EU CBAM Officially Implemented: Chinese Enterprises Need Immediate Action

Core Timeline and Key Obligations

Vittorio Roa, head of the CBAM department at the European Commission, clearly pointed out the key milestones enterprises must adhere to:

• Immediate Action (By March 31, 2026): All EU importers must complete registration in the CBAM registry and obtain a CBAM declarant number. This is the only mandatory obligation to be completed this year (2026). Importers who fail to submit an application and obtain a number by March 31 will not be able to continue importing CBAM goods. Chinese enterprises should proactively contact and ensure their EU import partners have completed this registration.
• Data Preparation and Verification (Throughout 2026): This is a crucial "preparation year." If Chinese enterprises want their EU customers to use actual emission data for declaration (which is usually more economical than using default values), they must:
  • Develop a monitoring plan immediately: Establish a compliant monitoring system according to the new "Implementing Regulation on Embedded Emission Calculation Methods" adopted in December 2025.
  • Start monitoring and calculation: Monitor and calculate production emissions for the entire year of 2026 to generate emission reports.
  • Contact verification bodies: Find and engage third-party verification bodies that intend to and are about to obtain CBAM qualifications, in preparation for formal verification in early 2027.
• Declaration and Compliance (2027):
  • From February 2027: EU importers can start submitting CBAM annual declarations.
  • By September 30, 2027: Importers must finally submit CBAM declarations for goods imported in 2026 and complete the purchase and surrender of corresponding CBAM certificates. This means Chinese enterprises need to provide verified emission data (if choosing the actual value path) to importers by September 2027 at the latest.

Two Declaration Paths: Actual Values vs. Default Values

Enterprises face a core choice: use actual emission values or default values.

• Actual Emission Values: Must be monitored and calculated by the producer (Chinese export enterprise), and verified on-site by an independent verification body recognized by the EU, with an English verification report issued. This path may reduce tax burdens but is complex, time-consuming, and requires significant upfront investment.
• Default Values: Published by the European Commission based on the country of origin and product category. Using default values requires no verification and is simple, but the values are conservative (including a markup), which may lead to higher CBAM costs.

Important Note: Choices can be mixed. For the same product, different suppliers can adopt different paths (e.g., Supplier A uses actual values, Supplier B uses default values). However, once a path is selected, the three calculation elements—embedded emissions, free allocation adjustments, and carbon price offsets—must remain consistent (i.e., all actual values or all default values).

Action Guide for Chinese Enterprises

Based on the webinar content, the following specific suggestions are made for Chinese export enterprises:

Summary

The full implementation of EU CBAM marks a new era of green rules in global trade. For Chinese enterprises in relevant industries, challenges and opportunities coexist. Time is already tight, especially for enterprises wishing to optimize costs by providing actual emission data; preparation work in 2026 is crucial. Taking immediate action, deeply understanding the rules, and strengthening synergy across the upstream and downstream of the industrial chain are the only ways to respond to CBAM challenges and maintain and enhance export competitiveness to the EU.