CBAM for Vietnamese Steel Exporters: A 90-Day Readiness Plan

Updated 2026-10-11.

Vietnamese steel and aluminium exporters to the EU now supply buyers who owe CBAM certificates on every tonne of embedded emissions above the free-allocation adjustment, from 1 January 2026. In 90 days, a mill can map its CN codes, measure emissions per tonne and line up verification before buyers file their first declaration on 30 September 2027.

At a glance

Item	Detail
Vietnamese goods most affected	Iron and steel (Chapter 72, selected Chapter 73), aluminium (7601 and others)
Who pays	The EU importer (authorised CBAM declarant)
Certificate price, Q3 2026	€82.32 per tCO2
Default value mark-up	10% (2026), 20% (2027), 30% (2028 on)
Vietnam grid factor	About 0.68 tCO2e per MWh for 2024 (study with the Ministry of Agriculture and Environment; use the official Department of Climate Change figure once published)

The 90-day plan

Days 1 to 30: map and collect

List every product shipped to the EU with its CN code and annual tonnage per buyer.
Collect 12 months of fuel, electricity, raw material and output records per installation.
Identify precursors you buy in, such as pig iron, DRI or slabs.

Days 31 to 60: calculate

Calculate direct emissions per tonne for each product under the EU CBAM methodology.
Add precursor emissions using supplier data or default values.
Compare with the EU default value for each CN code to see where verified data helps your buyer.

Days 61 to 90: verify and share

Engage an accredited verifier. The Commission expected the first accreditations around September 2026 and verification work from early 2027.
Agree a data template and schedule with each EU buyer.
Publish one consistent figure per product and period, and keep the evidence trail.

Worked example

An EAF mill in Vietnam ships 2,000 tonnes of rebar a year to the EU.

Step	Value
Verified direct intensity (scrap EAF)	0.4 tCO2 per tonne
Embedded emissions	800 tCO2
Free-allocation adjustment (indicative benchmark 1.52 × 97.5% × 2,000 t)	2,964 tCO2
Certificates owed in 2026	0

A scrap-based mill below the benchmark may owe nothing in 2026; a blast-furnace mill shipping the same tonnage would owe on every tonne above the adjustment. Run both cases in the CBAM cost calculator.

Frequently asked questions

Does Vietnam's carbon market reduce CBAM?

Only a carbon price effectively paid, and documented, can be deducted under CBAM Article 9. Check whether any domestic payment applies to your plant.

Which grid factor should a Vietnamese plant use?

Use the official grid emission factor announced by the Department of Climate Change for the relevant year. For steel and aluminium, CBAM counts direct emissions only, so the grid factor matters most for your own carbon footprint and for cement or fertiliser products.

What if we sell through a trading company?

The EU importer of record is the declarant. Make sure the trader passes your installation data through unchanged.