Is carbon black exported to the EU covered by CBAM?
No. Carbon black is declared under 2803, and the only chapter 28 product in Annex I is hydrogen. EU tyre and rubber buyers file no CBAM figure for it, but many ask for a product footprint because carbon black is carbon intensive.
What buyers ask instead
A cradle to gate footprint per tonne: feedstock oil, process gas use, tail gas combustion and power, with any exported power or steam credited by a stated method.
Could coverage change
The Commission proposed in December 2025 to extend CBAM to some downstream steel and aluminium products. As of October 2026 that is not law, so check Annex I again before each contract season.
What Senseible does here
Senseible reads your fuel and electricity invoices into dated, fingerprinted records, so if a buyer asks for a product footprint you can answer from documents rather than estimates.
Sources: CBAM Regulation (EU) 2023/956, consolidated, European Commission, CBAM legislation and guidance
Last reviewed 2026-10-22.