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China — CBAM Guide

China faces the highest default embedded emissions across Steel, Aluminium and Cement — carrying some of the largest CBAM cost exposure globally.

Iron & SteelAluminiumCement
First declaration deadline
30 Sep 2027
De minimis threshold
50 t / year
Carbon pricing
Power-sector ETS only — no deduction
EUA price Q1 2026
€75.36 / tCO₂e
CBAM phase-in 2026
2.5% of full liability
CBAM phase-in 2030
48.5% of full liability

Trade Profile

China is the world's largest producer of steel, aluminium, and cement. EU-bound exports include structural steel sections, flat-rolled products, tubes, and primary aluminium semi-fabricates. Chinese steel and aluminium default values are among the highest in IR 2025/2621, reflecting coal-intensive production. Chinese ammonia carries a default of 4.36 tCO₂e/t — the highest of any major exporting country.

Article 9 — Carbon Price Deduction

Very limited

Carbon pricing in China: China's national ETS (CN-ETS) covers the power generation sector but does not currently impose a verified, reported carbon price on steel, aluminium, or cement production.

The Chinese national ETS covers power generation only. Steel, aluminium, and cement producers do not currently pay a qualifying carbon price under Article 9 criteria. No Art. 9 deduction is available for Chinese CBAM-covered goods as of 2026. The Commission has not recognised CN-ETS as qualifying for deduction purposes.

Compliance Insight for China Exporters

Chinese producers face the highest default values of any major CBAM-affected country — steel semi-finished at 3.17 tCO₂e/t (BF-BOF) and primary aluminium at 3.00 tCO₂e/t. Producers with actual emissions below these defaults have a strong financial case for verification. The gap between default and actual can represent tens of millions of euros in certificate costs for large-volume exporters by 2030.

Verify Your Actual Emissions →

Four Steps to Compliance

1
Register in the CBAM Operators Portal
Upload installation identification data: legal name, UN/LOCODE, GPS coordinates, contact person. This enables your EU buyer's authorised declarant to access your verified data.
2
Establish a monitoring plan
Document all energy inputs, production outputs, and emission calculation methodology per the governing EU implementing regulation. This is the foundation for any verified data submission.
3
Engage an accredited verifier
Appoint a third-party verifier accredited under EN ISO/IEC 14065 by an EA-recognised National Accreditation Body. A physical site visit is required before verified data can be submitted.
4
Share verified data with your EU buyer
Provide verified specific embedded emissions to your EU buyer's authorised CBAM declarant before the September 2027 declaration deadline. Verified actual data replaces default values — typically at significantly lower cost.

Key Deadlines

2026
First full reporting year begins
CBAM Regulation fully in force
30 Sep 2027
First CBAM declaration due
Covers goods imported in 2026
2028+
Annual declarations continue
Phase-in increases each year to 2034
2034
Full CBAM liability
100% of certificates required

Calculate your exposure

Estimate your 2026–2034 CBAM certificate costs using your sector, volume, and production route.

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Country Assessment Report

Need a verified, installation-specific CBAM exposure report for China? Our Country Assessment covers default vs actual emission gaps, benchmark comparison, and a 2026–2034 cost trajectory.

Request Assessment →

Default values sourced from IR 2025/2621 (EU Commission). Net costs are illustrative — actual liability depends on verified embedded emissions, SEFA benchmark deduction, and the applicable CBAM phase-in factor. Not legal or compliance advice.