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CBAM does NOT apply to intra-EU trade: why, and how to verify your supply chain

This is one of the most common CBAM confusions: companies buying steel, aluminium or cement from EU suppliers wonder if CBAM applies to them. The answer is no. CBAM applies exclusively to goods imported from third countries outside the EU customs territory. EU producers already pay for their carbon emissions through the EU ETS — CBAM ensures that imports bear a comparable cost. If you buy within the EU, you have no CBAM obligations. But verify: if your EU supplier is actually reselling third-country goods, the original importer may have CBAM obligations. The free checker confirms.

Generate your CBAM dossier — €299Free check: does CBAM affect 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

Why CBAM does not apply to intra-EU trade

EU ETS
EU producers already pay for carbon emissions through the Emissions Trading System
CBAM = imports
CBAM applies only to goods released for free circulation from third countries
Intra-EU = no CBAM
Goods traded between EU member states are not subject to CBAM declarations or certificates

How to verify if CBAM applies to your purchases

1
Check: are you the importer of record?
CBAM applies to the company that releases goods for free circulation in the EU. If you buy from a European supplier who imported the goods, the supplier is the importer — not you.
2
Check: is the goods' origin within the EU?
If the steel, aluminium or cement was produced in the EU, CBAM does not apply. EU producers pay EU ETS.
3
Check: are the goods from Annex III exempt countries?
Iceland, Liechtenstein, Norway and Switzerland are exempt. Goods from these countries are not CBAM goods.
4
If all your purchases are intra-EU: no CBAM obligations
You do not need authorisation, declaration or certificates. No action required.
5
If some purchases include third-country imports: check those
If you import some goods directly from third countries (even if most of your supply is intra-EU), the imported portion is subject to CBAM.
6
Use the free checker to verify
The CBAMCheck free checker confirms whether your CN codes and origins are in scope. If you buy intra-EU, the checker confirms you are not affected.

Three misconceptions about CBAM and intra-EU trade

MISCONCEPTION 1 — CBAM APPLIES TO ALL STEEL/ALUMINIUM/CEMENT

Thinking CBAM covers domestic EU trade

CBAM is exclusively for third-country imports. EU-produced goods are covered by the EU ETS. There is no double coverage.

MISCONCEPTION 2 — EU RESELLERS CREATE CBAM OBLIGATIONS FOR BUYERS

Thinking you have CBAM obligations when buying from an EU distributor

If an EU distributor imported goods from a third country, the distributor is the importer of record and bears the CBAM obligations — not you as the downstream buyer.

MISCONCEPTION 3 — BUYING COMPLIANCE TOOLS BEFORE CHECKING

Purchasing CBAM documentation when you only trade within the EU

If all your purchases are intra-EU, you have no CBAM obligations. The free checker confirms in seconds. Do not pay for compliance you do not need.

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: quantities, emissions, certificates, carbon price.

5

Carbon Price Documentation

Documents any carbon price paid in the country of origin for Art. 9 deduction. Pre-formatted for the CBAM Registry.

6

Annex V Record Template

Record-keeping template compliant with Annex V requirements. Ready for verifier review.

7

Verification Preparation

Structured preparation for Art. 8 verification by an accredited verifier. Annex VI checklist included.

8

Supplier Letter Template

Model letter in English requesting emissions data and installation information from your third-country supplier.

9

Compliance Calendar (.ics)

Importable calendar with quarterly certificate obligations (Art. 22(2)), annual declaration deadline (30 September), and key milestones.

10

Executive Summary

One-page overview of your CBAM exposure: cost estimate, timeline, risk areas. Ready for management or board reporting.

11

Interactive HTML Dashboard

Standalone HTML dashboard with 2026–2032 projections reflecting free allocation phase-out (Art. 31). Works offline, no subscription.

12

Compliance Calendar Document

Visual calendar of all CBAM deadlines, reporting windows and certificate purchase 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 emissions 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 projectionPlatform-locked
Supplier letterNoEnglish template includedVariable
Art. 8 verification prepNoIncludedVariable
PrivacyVariable100% browser-sideData on server
Multi-company supportNoVia Professional PackYes

Choose your licence

1 DOSSIER
€299
/ dossier

  • 10 professional PDF documents
  • Interactive HTML dashboard (2026–2032 projection)
  • 13,566 official default values integrated
  • English supplier letter template
  • 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 brokers
  • 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 10 PDFs, HTML dashboard and .ics calendar remain functional offline.

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 your declaration in the CBAM Registry.

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 rate
EU ETS rate per 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 per Art. 16(4). The penalty applies per certificate not surrendered. 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): anyone introducing goods without authorisation faces a penalty of 3 to 5 times the standard penalty, depending on duration, gravity, scope, intent and cooperation. Also applies to importers exceeding the de minimis threshold (50 tonnes, Art. 2a) without authorisation (Art. 26(2a)).

Not sure if your supply chain includes third-country imports?

The free checker handles individual scope verifications. If you discover some imports are from third countries, CBAMCheck generates the dossier for those — €299 per dossier.

Request Professional Pack →
Free checker for scope · Intra-EU = no CBAM · Third-country imports = €299 per dossier

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 this a subscription?
No. One-time payment. The licence includes 30 days of editing and 10 regenerations. The downloaded dossier is yours forever.
Can I request a refund?
By activating the licence you give express consent for the immediate generation of digital content under Art. 16(m) of Directive (EU) 2011/83, waiving the 14-day withdrawal right. Refunds are accepted only for reproducible technical faults.
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.
Does CBAM apply if I buy steel from a German supplier?
No. If the steel was produced in Germany (or any EU country), CBAM does not apply. The German producer pays EU ETS for its carbon emissions. CBAM is only for imports from outside the EU.
What if my EU supplier imports from China and resells to me?
The CBAM obligation falls on the importer of record — the company that released the goods for free circulation. If your supplier imported and cleared the goods, they bear the CBAM obligations, not you.
Is there a free way to verify?
Yes. The CBAMCheck free checker confirms whether your purchases are subject to CBAM based on CN codes and origin. If all your supply is intra-EU, the checker confirms you are not affected — at no 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.

Intra-EU trade is not affected. Third-country imports are. Verify for free.

Free checker. No CBAM for intra-EU. If third-country imports exist: 12 deliverables, €299.

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