Cement
Cement clinker, white and grey Portland cement, aluminous cement, other hydraulic cements and calcined kaolinic clays.
CBAM Solutions for
End to end Carbon Border Adjustment Mechanism (CBAM) compliance for exporters of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen in India and worldwide, and for the EU importers who declare them. Embedded emissions measured, verified and reported, and CBAM certificates managed, as one accountable engagement delivered from Mumbai.
Measure · Verify · Report
Six covered goods
India and worldwide delivery
On record
Definitive regimeLive since 1 Jan 2026
Covered goodsSix product groups
Legal basisRegulation (EU) 2023/956
De minimis threshold50 t per importer a year
Default value markup10 / 20 / 30 percent
Coverage
01
From transition reporting to definitive compliance
For exporters of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen, and the EU importers who declare them.
The Carbon Border Adjustment Mechanism (CBAM) is the European Union framework that prices the carbon emissions embedded in imported goods. Transitional reporting ran from October 2023 to December 2025, and the definitive regime has applied since 1 January 2026. CBAM Solutions by GreenSutra carry exporters in India and worldwide, and their EU importers, from transition era reporting into full definitive compliance.
CBAM covers six product groups: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Under the Omnibus simplification a de minimis threshold of 50 tonnes per importer each year exempts most small consignments of the first four groups, while electricity and hydrogen remain in scope at any volume. Around 90 percent of importers are exempt, yet close to 99 percent of embedded emissions stay covered, so material exporters to the European market must act.
Each engagement quantifies the embedded emissions of the goods from actual verified installation data wherever possible, rather than default values that carry a regulatory markup. Verified data reaches EU importers and authorised declarants through the central CBAM registry, and the certificate exposure that tracks the EU ETS price is planned and managed.
Based in Mumbai and working with exporters in India and worldwide, GreenSutra runs the work end to end: exposure identified, embedded emissions measured, data verified and reported, and certificate obligations managed alongside a reduction pathway.
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Goods covered by CBAM
The six Annex I product groups, with representative products and the de minimis position of each.
CBAM applies to the goods listed in Annex I of Regulation (EU) 2023/956, grouped into six product groups. Coverage follows the combined nomenclature (CN) code of each good rather than its trade name, so the chapters and headings below act as the guide. The product lines name representative goods in each group rather than every covered code.
Iron and steel
Pig iron, crude and semi finished steel, flat rolled products, bars and rods, tubes and pipes, screws, bolts and nuts, and steel structures.
Aluminium
Unwrought aluminium, bars, rods and wire, plates, sheets and strip, foil, tubes and pipes, aluminium structures, containers and stranded wire.
Fertilisers
Nitric acid, ammonia, potassium nitrates, urea and other nitrogenous fertilisers, and multi nutrient fertilisers containing nitrogen.
Electricity
Electrical energy imported into the European Union.
Hydrogen
Hydrogen, a single combined nomenclature code covering the pure product.
A precise check of each product against the Annex I code list is the first step of every CBAM readiness review.
03
How a CBAM engagement runs
From exposure assessment to a verified, declared and managed certificate position.
01
Assess CBAM exposure
Covered goods, export destinations and volumes mapped against the definitive regime, the de minimis threshold and the authorised declarant requirement, so the obligation is understood before data work begins.
02
Measure embedded emissions
Embedded emissions of each product quantified from actual installation data following the EU methodology, in place of default values that carry a regulatory markup, then prepared for verification.
03
Verify with accredited verifiers
Installation data and the monitoring methodology behind it confirmed by an accredited verifier, so the declared embedded emissions stand on evidence rather than marked up default values.
04
Report through the CBAM registry
Verified data shared with EU importers and authorised declarants through the central CBAM registry, and the annual declaration prepared so every covered consignment is accounted for.
05
Manage certificates and reduce
Certificate position tracked against the EU ETS price, any carbon price paid at origin deducted, and a reduction pathway built to lower the embedded emissions and the cost over time.
