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You import specialty steel from Japan — and Japan’s carbon tax may qualify for an Art. 9 deduction that lowers your CBAM certificate cost

You are an OEM, tier-1 automotive supplier or specialised manufacturer in Germany, France or Italy. Your steel comes from Japanese mills producing grades that few other suppliers can match — electrical steels, advanced high-strength automotive grades, precision alloys. Japan is not a volume commodity exporter, but it supplies the EU with high-value steel critical to advanced manufacturing. Under the CBAM, every tonne is subject to embedded emissions reporting. Japan has a carbon tax (Tax for Climate Change Mitigation) and is developing an emissions trading system, which may qualify for a partial Art. 9 deduction. CBAMCheck generates documentation for both the embedded emissions and the carbon price deduction pathway. 12 deliverables. €299 one-time.

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

2.743
tCO₂e/t — Japan iron and steel default (Reg. 2025/2621)
Art. 9
Carbon price deduction pathway — Japan has an active carbon tax
€299
One-time — full CBAM dossier including carbon price documentation

Your CBAM compliance timeline

1
Register as authorised CBAM declarant
Art. 5. Required before importing any CBAM goods from Japan.
2
Map your steel CN codes
Specialty steels fall under Chapter 72 and headings 7301–7326. GHG: CO₂ only (direct emissions, Annex II).
3
Determine embedded emissions
Use Japan default (2.743 tCO₂e/t) or request actual data from your Japanese mill. Art. 7 + Annex IV.
4
Document the Japanese carbon price for Art. 9 deduction
Japan’s Tax for Climate Change Mitigation may qualify for a reduction in certificates. Collect carbon price documentation certified by an independent person. Art. 9(1) and (2).
5
Purchase CBAM certificates quarterly
Art. 22(2). Certificates net of any Art. 9 deduction and free allocation adjustment (Art. 31).
6
Submit annual CBAM declaration by 30 September
First declaration: 30 September 2027 for calendar year 2026. Art. 6.

Three mistakes that inflate your CBAM cost or create compliance risk

MISTAKE 1 — IGNORING ART. 9

Not claiming the Japanese carbon price deduction

Japan has an active carbon tax. Failing to document and claim this under Art. 9 means paying for CBAM certificates that could have been partially offset. CBAMCheck generates the carbon price documentation template.

MISTAKE 2 — COMMODITY TREATMENT

Applying commodity steel default values to specialty grades

Japanese steel exports to the EU are predominantly high-value grades. Actual emissions per tonne from a modern Japanese mill may differ significantly from the country default. Art. 7(2)(a) allows actual emissions.

MISTAKE 3 — DISPROPORTIONATE COST

Paying enterprise platform fees for niche import volumes

CBAM compliance for specialty steel imports does not require an enterprise SaaS platform. A €299 one-time dossier covers the documentation requirement without a recurring subscription.

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 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
Multi-company supportNoVia Professional PackYes

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

Importing steel from Japan, South Korea, Taiwan and other Asian mills? Managing CBAM across multiple specialty suppliers?

The Professional Pack covers 70 generations. One dossier per supplier, per origin, per steel grade if needed. Carbon price documentation for Art. 9 included in every dossier.

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

Does Japan have a carbon price I can deduct?
Japan has a carbon tax (Tax for Climate Change Mitigation). Whether it qualifies for an Art. 9 deduction depends on whether the price has been effectively paid on the embedded emissions in your goods. CBAMCheck generates the carbon price documentation template that your Japanese supplier can complete for Art. 9 certification.
Are all Japanese steel products covered by CBAM?
All iron and steel products under Chapter 72, CN 2601 12 00 (agglomerated iron ores), and headings 7301 through 7326 are in scope of Annex I. This includes flat products, long products, tubes, fasteners and structures. Ferrous scrap (7204) is excluded.
Can actual emissions lower my CBAM cost for Japanese steel?
Yes. Under Art. 7(2)(a) and Annex IV, you may use verified actual emissions from the producing installation instead of default values. Japanese mills with advanced efficiency may have lower emissions than the 2.743 country default.
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.

Japanese steel, Japanese carbon price deduction. Document both in one dossier.

12 deliverables. Japan default 2.743 tCO₂e/t. Art. 9 carbon price documentation pre-structured. Supplier letter in English. €299.

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