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What CBAM means for future hydrogen imports from Saudi Arabia — the regulatory framework is in force and your long-term contracts should reflect it

You are an energy company or industrial buyer evaluating long-term hydrogen supply from Saudi Arabia. Saudi Arabia has large-scale green and blue hydrogen production projects under construction, targeting EU export markets. The CBAM framework for hydrogen is already in force under Reg. (EU) 2023/956 — hydrogen (CN 2804 10 00) is listed in Annex I with CO₂ as the applicable greenhouse gas. Saudi Arabia has no carbon pricing mechanism. The de minimis threshold does not apply to hydrogen (Art. 2a(4)). You do not need CBAMCheck today — but you need to understand the framework that will govern your imports when commercial flows begin. CBAMCheck is available at €299 one-time when you are ready to generate documentation.

Generate your CBAM dossier — €299Free check: does CBAM apply to you?

€299 · One-time · 12 professional deliverables · Your data never leaves your browser

Built on Reg. (EU) 2023/956 · Modified by Reg. (EU) 2025/2083 · 13,566 default values (Reg. 2025/2621) · 100% browser-side — your data never leaves your device

The numbers that matter for your CBAM compliance

CN 2804 10 00
Hydrogen is CBAM-covered. GHG: CO₂. Framework already in force
No de minimis
Art. 2a(4): every kilogram of hydrogen is subject to CBAM
Saudi default: 13.45
tCO₂e/t — but green hydrogen actual emissions could be far lower

Your CBAM compliance timeline

1
Understand the CBAM framework for hydrogen
CN 2804 10 00. Annex I. CO₂. No de minimis (Art. 2a(4)). In force since 1 January 2026.
2
Assess emission calculation methods
Art. 7 + Annex IV. Default value for Saudi hydrogen: 13.45 tCO₂e/t. For green hydrogen with verified actual emissions, the figure could be dramatically lower.
3
Evaluate Art. 9 carbon price status
Saudi Arabia has no carbon pricing mechanism. No deduction available.
4
Build CBAM clauses into supply contracts
Long-term offtake agreements should include emissions data obligations, verification requirements and cost-sharing provisions for CBAM certificates.
5
Model CBAM cost projections
Use the free allocation phase-out schedule (2.5% in 2026 rising to 100% by 2034) to project long-term CBAM costs.
6
Generate documentation when ready
CBAMCheck generates the full dossier (€299) when commercial flows begin or when you need documentation for investment decisions.

Three mistakes that inflate your CBAM cost or create compliance risk

MISTAKE 1 — IGNORING CBAM IN CONTRACTS

Signing long-term hydrogen offtake without CBAM cost provisions

CBAM costs will escalate as free allocation phases out. A 15-year contract signed without CBAM clauses exposes you to unhedged regulatory cost from 2026 onwards.

MISTAKE 2 — HYDROGEN NOT COVERED ASSUMPTION

Assuming CBAM only applies to steel, cement and traditional industrial goods

Hydrogen (CN 2804 10 00) is one of six sectors explicitly covered by Annex I. It has been in scope since the original regulation.

MISTAKE 3 — DE MINIMIS TRAP

Planning for small initial volumes assuming they’re exempt

Art. 2a(4) explicitly excludes hydrogen from the 50-tonne de minimis threshold. No volume is too small.

What you receive: 12 deliverables in one ZIP file

CBAMCheck generates a complete CBAM compliance dossier — not a single PDF. 12 structured documents delivered as a ZIP file, each citing the specific article of Reg. (EU) 2023/956 it addresses.

1

Scope Assessment

Determines whether your imports fall under CBAM and which obligations apply. Art. 2 + Art. 2a of Reg. (EU) 2023/956.

2

Embedded Emissions Calculation

Calculates embedded emissions per tonne using default values from Implementing Reg. (EU) 2025/2621 or your actual data. Art. 7 + Annex IV.

