Practical Guide · Carbon Border Adjustment Mechanism · Exporters

CBAM Romania —
Guide for Exporters

Since October 2023 the CBAM transition period began, and from 2026 European importers of steel, aluminium, cement, fertilisers, electricity and hydrogen will pay carbon certificates for embedded emissions. This guide covers everything you need to know about CBAM's impact and obligations.

CBAM 2026Carbon Border TaxSteel RomaniaAluminiumEmbedded Carbon
Current status: The CBAM transition period (Oct. 2023 – Dec. 2025) requires EU importers to report embedded emissions quarterly without purchasing certificates. From 1 January 2026, importers must purchase CBAM certificates (in EUR/tonne CO₂) for emissions exceeding the carbon price already paid in the country of origin.

What is CBAM and how does it work?

The Carbon Border Adjustment Mechanism (CBAM) is a European Green Deal instrument designed to prevent carbon leakage. Without CBAM, European producers paying for their emissions through the EU ETS would be disadvantaged against competitors from countries without a carbon price, creating an incentive to shift polluting production outside the EU.

In practice: a European importer bringing steel from Turkey or Ukraine must purchase CBAM certificates corresponding to the CO₂ emissions embedded in that steel's production. The certificate price tracks the weekly average EU ETS allowance price (currently €60–80/tonne CO₂). If the Turkish producer already paid a carbon price domestically, that amount is deducted.

Products covered by CBAM

SectorTypical productsCN codes (examples)
Steel and ironRolled products, beams, pipes, wire7206–7229, 7301–7326
AluminiumIngots, profiles, foils, alloys7601–7616
CementClinker, Portland cement, aluminous cement2507, 2523
FertilisersAmmonia, nitric acid, urea, DAP, MAP2808, 2814, 3102–3105
ElectricityElectric energy imported from outside the EU2716
HydrogenPure hydrogen, hydrogen mixtures2804

CBAM Timeline — Key Dates

PeriodWhat happens
Oct. 2023 – Dec. 2025Transition period: EU importers report embedded emissions quarterly, no certificate purchase required.
1 Jan. 2026Full system: importers must be authorised as CBAM declarants and purchase certificates.
1 Feb. 2027Centralised CBAM certificate platform opens — declarants can purchase certificates for 2026 emissions.
30 Sept. 2027Updated deadline (Omnibus package, Oct. 2025): first annual CBAM declaration for products imported in 2026, with certificate surrender (original deadline was 31 May 2027).
October 2025 update (Omnibus package): The European Commission simplified CBAM rules — the de minimis threshold rose to 50 tonnes/year, the quarterly minimum certificate holding requirement dropped from 80% to 50%, and the annual declaration deadline moved from 31 May to 30 September. Full details in our CBAM Calendar 2026-2027 guide.

How to calculate embedded carbon

CBAM distinguishes two types of embedded emissions: direct emissions (from the production process, equivalent to producer's Scope 1) and indirect emissions (from electricity consumed in production, equivalent to Scope 2 — included for aluminium, not for cement). Three calculation options exist:

  1. Actual installation data — Producer calculates installation-specific emissions per EU methodology and communicates them to the importer via a verified declaration. Preferred method.
  2. Country default values — European Commission publishes default emission values per tonne of product for each third country and sector.
  3. EU default values — If no country-specific values exist, EU default values plus 120% apply. Penalising option that discourages use of actual data.

Frequently asked questions about CBAM

Does CBAM affect Romanian exporters or only EU importers?

Directly, CBAM is an obligation of EU importers — companies bringing products from outside the EU into the European market. Romanian producers selling in the EU market do not pay CBAM certificates. Indirectly, CBAM improves the competitiveness of Romanian products (which already pay EU ETS) relative to imports from countries without a carbon price.

Is ISO 14067 accepted for CBAM emission calculations?

ISO 14067 is methodologically compatible with CBAM requirements, as both target emissions from the production process. However, CBAM has specific additional requirements (e.g. separating direct vs. indirect emissions), so an ISO 14067 study must be adapted. CarbonDRI can deliver calculations compatible with both requirements simultaneously.

What is the link between CBAM and my company's Scope 3?

If you purchase CBAM raw materials (steel, aluminium, cement) from outside the EU, embedded emissions become part of Scope 3 Category 1 (purchased goods) of your carbon footprint. Data collected for CBAM can be directly reused in Scope 3 calculations, reducing reporting effort. Read our Scope 3 guide.

What penalties apply if a EU importer does not submit the CBAM declaration?

The penalty is €100 per unsurrendered CBAM certificate (amount indexed to inflation), uncapped. Unauthorised importers from 2026 will no longer be permitted to import CBAM products into the EU.

Can Romanian companies benefit from CBAM competitiveness?

Yes. Romanian producers in CBAM sectors (steel, aluminium, cement) who already participate in EU ETS benefit from CBAM because their non-EU competitors now face an equivalent cost. This levels the playing field and supports investment in low-carbon production in Romania.

Need embedded emission calculations for CBAM?

CarbonDRI calculates installation-specific emissions per Regulation (EU) 2023/1773, compatible with ISO 14067. We deliver documentation for communication with European importers and CBAM certification.

Request CBAM Emission Calculation →

See also: CBAM Importers Guide · ISO 14067 Guide · Scope 3 Guide · CFP Service