04
How the Carbon Border Adjustment Mechanism works
The CBAM border mechanism follows embedded emissions from the Indian installation across the European border to the certificate that is surrendered.
01Installation · India
An Indian installation produces a covered good: cement, iron and steel, aluminium, fertilisers, electricity or hydrogen.
02Embedded emissions
The emissions embedded in the good are measured from installation data, or estimated using default values that carry a regulatory markup.
03Verified and shared
An accredited verifier confirms the data, which is shared with the European importer through the central CBAM registry.
04Border · declarant
The good crosses the European border, where an authorised CBAM declarant reports the embedded emissions for the year.
05Certificates surrendered
CBAM certificates are surrendered for the embedded emissions, priced off the EU ETS, with any carbon price already paid at origin deducted.
Embedded emissions are measured at the Indian installation, verified and shared through the CBAM registry, then declared at the European border by an authorised declarant who surrenders certificates priced off the EU ETS. A carbon price paid in the country of origin is deductible where the European Union recognises it.
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CBAM exposure self-check
Three answers map a business onto the definitive regime.
Three questions map an export trade against the definitive CBAM regime: the goods, the volume and the import route. The result states what the regulation says about that position and what to verify next.
Three questions decide CBAM exposure: which covered goods the business exports to the European Union, the combined annual volume bound for the EU, and who imports. A CBAM readiness review works through all three with the figures on the table.
Request a CBAM readiness review →- Declarant applicationsWindow closed 31 Mar 2026
- Certificate sales open1 Feb 2027
- First annual declaration, 2026 importsDue 30 Sep 2027
The trade sits outside CBAM today
None of the six covered goods are exported, so the Carbon Border Adjustment Mechanism places no obligation on this trade today. CBAM covers cement, iron and steel, aluminium, fertilisers, electricity and hydrogen under Regulation (EU) 2023/956. A proposal published in December 2025 would extend the mechanism to a wider set of downstream products from 2028; it has not been adopted, so the product list is the point to watch.
Covered goods, possibly within de minimis
The goods are covered and the combined volume sits under 50 tonnes a year. The 50 tonne de minimis applies to each EU importer's cumulative annual imports rather than to a single exporter's shipments, so exemption cannot be confirmed from the export side alone. If the buyer's total CBAM imports stay under 50 tonnes for the year, the consignments may fall within de minimis under Regulation (EU) 2025/2083. Verifying the buyer's position is the next step.
Covered goods, volume to confirm
The goods are covered, so exposure now turns on volume. The 50 tonne de minimis is measured on each EU importer's cumulative annual imports rather than on one exporter's shipments, so the buyer's total position decides it under Regulation (EU) 2025/2083. Confirming the combined EU bound volume and the buyer's import total is the first step of a readiness review.
Squarely within the definitive regime
The goods are covered and the volume is at or above 50 tonnes a year, so the trade sits squarely within the definitive CBAM regime that has applied since 1 January 2026. Embedded emissions must be measured, verified and shared so the EU importer or authorised declarant can file an accurate annual declaration, and verified actual data usually lands below the marked up default values.
In scope at any volume
Electricity and hydrogen are covered goods and both sit outside the 50 tonne de minimis, so volume does not lift the obligation. The trade falls within the definitive CBAM regime that has applied since 1 January 2026, and embedded emissions must be measured, verified and shared for the EU importer's annual declaration.
An own European entity importing the goods itself needs authorised CBAM declarant status to file the annual declaration.
The European buyer acts as the authorised declarant and will need verified embedded emissions data from the exporting installation.
The trader or agent importing into the EU holds the declarant obligation and will need verified embedded emissions data from the exporting installation.
Identifying the authorised declarant for the trade is part of the readiness review.
Answers stay in this browser. Nothing is sent until a contact channel is opened.
Embedded emissions follow each good from the Indian installation to the European border, and a readiness review turns that path into a measured, verified compliance plan.
WhatsAppRequest a CBAM readiness review →06
Benefits of CBAM solutions
What definitive regime readiness earns an exporter and its EU importer.
B·01
Market access retained
Verified embedded emissions data keeps covered goods moving into the European market under the definitive regime without compliance friction.