3

CBAM Certificate Estimation

Estimates the number of certificates required and the projected cost, adjusted for free allocation (Art. 31).

4

Draft CBAM Declaration

Pre-structured declaration following Art. 6(2) requirements.

5

Carbon Price Documentation

Documents any carbon price paid in the country of origin for Art. 9 deduction.

6

Annex V Record Template

Record-keeping template compliant with Annex V requirements.

7

Verification Preparation

Structured preparation for Art. 8 verification. Annex VI checklist included.

8

Supplier Letter Template

Model letter requesting emissions data from your third-country supplier.

9

Compliance Calendar (.ics)

Importable calendar with quarterly certificate obligations, annual declaration deadline and key milestones.

10

Executive Summary

One-page CBAM exposure overview for management reporting.

11

Interactive HTML Dashboard

Standalone dashboard with 2026–2032 projections. Works offline.

12

Compliance Calendar Document

Visual calendar of all CBAM deadlines and schedules.

Generated from your input data, in your browser. No data leaves your device.

See what you get

Download a sample CBAMCheck dossier. This is a real output generated with generic data — the same 12 deliverables you will receive with your company’s actual figures.

Download sample dossier (ZIP)

Generic data. Your dossier will contain your actual import figures, CN codes and emission calculations.

Estimate your CBAM exposure

Select your sector and country of origin. CBAMCheck searches through 13,566 official records from Implementing Reg. (EU) 2025/2621 and shows the result with the 2026 mark-up included.

Quick CBAM Calculator

Average European Commission default values per sector and country of origin.

Default emissions (tCO₂e/t)
Mark-up 2026 (10%)
Total emissions with mark-up
CBAM rate 2026 (2.5%)
Estimated certificates

This is a quick estimate. Your complete dossier includes projections through 2032, an editable interactive dashboard, and 10 PDF documents.

Generate your complete dossier — €299 →

Average values per sector from Implementing Reg. (EU) 2025/2621. The complete dossier uses the exact CN code of your goods, not the sector average. Estimated EU ETS price: €75/tCO₂e.

What CBAM compliance costs with each alternative

FeatureFree toolCBAMCheckSaaS Enterprise
PriceFree€299 (one-time)€1,990–€4,800/year
ModelGeneric template12 professional deliverablesAnnual subscription
Default valuesNot included13,566 (Reg. 2025/2621)Partial
Interactive dashboardNoHTML, 7-year projectionInside platform
Supplier letterNoEnglish template includedVariable
Art. 8 verification prepNoIncludedVariable
PrivacyVariable100% browser-sideData on server

Choose your licence

1 DOSSIER
€299
/ dossier

  • 10 professional PDF documents
  • Interactive HTML Dashboard (projection 2026–2032)
  • 13,566 official values integrated
  • Template letter in English for supplier
  • Importable .ics calendar
  • 10 regenerations · 30 days
  • 1 licence = 1 importing company
Get your individual licence →
PROFESSIONAL PACK
€1,999
70 generations · 1 key

  • 70 generations with a single key
  • 70 complete dossiers (12 deliverables each)
  • Switch product between generations
  • Ideal for customs representatives
  • For consultants billing CBAM compliance
70 interactive HTML Dashboards × product (projection 2026–2032). Real-time tables and charts with variable calculations. No technical training required. Fully intuitive.
🔒 Data stays on your computer. No information shared with third parties.
Request Professional Pack →

How your licence works

1
1 licence = 1 importing company. You pay €299 for the dossier you generate now. The licence is linked to your company name + EORI.
2
Up to 10 regenerations of the ZIP to correct data, adjust goods or update technical information.
3
30-day editing window from first activation. Within that period you can regenerate the dossier as many times as needed (up to 10).
4
The downloaded dossier is yours forever. It does not expire and is not tied to any subscription.

The EU CBAM portal asks for data. CBAMCheck calculates it.

