What does the EU carbon border charge (CBAM) mean for Brazilian suppliers of steel, aluminium and other covered goods?

The European Union (EU) Carbon Border Adjustment Mechanism (CBAM) charges the importer, not you, for the carbon released making steel, aluminium and a few other goods. But your buyer needs your plant's emissions per tonne, so expect to be asked. Brazil is not on the exempt country list, and the first yearly declaration covers 2026.

What it is, in plain words

The Carbon Border Adjustment Mechanism (CBAM) works like a customs duty that depends on how much greenhouse gas went into making the goods. Think of a fuel tax on a delivery van: the more the process burned, the more it costs.

The legal duty sits with the EU importer. Above 50 tonnes a year it needs to be an authorised CBAM declarant. Under 50 tonnes it is exempt. You are not the one filing. You are the one holding the numbers.

What the Regulation (EU) 2023/956 says that matters to you

• It applies to the goods in Annex I that come from a country outside the EU. The countries left out in Annex III are Iceland, Liechtenstein, Norway and Switzerland, plus a few small territories. Brazil is not among them.
• Annex I covers cement, electricity, fertilisers, iron and steel, aluminium and one chemical, hydrogen.
• The importer files a CBAM declaration by 30 September each year. The first one is due in 2027 and covers 2026.
• The declaration states the embedded emissions, in tonnes of carbon dioxide equivalent (CO2e) per tonne of goods. These come from the producer's actual emissions or from default values.
• Where actual emissions are used, a verifier under Article 18 must verify the total embedded emissions.
• The importer must keep the records until the end of the fourth year after the year of the declaration.
• The operator of a plant outside the EU can ask the Commission to register itself and its plant in the CBAM registry. The registration is valid for five years.

Check your product code

• Iron and steel: all of Chapter 72, except the listed items. The exceptions include ferro-niobium (7202 93 00), ferro-silicon, ferro-silico-manganese and ferrous waste and scrap (7204). Ferro-niobium (7202 93 00) is on the excluded list, so Brazilian ferro-niobium is outside.
• Iron and steel articles in Chapter 73 are also listed: 7301 to 7311, 7318 and 7326, for example tubes, pipes, fittings, structures, tanks, containers, screws and bolts. Check your exact code in Annex I.
• Iron ore: only heading 2601 12 00, agglomerated iron ores and concentrates other than roasted iron pyrites, is listed. My reading is that pellets fall here and ore fines do not.
• Aluminium: unwrought aluminium (7601), plates, sheets and strip over 0.2 mm (7606), foil (7607), bars, rods and profiles (7604) and other listed articles.
• Fertilisers, cement and hydrogen have their own listed codes in the same Annex.

The 50 tonne rule

An importer whose total net mass of covered goods in a calendar year does not exceed 50 tonnes is exempt. The threshold counts all Combined Nomenclature (CN) codes added together, per importer. Once the importer goes over, all its covered goods that year come under the Regulation. This does not apply to hydrogen or electricity (Article 2a(4)).

My reading: whether your shipment matters depends on the importer's total, not on yours. A small order to a big importer is still in scope.

What to have ready for a buyer

1. Your CN code for each product.
2. Fuel, reductant, electricity and process records for the plant, per product, for the year.
3. Production tonnes per product, so emissions can be shared out per tonne.
4. Whether Brazil prices the emissions of your products and whether you have paid it. With actual emissions the importer can claim a reduction only for a price effectively paid, with independent evidence (Article 9(1) and (2)). From 2027 the Commission may publish default carbon prices by country (Article 9(4)).
5. If you want the buyer to use your actual figures and not default values, plan for a verifier visit, and tell the buyer early.

Does the 50 tonne rule catch these two importers? (example numbers)

• Importer A buys 30 tonnes of aluminium sheet from you and 15 tonnes of steel from elsewhere: 30 + 15 = 45 tonnes, under 50, so exempt
• Importer B buys 30 tonnes of aluminium sheet from you and 40 tonnes of steel from elsewhere: 30 + 40 = 70 tonnes, over 50, so all 70 tonnes are covered
• Your 30 tonnes are the same in both cases. The outcome depends on the importer's total.

These are example numbers, not real orders.

What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records, so the fuel behind each tonne traces back to a dated invoice. Senseible is not a CBAM verifier. Where actual emissions are used, the Regulation requires an outside verifier.

• Brazil carbon market and CBAM deduction
• Brazil grid emission factor for suppliers
• CBAM verification report: what it contains

Sources: Regulation (EU) 2023/956, consolidated text of 20 October 2025: Articles 2a (including 2a(4)), 5, 6, 7, 8, 9, 10 and Annexes I, III, VII

Last reviewed 2026-11-07. Read from the consolidated text of 20 October 2025. Re-check the Commission's CBAM pages for amendments, for the CBAM registry opening to plant operators, and for any change to the 50 tonne threshold.