B·02
Lower certificate cost
Actual verified data replaces marked up default values, so the certificate obligation reflects real performance rather than a penalty estimate.
B·03
Trusted supplier status
Sharing verified data through the CBAM registry positions the exporter as a preferred supplier to European importers and declarants.
B·04
Decarbonisation advantage
A reduction pathway lowers embedded emissions over time, an advantage that grows as EU ETS free allocation phases out toward 2034.
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Why GreenSutra leads CBAM consulting
The reasons behind the reputation.
R·01
Certified expertise
Each engagement led by a certified specialist with proven experience across carbon accounting and climate compliance.
R·02
EU and India regulatory fluency
Working knowledge of the definitive CBAM regime alongside India's carbon market and CCTS, so guidance fits both sides of the trade.
R·03
Data driven
Actual installation data turned into verified embedded emissions, reducing reliance on marked up default values.
R·04
End to end delivery
Exposure assessment, measurement, verification, reporting and certificate management handled as one accountable engagement.
R·05
Mumbai based, serving worldwide
CBAM services delivered to exporters and EU importers worldwide from a Mumbai base.
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Built for every covered good
The same compliance discipline, tuned to each exporter and the importers they supply.
01
Iron, steel and aluminium exporters
Metals producers measure embedded emissions per installation and share verified data with European buyers.
02
Cement and fertiliser producers
Process heavy goods assessed against the definitive regime, with the de minimis position and declarant route clarified.
03
Electricity and hydrogen suppliers
Goods that stay in scope below the threshold supported with installation level emissions data and registry reporting.
04
European importers and declarants
Authorised declarants and importers sourcing from India obtain verified supplier data to file accurate annual declarations.
Every covered good carries the same compliance discipline, tuned to the exporter and the European buyers it supplies.
WhatsAppRequest a CBAM readiness review →09
CBAM questions, answered
Q·01What are CBAM solutions?
CBAM solutions help exporters of covered goods in India and worldwide, and the EU importers who declare them, comply with the European Union Carbon Border Adjustment Mechanism. The work covers exposure assessment, measurement of embedded emissions, verification, reporting through the CBAM registry and management of certificate obligations under the definitive regime that has applied since 1 January 2026.
Q·02Which goods does CBAM cover?
CBAM covers six product groups: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. A proposal published in December 2025 would extend the mechanism to a wider set of downstream products from 2028, but that extension has not been adopted.
Q·03What are embedded emissions?
Embedded emissions are the greenhouse gas emissions released in producing a good. Under CBAM they are calculated from actual verified installation data where available, or from default values that carry a regulatory markup of 10 percent in 2026, 20 percent in 2027 and 30 percent from 2028.
Q·04Does the 50 tonne threshold remove the obligation?
The Omnibus simplification introduced a de minimis threshold of 50 tonnes per importer each year for cement, iron and steel, aluminium and fertilisers. Electricity and hydrogen are excluded from this exemption. Around 90 percent of importers fall below the threshold, yet close to 99 percent of embedded emissions remain covered, so material exporters are still affected.
Q·05Why use actual data instead of default values?
Default values carry a regulatory markup, so they tend to overstate emissions. Actual verified installation data, confirmed by an accredited verifier, usually produces a lower and more accurate figure, which reduces the certificate obligation that the European importer faces. Compare default and verified costs in the calculator →
Q·06What are the key CBAM deadlines?
Importers above the threshold must hold authorised CBAM declarant status; the application window closed on 31 March 2026. Certificate sales begin on 1 February 2027, and the first annual CBAM declaration, covering 2026 imports, is due by 30 September 2027.
Q·07What data does the European importer need from an Indian supplier?
The importer or authorised declarant needs the verified embedded emissions of the goods supplied. An Indian installation can register voluntarily in the CBAM registry and share this verified data centrally, so the declarant can file an accurate annual declaration.
Q·08Can a carbon price paid in India be deducted?
