CBAM Reporting for Ukrainian Exporters: What to Do from 2026

CBAM (Carbon Border Adjustment Mechanism) is the EU's carbon border levy, introduced by Regulation (EU) 2023/956. People often call it a carbon tariff, though technically it isn't one: the importer buys certificates covering the CO₂ emissions embedded in the goods they bring in. The logic is straightforward. If a European plant pays for its emissions under the EU ETS (the EU Emissions Trading System), imported products should carry a comparable carbon price. Otherwise production simply migrates to wherever emissions are free.

For a Ukrainian manufacturer, this means something very concrete: your EU buyer is now obliged to declare the emissions generated at your production site. They don't have that data, and there's nowhere to get it except from you. That's why questionnaires about direct and indirect emissions, energy consumption, and calculation methodology are already landing in the inboxes of steel, fertiliser, and cement suppliers.

The importer pays for the certificates. But the producer collects the data.

And one more thing that rarely gets said out loud: emissions data is the product of a system, not a one-off spreadsheet exercise. We covered how such a system is built in our complete ISO 14001 guide. Here we'll focus on the practical mechanics of CBAM: who's covered, what exactly to calculate, and how to make your numbers stand up to scrutiny.

The list is set by Annex I to Regulation (EU) 2023/956 and defined by CN codes (the EU's Combined Nomenclature). There are six sectors: cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. Coverage extends beyond primary products to certain downstream goods made of iron, steel, and aluminium, from structural steelwork to fasteners.

A practical tip: don't guess based on the product name. Take the CN codes from your own customs declarations and check them against Annex I. Manufacturers often first hear about CBAM from a buyer who suddenly requests emissions data for an item that had always been plain rolled steel.

From October 2023 until the end of 2025, CBAM ran in transitional mode: importers filed quarterly reports on embedded emissions but paid nothing. In effect it was a training ground where the EU fine-tuned the methodology and businesses learned to collect data. On 1 January 2026, on the European Commission's schedule, the mechanism moved into its full, definitive regime, and the requirements got significantly tougher.

Pay attention to the calendar. The annual declaration for 2026 is due by 30 September 2027, together with the surrender of certificates. So the financial settlement for the first year of the definitive regime won't happen until 2027. There's still time to prepare your data, but less than it seems: 2026 emissions are accumulating right now, and you can't measure them retroactively.

We broke down what exactly the definitive regime changes for exporters, and which steps it triggers, in a separate news piece: CBAM in 2026: what the definitive regime changes.

In October 2025 the EU adopted Regulation (EU) 2025/2083, which simplified the mechanism. The headline change is a de-minimis rule: if an importer brings less than 50 tonnes of CBAM goods into the EU per year in total, CBAM obligations don't apply to them. The threshold is counted by net mass, cumulatively across all goods in the iron and steel, aluminium, fertiliser, and cement sectors. It doesn't apply to electricity or hydrogen.

By the European Commission's estimate, the exemption takes roughly 182,000 importers out of the mechanism, mostly small businesses, while keeping over 99% of emissions covered. The logic is easy to follow: the administrative burden was lifted from those whose contribution to emissions is negligible, while the big payers stay in scope.

What does this mean for a Ukrainian supplier? The threshold is counted on the importer's side, not yours. Your 30-tonne contract for aluminium profiles doesn't exempt your buyer if they source another 40 tonnes from someone else. So the conclusion that you're too small to be affected can only be drawn after talking to your specific buyer about their total annual volumes.

An authorised CBAM declarant states the embedded emissions for each type of goods in the declaration. They can take those figures from two sources: actual data from the producer, or default values published by the Commission. For you as a supplier, the first option is almost always the better one, and I'll explain why below.

A typical request from a European buyer includes:

• identification of the installation where the goods were produced: name, location, coordinates;
• actual direct emissions per tonne of product, from fuel and process emissions;
• indirect emissions from purchased electricity;
• the calculation methodology: boundaries, factors, data sources;
• a breakdown by production route if the product involves more than one process.

Direct emissions arise at the installation itself: gas burned in a furnace, process emissions such as ore reduction or clinker firing. Indirect emissions come from the power plant that generated the electricity you consumed. For electricity-intensive production, such as electric arc steelmaking or aluminium smelting, the indirect share can outweigh the direct one, so counting just the gas won't cut it.

