EU CBAM: What Exporting Companies Must Do to Comply and Continue Accessing the European Market
1. What is CBAM and why should exporting companies be concerned?
The Carbon Border Adjustment Mechanism (CBAM) is a carbon pricing mechanism introduced by the European Union (EU). It is designed to assess the CO₂ emissions embedded in imported goods, ensuring fair competition between products manufactured within the EU and those imported from outside the EU.
CBAM is implemented in two phases:
Transitional Phase (1 October 2023 – 31 December 2025)
- Importers are required to report greenhouse gas (GHG) emissions embedded in products.
- No carbon payment is required during this phase.
Full Implementation Phase (from 1 January 2026)
- EU importers must purchase CBAM certificates corresponding to the CO₂ emissions embedded in imported goods.
- Annual emissions declarations and submission of corresponding carbon certificates will be required.
CBAM currently applies to sectors with high carbon intensity, including:
- Iron and steel
- Aluminium
- Cement
- Fertilizers
- Electricity
- Hydrogen
In practice, companies in the EU supply chain will require manufacturers in Vietnam and other exporting countries to provide verified emissions data so that they can comply with CBAM obligations.
If emissions data is not available, the EU may apply default emissions values, which are typically much higher. This may significantly increase import costs and reduce the competitiveness of exported products.
VINTECOM International Supports Vietnamese Companies to Comply with CBAM for Export to the EU
Based on the latest EU regulations and practical implementation experience in global supply chains, VINTECOM International provides guidance and consulting services to help companies implement CBAM compliance through the following seven key steps.
Step 1: Determine Whether the Product Falls Within the Scope of CBAM
Companies must determine:
- The HS Code of the product
- Whether the sector is covered under CBAM
- The composition of raw materials and semi-finished products
Key aspects to analyze include:
- main product
- input raw materials
- intermediate products (precursors)
Step 2: Establish a Carbon Data Management System
CBAM requires companies to establish a system for managing emissions data throughout the production process.
VINTECOM International provides guidance for companies to establish:
1. MRV System (Monitoring – Reporting – Verification)
Including:
- energy data collection
- CO₂ emissions measurement
- emissions calculation for products
2. Emissions Scope
- Direct emissions (Scope 1)
- Indirect emissions from electricity (Scope 2)
3. Required Data Collection
- electricity consumption
- fuel consumption
- raw material usage
- production output
Step 3: Calculate the Product Carbon Footprint
This is the most critical step in CBAM compliance.
VINTECOM International will guide companies to:
- define the system boundary of the production process
- collect energy and raw material data
- calculate emissions according to EU CBAM methodology
The emissions to be calculated include:
- Direct emissions (CO₂ from furnaces or fuel combustion)
- Process emissions (chemical reactions)
- Indirect emissions from electricity
The final result must determine:
tCO₂ per ton of product
Step 4: Establish the CBAM Technical File for the Product
The EU requires transparent and traceable emissions documentation.
VINTECOM International assists clients in establishing CBAM documentation including:
- production process description
- process flow diagram
- energy consumption data
- emissions calculation methodology
- carbon intensity results
- verification records
This documentation is similar to a Technical File required under many EU regulations.
Step 5: Verification of Emissions Data
To ensure credibility, emissions data must:
- undergo internal review
- be independently verified by VINTECOM International experts
- be assessed by independent organizations where required
The CBAM evaluation process includes:
- documentation review
- on-site assessment
- verification of calculation methodology
Step 6: Provide CBAM Data to EU Customers
EU importers require emissions data for:
- quarterly CBAM reports during the transitional period
- annual CBAM declarations starting from 2026
Companies must provide the following information to the VINTECOM expert team:
- export volume
- embedded emissions
- carbon price paid in the country of production (if applicable)
If a carbon tax has already been applied in the exporting country, the cost may be deducted from CBAM obligations.
Step 7: Improve Emissions Performance to Maintain Competitiveness
CBAM will significantly increase pressure on carbon costs.
VINTECOM International provides consulting support to help companies:
- optimize energy consumption
- adopt renewable energy
- improve manufacturing technology
- optimize logistics
The objective is to:
reduce the carbon intensity of products
Major Risks if Companies Are Not Prepared for CBAM
Companies that fail to prepare for CBAM may face serious risks, including:
- EU customers suspending imports
- application of high default emission values
- loss of competitive advantage
- delays in EU customs clearance
VINTECOM International's Role in Supporting CBAM Implementation
With extensive experience in implementing international standards across global FDI supply chains, VINTECOM International supports companies in building comprehensive CBAM compliance systems, including:
1. CBAM Training for Exporting Companies
- EU CBAM regulations
- embedded emissions calculation methods
- MRV system implementation
2. Carbon Inventory System Consulting
- establishment of emissions data management systems
- CO₂ calculation methodologies aligned with EU requirements
- development of CBAM documentation
3. Emissions Data Assessment and Verification
- evaluation of carbon inventory systems
- on-site assessments
- verification of CBAM documentation for EU customers
4. Support for FDI Companies in EU Supply Chains
Industries include:
- steel
- aluminium
- electronics
- automotive supply chains
Conclusion
CBAM is not only an environmental regulation but is rapidly becoming a new trade barrier introduced by the European Union.
Companies wishing to maintain exports to the EU must:
- establish emissions inventory systems
- ensure transparent carbon data
- comply with CBAM reporting requirements
Early preparation will help companies reduce carbon costs and maintain competitiveness in global supply chains.
Organizations and enterprises seeking consulting and certification support for the EU Carbon Border Adjustment Mechanism (CBAM) in the supply chain of goods exported to the European market, please contact:
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📶📶📶 Further information, Please contact us as below:
☎ VINTECOM International Office in Ha Noi City: 16th Floor - Green Stars City, 234 Pham Van Dong, Bac Tu Liem District, Ha Noi City. Hotline 094-886-5288/ (024) 730-588-58
☎ VINTECOM International Office in Ho Chi Minh City: GH3 - Glory Height Vinhome Grand Park - Thu Duc City, Ho Chi Minh City. Hotline 0938-083-998/ (028) 7300-7588
VINTECOM INTERNATIONAL MANAGEMENT CONSULTANCY COMPANY
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Address: 16th Floor - Green Stars City
234 Pham Van Dong Street, Phu Dien Ward, Hanoi City
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88 Phuoc Thien Street, Long Binh Ward, Ho Chi Minh City
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Hotline: 0938 083 998
Email : office-hcm@vintecom.com.vn
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