CBAM 2026: how exporters collect emissions data, and where AI helps.
Serhat Altunoğlu
· 4 min read
If you sell steel, aluminium or cement to the European Union, the emails from your customers have changed this year. They no longer ask only about price and delivery. They ask how much was emitted in making the product, how it was calculated and who verified it.
In this post I explain what CBAM changed in 2026, what data your customer will ask for, and where an AI agent helps you collect it.
What changed in 2026?
During the 2023–2025 transition, companies only reported. From 1 January 2026 the mechanism became a real cost:
- Authorised declarant: only importers with authorised CBAM declarant status can bring covered goods into the EU.
- 50-tonne threshold: importers bringing in less than 50 tonnes of covered goods a year are exempt. This simplification came with Regulation (EU) 2025/2083. Your large buyers are not exempt.
- Certificates: the importer buys and surrenders CBAM certificates matching the embedded emissions. Certificate sales start on 1 February 2027.
- First annual declaration: the declaration covering 2026 imports is due by 30 September 2027.
- Default values: without real, verified data, the Commission's default values apply, with a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028.
If you don't measure, you pay the default. And the default is usually higher than your real value.
What data will your customer ask for?
The importer pays, but the calculation rests on the producer's data. Expect requests for:
- A description of the installation and production route (for example electric arc furnace or blast furnace).
- A product list by customs (CN) code, with production volumes.
- Direct emissions: fuel use and process emissions.
- Indirect emissions: electricity consumed and its source.
- Precursors: inputs such as crude steel or ferro-alloys, with emissions data from those suppliers.
- Proof of any carbon price paid in the country of origin.
- A report from a verifier accredited in the EU. Real data replaces defaults only once verified.
Where does an AI agent help?
Most of this work is collecting scattered data, matching it and chasing what is missing. That is exactly what an agent does well. The calculation method and the declaration, however, are a matter of responsibility.
- A monthly fuel and electricity table from meters, invoices and the ERP
- Matching products to CN codes and flagging gaps
- Data requests and follow-up with precursor suppliers
- A summary comparing real data with default values
- The document pack for the verifier
- Calculation method and system boundaries
- Choice of verifier and the verification process
- Which data goes to the customer, under which contract
- Emission reduction investments
The situation in Türkiye
Türkiye is one of the EU's largest suppliers of CBAM goods. Secondary regulations for the emissions trading system under its Climate Law were published in August 2026; the start of the pilot phase is not yet fixed. A carbon price paid in Türkiye could later be deducted from the CBAM obligation. Collecting emissions data once, properly and traceably, serves both systems.
Four steps to get started
- 1Clarify the scopeWhich of your products are covered, and which customers buy more than 50 tonnes a year?
- 2Map your dataWhich meter, invoice or spreadsheet holds fuel, electricity, production and input data?
- 3Calculate a past monthThe agent drafts, the team checks. Compare the result with the default value.
- 4Talk to a verifier earlyAgree on the method and document structure before year end.
This work sits in the sourcing and production steps of the end-to-end AI automation loop. For the wider regulatory picture, see the AI regulation 2026 guide.
This post is general information, not legal advice. For your own products, rely on the official texts and expert advice.
In our first conversation, we will find the biggest wait in your supply chain and where the first agent should go.
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