Who files CBAM for your shipment, and what they need from you
Since 1 January 2026, if your EU buyer imports more than 50 tonnes a year of steel, aluminium, cement and fertilisers combined, the goods enter only through an authorised CBAM declarant. That is always a company in the EU, never the Indian exporter. It declares the emissions in your goods: your plant's verified figure, or an EU default if you send nothing.
Who holds the status
- Your buyer clears import (DAP, DPU), over 50 tonnes a year: Your buyer, or its customs representative. They need the status before your goods arrive, or EU customs will not release them.
- You clear import (DDP), over 50 tonnes a year: Someone in the EU. Not your Indian company. Only a company established in an EU country can hold the status. Under DDP that means an indirect customs representative who agrees to take the role, or an EU company of your own.
- 50 tonnes or less a year, no hydrogen or electricity: An importer bringing in 50 tonnes or less a year of these goods is exempt and needs no declarant status.
50 tonnes is your buyer's total, not yours
Counted per importer, per calendar year, by weight of goods across steel, aluminium, cement and fertilisers together. Hydrogen and electricity have no threshold.
Key dates
- 1 Jan 2026: Declarant status needed above 50 tonnes a year, or for any hydrogen or electricity.
- 31 Mar 2026: Importers who applied by this date could keep importing while they waited. Anyone applying now needs the status first.
- Feb 2027: Your buyer can start buying CBAM certificates, which pay the carbon charge on goods imported in 2026.
- 30 Sep 2027: First annual declaration, for everything imported in 2026.
The main lines the declarant needs from you
- Plant name, address, coordinates and reporting period
- Your goods by CN code, with how each is made
- Materials you bought in, such as billets or ingots, with each supplier's figure and report
- Emissions per tonne of each good, direct and indirect
- Free allocation per tonne (the free share an EU plant would get), which cuts the certificates your buyer owes
- Who verified the figures, and their opinion
Send nothing and the declarant files the EU default value for India, with a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 (1% for fertilisers). Actual values must be verified by an accredited CBAM verifier and carry no mark-up.
Straight answers
Can an Indian company be an authorised CBAM declarant?
No. The status is granted only to a company established in an EU country, by that country's authority. You can register your plant in the CBAM Registry as an operator so declarants can see your verified figures, but that does not make you a declarant.
Does my Indian company need to register for CBAM?
No. Declarant registration is for EU importers. Registering your plant as an operator is optional. It helps when you sell to several EU buyers and are tired of sending each one the same figures.
How do I check my EU buyer has the status?
There is no public register. Ask for their CBAM account number and the EU country that authorised them, and write the duty to hold the status into your contract.
We sell DDP. Who files?
Not your Indian company. An EU indirect customs representative has to agree to take the declarant role for your shipments, or you import through an EU company of your own. Or move to a term where your buyer clears import. Have an EU customs adviser confirm the setup before you ship.
Do our actual emissions need to be verified?
Yes. Actual values in a declaration must be verified by an accredited CBAM verifier. Default values need no verification, but carry a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028. Fertilisers carry 1% instead.
Does Senseible file the CBAM declaration?
No. Senseible is not a declarant or customs representative. It builds your plant's emissions figures, the file a verifier checks and the pack you send your buyer's declarant.
Build your CBAM data in the CBAM suite, see the supplier pack, estimate your cost or see CBAM cost per tonne by sector.