A carbon price paid in the country of origin is deductible against the certificate obligation where the European Union recognises it. As of June 2026 India's Carbon Credit Trading Scheme is not yet recognised by the European Union, although the India and European Union trade agreement opens a technical dialogue on carbon price recognition.
Q·09Which products fall under CBAM iron and steel?
The iron and steel group covers most of combined nomenclature chapter 72 and listed headings of chapter 73, from pig iron and semi finished steel through flat rolled products, bars, rods, tubes and pipes, to finished articles such as screws, bolts and nuts and steel structures. Coverage follows the CN code of each good, so Annex I of Regulation (EU) 2023/956 is the reference for any specific product.
Q·10Are downstream or finished products covered by CBAM?
The definitive regime covers the six Annex I product groups: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen, including finished articles that Annex I lists, such as iron or steel screws, bolts and structures. A proposal published in December 2025 would extend the mechanism to a wider set of downstream products from 2028, but that extension is a proposal only and has not been adopted.
Q·11Do CN codes decide CBAM coverage?
Yes. Annex I of Regulation (EU) 2023/956 lists the covered goods by combined nomenclature (CN) code, grouped into six product groups. Whether a good is in scope follows from its CN classification rather than from its trade name, so classifying the product correctly is the first step of any CBAM exposure assessment.
10
Asked at the Expert's Corner
Real CBAM and carbon border questions from the community, answered by the GreenSutra team.
Q · 01CBAM3,848 views
Who are NCA?
NCA are National Competant Authorities. National Competant Authorities are involved in the implementation of the Carbon Border Adjustment Mechanism also known as CBAM. Importers…
Answered by Team GreenSutra®Q · 02CBAM3,824 viewsWhat is meant by Embedded Carbon Emissions?
Embedded Carbon Emissions are carbon emissions that are emitted during the procurement, processing and distribution of goods. In other words, the greenhouse gas emissions…
Answered by Team GreenSutra®Q · 03CBAM3,724 viewsWhat is meant by Life Cycle Assessment (LCA)?
Life Cycle Assessments or LCA are assessment methodologies that allow quantification of environmental and other impacts of products or processes throughout their various stages…
Answered by Team GreenSutra®Q · 04CBAM3,690 viewsWhat is ETS?
ETS refers to Emissions Trading Scheme. Article 17 of Kyoto Protocol allows the countries that have emissions units to spare to sell these excess…
Answered by Team GreenSutra®Q · 05CBAM3,657 viewsAre there penalties for non-compliance with the CBAM Regulation?
CBAM Regulations were enforced from 1st October 2023 by the European Union. The introduction of these regulations are attempt to address the global problem of…
Answered by Team GreenSutra®Q · 06CBAM3,651 viewsWhat is CBAM definitive period?
Carbon Border Adjustment Mechanism or CBAM has been enforced by the European Union in an attempt to address the global problem of climate change.…
Answered by Team GreenSutra®Q · 07CBAM3,645 viewsWhat is CBAM transitional period?
CBAM or Carbon Border Adjustment Mechanism was enforced by the European Union on 1st October 2023 in an attempt to address the global problem…
Answered by Team GreenSutra®Q · 08CBAM3,566 viewsWhat are Simple CBAM Goods?
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Request a CBAM readiness review
A short conversation about covered goods, export volumes and the European buyers involved turns into a tailored CBAM plan. Schedule a call directly or send a written brief.
01Schedule a call
Pick the service and a slot; a practitioner takes the call.
02Write to us
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Field notes and stories
Reading on carbon markets, the EU and Indian green standards from the GreenSutra journal.
13
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Maintained by GreenSutra · Last reviewed June 2026
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Summary
Article Name
Carbon Border Adjustment Mechanism (CBAM) Solutions - GreenSutra | India
DescriptionCarbon Border Adjustment Mechanism Solutions by GreenSutra helps organisations to comply with the (CBAM) regulation which has been introduced by the European Union (EU) to quantify a fair price on the Carbon emitted during the production of carbon intensive goods that are entering the EU.
Author
Team GreenSutra
Publisher Name
GreenSutra
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