How does a non-EU steel or aluminium producer register as an operator in the CBAM Registry, and is it worth doing?

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Senseible · Accepted Answer

Article 10 of the CBAM Regulation lets a producer outside the EU ask to be registered in the CBAM Registry with its installations. Once registered, it can share its verified embedded emissions with every EU declarant that buys from it. It is worth doing if you sell to several EU importers and your actual emissions beat the default values. Without registration, each EU importer has to collect your emissions data and verification report separately, usually by email and spreadsheet. A registered operator enters the installation and its verified emissions once, and then chooses which authorised declarants can see them. The importer uses that data in its annual CBAM declaration instead of EU default values. Registration is voluntary. An importer can still use your actual data if you are not registered, as long as the data is verified, but the exchange is slower and easier to get wrong. Request registration with the operator's name, address and contact details. List each installation: its location and its main economic activity. Determine embedded emissions for the goods made there, using the method in Annex IV of the Regulation. Have those emissions verified by an accredited verifier, following Annex VI, and keep the verification report. Grant access to the declarants you sell to, and update the registry when details change. Count your EU customers. One importer can handle your data directly; five or more is where registration saves real time. Compare your actual intensity with the EU default value for your CN code. Defaults carry a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 for steel and aluminium, so verified actual data usually lowers your buyer's bill. Price the yearly verification. You need it for actual data whether or not you register, so registration adds little extra cost once you are verifying. Check your buyers' contracts. Many now ask for verified data or a price adjustment, which makes registration a sales point. The Commission opens portal access for third-country operators and sets the process through implementing acts and guidance. Check the Commission's CBAM pages for the current status before you start. Annual declarations for 2026 imports are due in 2027, so verified 2026 data is what your buyers will ask for first.