If the producer doesn't provide verified actual data, the importer declares the goods using the Commission's default values: averaged figures for each type of product. The Commission has already published these values for the definitive regime. Formally, that saves the declaration. In practice, you're handing a third-party table the number that determines how many certificates your buyer purchases for your goods.

The base metric is specific embedded emissions: tonnes of CO₂ equivalent per tonne of product. The calculation principle looks like this: the installation's direct and indirect emissions attributed to a specific product are divided by the production volume of that product over the period. The methodology for CBAM is set by EU implementing acts, and its logic sits close to the corporate carbon accounting standards, GHG Protocol and ISO 14064.

Here's how it works in practice:

1. Define the installation boundaries and the processes relevant to the CBAM goods.
2. Collect primary data: fuel, raw materials, electricity consumption, production volumes. This is usually the step where you discover the meters aren't where they should be, and half the data lives in accounting's own format.
3. Apply emission factors and calculate direct and indirect emissions for the period.
4. Attribute the emissions to the product and divide by the tonnes.

Sounds simple. The difficulty isn't the formula, it's data discipline: the numbers have to reconcile between years, survive follow-up questions, and be reproducible when a buyer or verifier asks to see where each figure came from.

Let's be honest: no ISO standard is a formal CBAM requirement. The regulation demands reliable data, not certificates. But that's exactly where the trap is: a one-off Excel calculation with no data collection system behind it falls apart at the importer's first follow-up question. Who calculated this? Under which methodology? Why was last year's figure different? Without a system, panic answers those questions. With one, records do.

What ISO 14001 certification gives you in the CBAM context:

• a register of environmental aspects, so you know all your emission sources, not just the obvious ones;
• document and record control: every figure has a date, a source, and an owner;
• internal audits, so errors in the accounting are found by you rather than your customer;
• a legal requirements register where CBAM and related rules are tracked systematically.

ISO 50001 adds the energy dimension. Process-level energy accounting is a ready-made basis for indirect emissions, which otherwise have to be reconstructed from utility bills. We covered that standard separately in our ISO 50001 energy management guide.

In practice, the combination that works best is an EMS (environmental management system) built on ISO 14001 as the framework, carbon accounting under GHG Protocol, and energy data via ISO 50001. To an EU customer, it signals that the numbers in your supplier questionnaire aren't the sales department's creative writing.

Ukraine has had Law No. 377-IX, On the Principles of Monitoring, Reporting and Verification of Greenhouse Gas Emissions, in force since December 2019. It created a national MRV system (monitoring, reporting, verification): operators of installations covered by the system file verified emissions reports.

This is a head start that few companies use deliberately. If your installation already reports under Ukrainian MRV, a large share of the CBAM work is done: installation boundaries are defined, emission sources identified, the methodology documented, and the reports have been through verification. What remains is adapting the data to EU requirements: attributing emissions to specific products and adding the indirect component from electricity.

If your facility isn't covered by MRV, you'll be building carbon accounting from scratch. It's doable in a few months, but it's better to start before your buyer sets a two-week deadline.

Here's the sequence we recommend to manufacturers that have received, or expect, CBAM requests:

1. Check your products' CN codes against Annex I of Regulation (EU) 2023/956.
2. Talk to your buyer: do they hold authorised CBAM declarant status, does their total import volume exceed the 50-tonne threshold, and in what format do they want the data?
3. Define the installation boundaries and set up primary data collection: fuel, electricity, raw materials, production volumes.
4. Calculate specific embedded emissions for each CBAM product.
5. Decide who will confirm your figures and how: internal control, external verification, a system audit.
6. Plan for an annual cycle. The definitive regime is a yearly exercise, and a one-off calculation won't carry you through.

If it's hard to judge how far your current accounting is from what's required, a sensible first step is a preliminary diagnostic of your management system and emissions data. It shows the gaps between what you have and what the importer will ask for, before those gaps become a contract problem.

Ekontrol has worked as a Bureau Veritas partner in Ukraine since 2014, supporting manufacturers that build management systems around export requirements. For CBAM, that means diagnosing your current emissions accounting, implementing an EMS under ISO 14001, setting up energy accounting under ISO 50001, and preparing for the certification audit. We don't fill in declarations on the importer's behalf: we make sure your data survives their checks.

If a buyer has already sent you an emissions data request, get in touch and we'll work out what to do with it before the deadline starts to bite.