CBAM for Brazilian Exporters: Embedded Emissions, Verification and Costs

Since 1 January 2026, the EU's Carbon Border Adjustment Mechanism (CBAM) has been in its definitive phase: EU importers of iron and steel, aluminium, cement, fertilisers, hydrogen and electricity pay for the greenhouse gases embedded in those goods by surrendering CBAM certificates. The importer pays, but the exporter's data sets the bill. A Brazilian plant that provides verified, installation-level emissions data lets its European customers avoid the Commission's default values, which carry a rising mark-up.

What applies since 1 January 2026

• Who pays: authorised CBAM declarants in the EU, in Ireland authorised by the EPA. Importers of up to 50 tonnes of CBAM goods a year are exempt; the threshold does not apply to hydrogen or electricity.
• When: certificates go on sale in February 2027, and the first annual declaration, covering 2026 imports, is due by 30 September 2027.
• Price: for 2026 imports, the average EU ETS auction price of the quarter of import: €75.36 for Q1, €75.28 for Q2 and €82.32 for Q3 2026. From 2027, prices are published weekly.
• Free allocation: the number of certificates is reduced to reflect the free allowances EU producers still receive under the EU ETS, which end in 2034 under current law.

Embedded emissions: what to measure

CBAM counts the specific embedded emissions of each good, in tonnes of CO2e per tonne of product, per installation. For iron and steel, aluminium and hydrogen, only direct emissions count; for cement and fertilisers, indirect emissions from the electricity consumed count as well. Emissions of relevant precursors, such as pig iron or clinker, are added to the good's total.

Actual emissions only count if they are monitored under the EU methodology and verified by an accredited verifier. For goods without verified data, importers use the default values the Commission publishes per country and product. Under Implementing Regulation (EU) 2025/2621, they carry a mark-up of 10% for 2026, 20% for 2027 and 30% from 2028, with 1% for fertilisers.

What your EU customers will ask for

• Specific embedded emissions per good and installation, calculated under the CBAM methodology.
• The production route, the precursors used and their emissions.
• For cement and fertilisers, electricity consumption and the related indirect emissions.
• A verification report from an accredited verifier for each year.
• Evidence of any carbon price effectively paid in Brazil.

Operators outside the EU can share their data with importers directly through the O3CI portal of the CBAM Registry.

CBAM and Brazil's SBCE

Article 9 of the CBAM Regulation lets importers deduct a carbon price effectively paid in the country of origin. Brazil's regulated market, the SBCE created by Law 15.042/2024, is still being implemented and does not yet produce a carbon price an exporter could document for that purpose. It is worth tracking: a documented price paid under the SBCE could reduce what EU customers owe in the future.

Steps to take now

1. Map the products and CN codes you sell into the EU, and to which customers.
2. Measure embedded emissions per installation and product, including precursors.
3. Engage an accredited verifier early; verification capacity is limited.
4. Agree with each EU customer what data you will share, in which format and by when.
5. Compare, per product, your customer's cost under default values and under your verified data. That gap is a sales argument.

Common mistakes

• Sending company-wide averages instead of installation- and product-level figures.
• Sharing data that no accredited verifier has checked.
• Leaving out precursor emissions, such as purchased pig iron or clinker.
• Assuming the importer will sort it out: without your data, they pay marked-up defaults and may look for another supplier.

How Carbonova helps

Carbonova CarbonOS connects plant data from SCADA, ERP and meters, calculates embedded emissions per installation and product and keeps the data lineage behind each figure, so verifiers and EU customers can trace every number. See our Proof Engine and compliance hub. Carbonova is a software provider; verification opinions come from accredited verifiers.

To see your embedded-emissions data organised for your EU customers, book a demo.

Do Brazilian exporters pay CBAM?

Not directly. The EU importer, as an authorised CBAM declarant, buys and surrenders the certificates. The exporter's verified emissions data determines how many certificates are needed, which is why EU buyers ask their suppliers for it.

What if a Brazilian supplier cannot provide verified data?

The importer must use the Commission's default values for that product and country, with a mark-up of 10% for 2026, 20% for 2027 and 30% from 2028 (1% for fertilisers).

Sources

• Regulation (EU) 2023/956 (EUR-Lex)
• Regulation (EU) 2025/2083 (EUR-Lex)
• Implementing Regulation (EU) 2025/2621 (EUR-Lex)
• European Commission: price of CBAM certificates

Last reviewed: 22 October 2026