CBAM Exporter Obligations: What a UK Manufacturer Selling into the EU Must Prepare

A UK factory has no direct obligation under the EU's CBAM: it does not declare, buy certificates or pay penalties. Those duties fall on the EU's authorised CBAM declarants. Since 1 January 2026, however, each tonne your EU customers import costs them certificates. They can only base that cost on your plant's actual emissions, instead of the Commission's conservative default values, if you provide data monitored under EU rules and verified by an EU-accredited verifier. This article covers what that means in practice, and what the EU CBAM knowledge base can and cannot tell you.

From data requests to a financial bill: transitional versus definitive

The Commission's Guidance No. 3 (August 2026) summarises the shift as a move "from a learning and data-collection phase to a fully operational regime in which embedded emissions determine the financial obligations of EU authorised declarants".

Does it affect your plant?

Check your products' CN codes against Annex I of Regulation (EU) 2023/956, which covers cement, iron and steel, aluminium, fertilisers, hydrogen and electricity. Annex III lists the only origins outside the scope: Iceland, Liechtenstein, Norway and Switzerland, plus five territories. The United Kingdom is not among them. Guidance No. 2 for non-EU operators points out that you are also concerned if:

• a trader resells your goods into the EU;
• another manufacturer uses your product as a precursor in a CBAM good later imported into the EU;
• your goods are sold to clients who themselves make CBAM goods.

The knowledge base contains only EU instruments. It says nothing about any UK carbon border adjustment, so none is discussed here.

Registration in the CBAM Registry: voluntary but recommended

Guidance No. 2 calls registration in the registry's O3CI module ("Operators of 3rd country Installations") "the recommended, but currently voluntary method". Under Article 10 of the regulation:

• the Commission registers you on request, with your company details, registration number, any parent company, and each installation's address and coordinates to six decimal places;
• registration lasts five years from notification;
• registered operators determine embedded emissions per type of good, have them verified, keep records for four years after verification, and upload carbon-price evidence where relevant;
• you may then disclose verified data to declarants, who may use it to meet their own verification obligation (Arts 8(2) and 10(7)).
• you can ask for your name, address and installation locations not to be public (Art. 14(4)); you may also ask to be deregistered at any time (Art. 10(8)).

The practical case for registering: you upload each installation's verified data once for all importers, and they see only a summary of your emissions report. Without registration, declarants must obtain your full verification and emissions reports. Since the 2025 amendment, the definition of "operator" includes a parent company that controls an installation (Art. 3(31)). A UK group can therefore manage several sites centrally.

Monitoring and the operator's emissions report

Guidance No. 2 describes how to build a monitoring plan, which must be available to the verifier in English:

1. Set installation boundaries and production processes, grouping CN codes as the Methodology Act permits.
2. Monitor direct emissions by calculation or continuous measurement. N2O from nitric acid must be measured; PFCs from primary aluminium use an overvoltage-based method.
3. Attribute measurable heat flows to production processes.
4. Track electricity for indirect emissions where the good requires it. Goods in Annex II (iron and steel, aluminium, hydrogen, electricity) count direct emissions only, so in practice this applies to cement and fertilisers.
5. Record precursors and their suppliers' verified data. There is no minimum quantity below which a precursor can be ignored.
6. Collect the data for the free allocation adjustment and, where relevant, the carbon price paid.
7. Put data-flow controls in place.

Each year you complete the mandatory operator's emissions report template and its summary, then pass the specific embedded emissions to your EU customers.

Why customers now ask for free allocation data

Under Article 31, the certificates a declarant surrenders are reduced to reflect the free EU ETS allowances that EU producers of the same goods still receive. Under Implementing Regulation 2025/2620, the adjustment takes into account the quantity imported, the EU ETS cross-sectoral correction factor, the CBAM factor in the ETS Directive, and a CBAM benchmark for each commodity code. That benchmark combines the relevant EU ETS benchmarks. If your customer declares your actual emissions, the adjustment also reflects your actual production route, precursors and composition. If it uses default values, default CBAM benchmarks apply. The 2026 benchmarks are based on estimated 2026-2030 ETS benchmarks, and updated values apply to goods imported from 1 January 2027. For electricity, the adjustment is zero.

Verification and timing

Your verifier must be accredited by a national accreditation body in the EU, with an accreditation covering your sector (Guidance No. 2). Implementing Regulation 2025/2546 requires a physical site visit in the first year of verification. After that, a virtual visit or waiver is allowed only under strict conditions, and a physical visit must take place at least every two years. Misstatements are material above 5% of specific embedded emissions or of specific embedded free allocation, per tonne of each CN code.

If you pay a carbon price at home

Article 9 lets the EU declarant claim a reduction in the certificates to surrender for a carbon price effectively paid in a third country, net of any rebate or compensation. Guidance No. 2 adds that free allocation under an emissions trading system counts as a rebate. The evidence must be certified by a person independent of the declarant and of the third country's authorities. Where default values are used, only yearly default carbon prices, which the Commission may publish from 2027, can be relied on. You would need to express the price in euros per tonne of good for your customers.

The knowledge base cannot confirm the operational details. The implementing act on converting a carbon price paid into a reduction in certificates had not been adopted when it was compiled, and it does not assess whether any UK carbon pricing qualifies. Check the Commission's dedicated guidance when it is published.

This article is general information on EU rules as at the Commission guidance of August 2026, not legal or technical advice. Questions such as "Can my EU customer use my own figures instead of the EU default values?" can be put to the knowledge base, which cites its sources.