THE EU CBAM PORTAL

Asks you to declare data

The EU CBAM Registry (Art. 14) requires you to submit total embedded emissions, number of certificates and carbon price documentation. It does not calculate these for you. You must arrive with the numbers ready.

CBAMCHECK

Calculates the data you need to declare

CBAMCheck takes your import data (tonnes, CN codes, country of origin) and generates the embedded emissions calculation, certificate estimation, carbon price documentation and all supporting records. You download the dossier and use it to complete the CBAM Registry submission.

Enforcement: what happens when CBAM certificates are missing

Art. 26 of Reg. (EU) 2023/956 sets the penalties.

⚠️
Authorised declarant: penalty identical to EU ETS excess emissions penalty
EU ETS rate per missing certificate

Art. 26(1): an authorised CBAM declarant who fails to surrender the required certificates by 30 September faces a penalty identical to the excess emissions penalty under Art. 16(3) of Directive 2003/87/EC, increased pursuant to Art. 16(4). Payment does not release the obligation to surrender outstanding certificates (Art. 26(3)).

⚠️
Unauthorised importer: penalty 3–5 times the standard rate
3–5×

Art. 26(2): a person who introduces goods without authorisation faces a penalty of 3 to 5 times the standard penalty. This also applies to importers exceeding the de minimis threshold (50 tonnes, Art. 2a) without authorisation (Art. 26(2a)).

Evaluating hydrogen supply from Saudi Arabia, Morocco, Chile and Australia?

Professional Pack: 70 dossier generations. Model CBAM exposure across origins and production methods before committing to long-term supply.

Request Professional Pack
One-business-day response · No sales call required

What CBAMCheck guarantees and what it does not

CBAMCheck generates a document structured according to Art. 6 and Art. 7 + Annex IV of Regulation (EU) 2023/956 from the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as importer or authorised CBAM declarant.

We guarantee that the document structure follows Regulation (EU) 2023/956 and that the legal references cited are correct. We do not guarantee that a specific document will be accepted by a national competent authority in a specific case.

CBAMCheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.

Frequently asked questions

Is hydrogen from Saudi Arabia subject to CBAM?
Yes. Hydrogen (CN 2804 10 00) is listed in Annex I. CBAM applies from 1 January 2026 regardless of the production method (green, blue, grey).
What is the Saudi Arabia default value for hydrogen?
13.45 tCO₂e/t under Implementing Reg. (EU) 2025/2621. For green hydrogen produced from renewable electricity, verified actual emissions under Art. 7(2)(a) would be far lower.
Should I buy CBAMCheck now?
Only if you need to model CBAM exposure for investment decisions or contract negotiations now. If you are only evaluating the regulatory framework, this landing page gives you the key articles and obligations. CBAMCheck is €299 one-time when you are ready to generate documentation.
Does Saudi Arabia have a carbon price?
No. No carbon tax, no ETS, no mechanism qualifying for Art. 9 deduction.
Is this a subscription?
No. One-time payment. The licence includes 30 days of editing and 10 regenerations. The downloaded dossier is yours to keep.
Can I get a refund?
Upon activating the licence you give express consent for immediate generation of digital content pursuant to Art. 16(m) of Directive (EU) 2011/83, waiving the 14-day withdrawal right. Refunds are accepted only for a reproducible technical fault.
What if the regulation changes?
If the regulation changes during your licence validity, you can regenerate the document with the updated version of the generator at no extra cost.
⚠️ Important notice: CBAMCheck is a self-assessment documentation tool, not legal advice and not a third-party audit. The document is generated from your input data. You are responsible for the accuracy of the data you provide. CBAMCheck does not replace a qualified professional assessment.

The CBAM hydrogen framework is live. Understand it before your next offtake negotiation.

12 deliverables when you’re ready. Saudi default 13.45 tCO₂e/t. No de minimis. Projection 2026–2032. €299 one-time.

€299 one-time
12 professional deliverables · Browser-side · No subscription · Reg. (EU) 2023/956
Generate your CBAM dossier — €299