What CBAM Data to Ask Steel Suppliers For in Poland

Published 2026-10-13.

Poland's construction sites and fabrication shops use a great deal of imported steel, much of it rebar, wire rod and sections from mills outside the EU. Since 1 January 2026, every tonne of it carries a CBAM obligation for the importer, and Polish distributors have been slowing purchases while the cost of certificates is uncertain, as Eurometal reported.

The cost depends mostly on one thing the importer does not control: the emissions data its suppliers can provide. This article answers what to ask for, and why.

The Polish rules in brief

Poland's law implementing CBAM gives oversight to KOBiZE, the National Centre for Emissions Management, and connects CBAM checks to the national customs IT system. From 1 January 2026, the importer or its indirect customs representative needs authorised CBAM declarant status to import covered goods. Applicants who filed by 31 March 2026 could keep importing while their application was assessed. Importers below 50 tonnes of covered goods a year are exempt.

Certificates for 2026 imports are bought from February 2027, and the first annual declaration is due by 30 September 2027.

Why supplier data decides the bill

Without verified data from the producing installation, the declarant must use EU default values. For steel those carry a mark-up of 10 percent in 2026, 20 percent in 2027 and 30 percent from 2028. Defaults are set cautiously, so an importer buying from an efficient mill pays for emissions the mill never produced.

The spread between mills is wide. Ukraine illustrates it: the EU took about half of Ukraine's steel output in 2025, according to Metinvest, and an industry study puts emissions from Ukrainian blast-furnace steel at up to 2.3 tonnes of CO2 per tonne, against about 1.2 tonnes for the EU average. Scrap-based electric arc mills, in Ukraine, Türkiye or elsewhere, can be far lower.

The supplier checklist

Ask each mill, in the contract and before the order:

Installation and route. Which plant made the steel, and by which route: blast furnace, electric arc on scrap, or DRI.
Specific embedded emissions per tonne of each product, for a stated reporting period.
Monitoring and verification. The methodology used, and the accredited verifier or the date verification is planned.
Carbon price paid at origin, with evidence, which the declarant can deduct.
Precursors. For rolled products, the emissions of the crude steel or semi-finished material they were made from.

Build the answers into supply agreements, with a price adjustment if verified data is not delivered. That puts the incentive where the data is.

Work out the difference

The CBAM calculator compares default values with actual emissions for each route and year to 2034. For how suppliers in other countries are preparing, see the CBAM cost guide for Indian steel exporters and how German importers lower CBAM costs.

This is general guidance, not legal advice. Check KOBiZE's current guidance for your case.