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Russia — CBAM Guide

Iron & Steel, Aluminium and Fertilisers are Russia's main CBAM sectors — EU trade volumes have declined significantly since 2022.

Iron & SteelAluminiumFertilisers
First declaration deadline
30 Sep 2027
De minimis threshold
50 t / year
Carbon pricing
No qualifying scheme
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

Russia is a major global producer of steel, primary aluminium (RUSAL), and nitrogen fertilisers (EuroChem, PhosAgro). EU import volumes of Russian CBAM-covered goods have declined substantially since 2022. Residual trade flows and the possibility of future normalisation mean CBAM obligations remain relevant for Russian producers with EU buyers.

Article 9 — Carbon Price Deduction

No deduction

Carbon pricing in Russia: Russia does not operate a domestic carbon pricing mechanism applicable to CBAM-covered goods at a level or structure that would qualify for Article 9.

No qualifying carbon price applies to Russian production of CBAM-covered goods. Russia has a token carbon levy that does not meet Article 9 criteria. Full CBAM certificate costs apply to any verified embedded emissions above the SEFA benchmark.

Compliance Insight for Russia Exporters

Russian aluminium (RUSAL) benefits from significant hydropower-based electricity, which reduces embedded direct emissions. The default (2.16 tCO₂e/t primary aluminium) may overstate actual emissions for hydro-powered smelters — verified actual data could reduce certificate costs materially. Note that indirect electricity emissions are excluded from CBAM scope for aluminium.

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.

Free Sector Calculator →

Country Assessment Report

Need a verified, installation-specific CBAM exposure report for Russia? 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.