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CBAM liabilities are concentrated in steel and in a few exporting countries

Some exporters face tariff-equivalent exposure far above the global average.

By Carbon3 team1 min read

Carbon3 data card 'CBAM has arrived, and it will cost importers €12B+ in year one': effective CBAM tariff rates for the five most exposed countries (Indonesia, Egypt, Russia, India, Ukraine) and cost concentration by sector, led by iron and steel.

CBAM is now a financial reality, and the cost burden is highly concentrated. Steel dominates expected liabilities, while some exporting countries face tariff-equivalent exposure far above the global average.

Concentration is what makes the mechanism actionable. A small number of products and origins account for most of the expected cost, so a small number of supplier relationships account for most of a European importer's exposure. Those relationships are where co-financing a reduction pays back fastest, because the same tonne removed lowers the border levy and the importer's Scope 3 inventory at once.

Exporters see the mirror image. A verified reduction at the plant becomes a selling point to European customers and a source of revenue through inset credits, rather than a cost to be absorbed. Carbon3 structures that exchange so both sides can recover value from the same physical reduction.

Originally published on LinkedIn, 18 May 2026.

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