CBAM for Indian exporters: what to have ready before September 2027

The definitive CBAM regime started on 1 January 2026 for cement, iron and steel, aluminium, fertilisers, electricity and hydrogen.¹ An EU importer bringing in more than 50 tonnes a year of cement, steel, aluminium and fertiliser goods combined needs authorised CBAM declarant status. Once over the threshold, every tonne imported that year counts.²

The dates that matter

Default values cost money

Where verified actual emissions are not available, the importer declares default values. For 2026 imports, defaults for cement, iron and steel, aluminium and hydrogen carry a 10% mark-up, rising to 20% in 2027 and 30% from 2028; fertilisers carry 1%.³ India has its own country defaults. Hot-rolled flat steel on the blast furnace route (CN 7208), for example, is set at 4.28 t CO₂e per tonne before mark-up.³

For 2026 imports the certificate price is the quarterly average of EU ETS auction prices: €75.36 per tonne of CO₂e for the first quarter, €75.28 for the second and €82.32 for the third.⁴ The charge is reduced to reflect free allocation still given to EU producers: the CBAM factor is 97.5% in 2026, 95% in 2027 and 90% in 2028, falling to zero from 2034.⁸ Even so, every tonne of embedded emissions your data removes from the marked-up default lowers what your buyer pays.

What verification involves

Actual emissions must be monitored under the CBAM rules and verified by an accredited verifier. In the first year of verification a physical site visit is required in every case.⁵ A third-country installation can be registered in the CBAM registry for five years.² Verifiers could register from September 2026, and the first verification reports can be issued from January 2027.¹

Carbon prices paid in India

A deduction for a carbon price paid in the country of origin is allowed only for a price effectively paid, net of any rebate, and certified by an independent person.² Whether payments under India's Carbon Credit Trading Scheme will qualify is not yet settled. The India–EU trade agreement concluded on 27 January 2026 is not yet signed; its annex on carbon border measures gives no exemption. It provides for dialogue on default values and verification, on the possibility of taking a carbon price paid in India into account, and on exploring mutual recognition of verifier accreditation.⁶

Exporting to the UK as well

The UK's own CBAM starts on 1 January 2027 for aluminium, cement, fertiliser, hydrogen, and iron and steel, with the first annual return and payment due at the end of May 2028.⁷ Prepared once, the same installation data serves both.

What to do this quarter

List the products and CN codes you ship to the EU and UK, fix your installation boundary, and assemble twelve months of production, fuel, electricity and precursor data. Register the installation in the CBAM registry. Book an accredited verifier early, because the first-year site visit takes time to schedule and your buyers need the verified report well before their 30 September 2027 declaration.

PathCarbon prepares the monitoring plan, the embedded-emissions calculation for each good and the data pack your importer and verifier need. Verification itself must be carried out by an accredited CBAM verifier. Our job is to have the monitoring plan, calculations and evidence ready so the verifier can complete it without avoidable findings.