CBAM and Scope 3: what the EU border carbon price means for value-chain emissions

The Carbon Border Adjustment Mechanism puts a carbon price on certain goods imported into the EU, equal to the price EU producers pay under the EU Emissions Trading System (EU ETS). It covers cement, iron and steel, aluminum, fertilizers, hydrogen and electricity, and some of their precursors and downstream products.

• Authorized CBAM declarants report the embedded emissions of the goods they imported in the previous year and surrender one CBAM certificate per tonne of CO₂e.
• Importers below 50 tonnes of covered goods a year are exempt. The threshold does not apply to hydrogen or electricity.
• Embedded emissions should be based on actual data from the producing installation, checked by an accredited verifier. Where actual data is missing, default values apply.
• A carbon price effectively paid in the country of production can be deducted.
• Certificates for 2026 imports are priced at the quarterly average of EU ETS auction prices, and from 2027 at the weekly average.

For the company that buys imported steel, aluminum or cement, the embedded emissions of those goods are Scope 3 emissions, under Category 1, purchased goods and services, or Category 2, capital goods. CBAM obliges importers to collect independently verified, installation-level emissions data for those same goods.

That makes CBAM a source of primary supplier data. A buyer that has relied on industry-average emission factors for purchased metals can ask for the embedded-emissions figures its suppliers already report, and use them to calculate and track its Scope 3 emissions.