve EU clients with Chinese supply chains and need the China part done: Tier-2 and Tier-3 data sourcing, mapping Chinese records to CBAM rules, on-site preparation before the verifier arrives. We work white label under your brand.

CBAM cost per tonne of steel, 2026 to 2034

The 2026 bill is not small. By 2034 it nearly doubles.

CBAM deducts the free ETS allowances European producers still receive: 97.5 % of the EU benchmark in 2026, falling to zero by 2034. Everything above the benchmark counts in full from the first year. For Chinese steel on default values that is about half of the 2034 rate already for 2026 imports.

ramp · free-allocation phase-out · 2026–2034

2026–2034

Which is why 2026 is the year to act, not 2030

The goods shipped this year already count, and for goods above the EU benchmark most of the charge applies from the first year. Payment comes in 2027: certificate sales start on 1 February, surrender with the declaration by 30 September. The first annual declaration is due on 30 September 2027, and without verified plant values it is calculated on default values plus a markup. The data system in place by then carries the years in which the free allocation is gone.

Cost = tonnes × (default value × (1 + markup) − free allocation × benchmark) × certificate price

Example: 10,000 t of Chinese steel slab a year

2026 10,000 t × (3.169 × 1.10 − 97.5 % × 1.364) × 82.32 € ≈ €1,800,000

2034 10,000 t × (3.169 × 1.30 − 0 % × 1.364) × 82.32 € ≈ €3,400,000

€ per t = (3.169 t CO₂e/t default value × (1 + markup) − free allocation × 1.364 t CO₂e/t benchmark) × €82.32 certificate price

Year2026 Free allocation97.5 % Markup+10 % € per t of steel€177.46

Move along the curve or tap a year to see the values.

Show values as a table

YearFree allocation (share of EU benchmark)Markup€ per t of steel

2026

97.5 %

+10 % €177.46

2027

95 %

+20 % €206.36

2028

90 %

+30 % €238.05

2029

77.5 %

+30 % €252.09

2030

51.5 %

+30 % €281.28

2031

39 %

+30 % €295.32

2032

26.5 %

+30 % €309.36

2033

14 %

+30 % €323.39

2034

0 %

+30 % €339.11

Percentages are the legislated phase-out of free allocation (ETS Directive, correction factor 1.0 for 2026 to 2030, assumed unchanged after). Euro figures: steel slab from China on default values with the legislated markup, minus the free allocation on the CBAM benchmark for the blast-furnace route (1.364 t CO₂e/t, Regulation (EU) 2025/2620), at the Q3 2026 certificate price (€82.32/t CO₂), the same calculation as in the estimator above. Benchmarks may be updated from 2027. A carbon price paid in China is not deducted. Estimate, not audit-grade.

Reporting is the floor. Reduction is the point.

Every provider in this market sells a report. The question our clients ask is the next one: how much of this can go, and how much less do I pay then? That question has an answer, and working it out is where a research background pays off.

Quick wins

weeks · no capital expenditure

Learn more

Electricity sourcing and contracting, scrap ratios, waste-heat recovery, and the measurement gaps that inflate the reported number without a single tonne of real emissions behind them.

grid_ppaPASS−8 %

scrap_ratioPASS−5 %

waste_heatPASS−3 %

metering_gapCHECK−4 %

contract_mixPASS−2 %

Illustrative

Structural measures

quarters · capital expenditure

Learn more

Fuel switching, electric-arc share, process redesign. Slower and more expensive, and the only route to a durable change in intensity.

eaf_share62

fuel_switch44

process_redesign31

electrification22

ccus_option9

Illustrative

Upstream

depends on the suppliers

Learn more

Whoever processes rather than smelts bought most of the embedded carbon with the input material. Changing that means reaching the supplier behind the supplier. We go there.

default→actual

slab_intensity_tCO2e_per_t:

- 3.169 # EU default, CN

+ 2.05 # verified, plant

precursor: coke

! tier2_supplier = pending

Illustrative

Two different things, kept apart

Details

Measuring properly lowers the number you report. Changing the process lowers the emissions themselves. Both cut the CBAM bill, and only the second is decarbonisation. We label every measure as one or the other, because an auditor will, and because European customers increasingly ask.

