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CBAM and inward/outward processing: Art. 6(3) and Art. 6(4) explained

Inward and outward processing are common customs regimes that interact with CBAM obligations in specific ways. Art. 6(3): for inward processing (third-country goods processed in the EU and then released for free circulation), you report the embedded emissions of the original imported goods — not the processed product. Art. 6(4): for outward processing (EU goods sent abroad for processing and then reimported), you report only the emissions from the processing operation performed outside the EU. CBAMCheck generates documentation covering both regimes.

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

The numbers that matter for CBAM processing regimes

Art. 6(3)
Inward processing → report embedded emissions of the original third-country goods
Art. 6(4)
Outward processing → report only the emissions of the processing operation abroad
Key distinction
Inward = full original emissions. Outward = processing delta only.

How to handle CBAM under processing regimes

1
Identify which processing regime applies
Inward processing: you import raw materials, process them in the EU, and release the finished product. Outward processing: you export EU goods, have them processed abroad, and reimport the result.
2
Inward processing: calculate emissions of the original goods
Art. 6(3): the CBAM declaration must cover the embedded emissions of the goods originally imported — the raw materials — not the finished product after EU processing.
3
Outward processing: calculate emissions of the processing operation only
Art. 6(4): you report only the embedded emissions generated by the processing operation performed outside the EU. The original EU-origin goods are not counted.
4
Document the processing regime clearly
Your customs declarations must identify the processing regime (inward or outward). The CBAM declaration must match the customs treatment.
5
Submit CBAM declaration with correct emissions basis
Art. 6: include the goods in your annual declaration with the emissions calculated under the correct processing rule. Inward = original goods. Outward = processing delta.
6
Prepare for Art. 8 verification
Verifiers will check that you applied the correct processing regime rule. Documentation linking customs regime to CBAM emissions basis is essential.

Three mistakes importers make with CBAM processing regimes

MISTAKE 1 — CONFUSING INWARD AND OUTWARD

Applying outward processing rules to inward processing or vice versa

The emissions basis is different: inward = full original goods emissions (Art. 6(3)); outward = processing operation emissions only (Art. 6(4)). Mixing them up creates either overcounting or undercounting.

MISTAKE 2 — REPORTING PROCESSED PRODUCT EMISSIONS FOR INWARD PROCESSING

Calculating emissions of the finished product instead of the original import

Under Art. 6(3), you report the emissions of the original imported goods — the raw materials — not the product after EU processing. The EU processing step is irrelevant for CBAM.

MISTAKE 3 — IGNORING PROCESSING REGIMES ENTIRELY

Treating all imports identically regardless of customs regime

Standard imports, inward processing and outward processing each have different CBAM emissions rules. Applying the standard rule to processing regime goods creates compliance errors.

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)).

Managing CBAM for both standard imports and processing regimes?

The Professional Pack covers 70 dossier generations. Handle standard imports, inward processing and outward processing — each with the correct emissions basis.

Request Professional Pack →
70 generations · 1 key · Processing regimes documented 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.
What is the CBAM rule for inward processing?
Art. 6(3): for goods subject to inward processing that are subsequently released for free circulation, the CBAM declaration must cover the embedded emissions of the original imported goods — not the processed product. You report the emissions of the raw materials, not the finished output.
What is the CBAM rule for outward processing?
Art. 6(4): for goods subject to outward processing (EU goods sent abroad for processing and reimported), the CBAM declaration covers only the embedded emissions of the processing operation performed outside the EU. The original EU goods are not counted.
⚠️ 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.

Inward and outward processing have different CBAM emissions rules. Get them right.

12 deliverables. Scope assessment for processing regimes. Art. 6(3) and 6(4) documentation. €299.

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