On paper before it costs money

Details

For each measure you get the delta calculated before you commit: intensity today, intensity with the measure in place, and what the difference is worth against the certificate price across the phase-in years.

As of 15 October 2026

What changed, and what it means for you

October 2026

Four CBAM verifiers accredited, capacity remains tight

New Details

Since late September four verifiers have been accredited: Bureau Veritas Italia, RINA and SGS ICS Italia via the Italian Accredia, and Intertek Certification via the Swedish Swedac. A fifth, EmiCert in Greece, has announced its accreditation. The Commission has not published its list yet. As of 7 October, 24 national accreditation bodies have committed and 18 are accepting applications. Germany's DAkkS accepts applicants from the EU only. In the first year of verification the verifier has to visit the plant in person.

For you · The queue for the 30 September 2027 declaration forms this autumn. Have the data ready before you need the slot, not after.

15 September 2026

Parliament wants CBAM extended to 457 downstream products

Pending Details

The plenary adopted Parliament's negotiating position on extending CBAM to downstream steel and aluminium goods by 464 votes to 50, with 159 abstentions. Parliament wants around 457 product lines added (fasteners, wire, springs, household articles, heat pumps and more), well beyond the Commission's roughly 180 and the Council's roughly 200. It also tightens anti-circumvention: a lower threshold for what counts as minor processing, and default values of the actual country of origin where circumvention is found. A temporary decarbonisation fund for exposed EU producers runs 2027 to 2029. Trilogue with the Council starts next; the current scope applies until the amending regulation is adopted.

For you · If you trade processed goods rather than slab or ingot, plan on being in scope from 2028; the final list is now negotiated between 200 and 457 lines. Restructuring the shipment is being ruled out as a strategy. Restructuring the data is not.

14 August 2026

Ten new Commission guidance documents for non-EU operators

New Details

Guidance on emission calculation, on the free-allocation deduction, and one document per sector for the definitive phase. This is the method a verifier will check the plant against.

For you · The method is now written down. We work to it, which shortens the verification.

31 July 2026

Default values corrected, retroactive to 1 January 2026

Fixed Details

Implementing Regulation (EU) 2026/1740 corrects figures and CN-code assignments in the default-value annexes of Regulation 2025/2621, including steel chapters 72 and 73. A corrected spreadsheet followed on 10 August.

For you · Any 2026 calculation done on default values needs a re-check against the corrected table. If you filed on defaults, the number may have moved.

Q4 2026 expected

Certificate purchase rules not adopted yet

Pending Details

The delegated act on sale and repurchase of CBAM certificates closed consultation on 6 August with 93 responses. Adoption is planned for the fourth quarter. Sales start 1 February 2027. The Q3 certificate price, published on 5 October, is €82.32, after €75.36 in Q1 and €75.28 in Q2. The Q4 price follows on 4 January 2027.

For you · The importer cannot buy certificates before February 2027, but the emissions being priced are this year’s.

Standing

The Chinese ETS payment does not count against CBAM

Standing Details

China’s national ETS has covered steel, cement and aluminium since March 2025 and traded around CNY 67, about €11 per tonne, in April 2026. It does not qualify for an Article 9 deduction: it allocates against intensity benchmarks rather than an absolute cap, and the Commission has made no determination. A Commission draft on recognising third-country carbon prices is with the member states; Chinese policy points to an absolute cap from 2027.

For you · There is no domestic credit to net off. Verified actual data is the only lever that changes the CBAM bill today.

Talk to us

Tell us whether you export to the EU or import into it, your sector and the volumes involved. We reply with a concrete next step.

hello@carbontoll.com Follow carbontoll on LinkedIn

WeChat
Scan to follow our official account

Or write to one of us directly

Dr. Chujun Zongchujun.zong@carbontoll.com
Dr. Hannes Harterhannes.harter@carbontoll.com
Dr. Michael Vollmermichael.vollmer@carbontoll.com

We are based in Munich. By arrangement we come to China and work on site at your plant. European clients meet us in Munich or at their site.