[Home](/)/[Resources](/resources)/EU CBAM for Hardware Companies EUTradeRegulation guide # EU CBAM for Hardware Companies CBAM puts a carbon price on the embedded emissions of certain imported goods entering the EU — starting with carbon-intensive raw materials like steel, aluminium, and cement, but with direct knock-on effects for hardware manufacturers who import these materials or components made from them. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Feu-cbam-hardware-exporters) At a glance Regulation (EU) 2023/956 Transitional period 2023–2025, reporting only Definitive regime From 2026, financial obligation begins Initially covered sectors Iron/steel, aluminium, cement, fertilisers, electricity, hydrogen Mechanism CBAM certificates matched to embedded emissions ## What CBAM does and why hardware companies care ### A carbon price at the border CBAM requires importers of covered goods to purchase CBAM certificates reflecting the embedded greenhouse gas emissions of those goods, mirroring the carbon cost EU producers already pay under the EU Emissions Trading System — the goal is to prevent "carbon leakage" where production simply moves outside the EU to avoid a carbon price. ### Direct exposure for raw material and component imports Hardware companies importing steel or aluminium stock, castings, or certain intermediate components made from covered materials are directly in scope even if their finished product itself is not on the initial covered-goods list. ### The scope is expected to widen CBAM began with a narrower list of carbon-intensive sectors, but the regulation anticipates extending coverage to additional downstream goods over time — hardware companies using covered materials should expect the practical reach of CBAM to grow, not shrink. ## How the phased rollout works ### Transitional period: reporting only During the transitional period, importers of covered goods must report the embedded emissions of their imports each quarter without yet paying for CBAM certificates — the purpose is to build the data and administrative infrastructure ahead of the financial phase. ### Definitive regime: certificates and financial obligation From the start of the definitive regime, importers must be registered as "authorised CBAM declarants" and annually surrender CBAM certificates matching the embedded emissions of their imports, purchased at a price linked to the EU ETS carbon price. ### Default values vs. actual emissions data Where actual verified emissions data from the foreign producer is unavailable, importers can initially rely on default emissions values set by the European Commission — but these defaults are generally set conservatively (higher), creating a cost incentive to obtain real supplier data. ## Preparing your supply chain for CBAM 01 Map your bill of materials and supply chain to identify any inputs falling within CBAM-covered categories — steel, aluminium, and related intermediate goods are the most common exposure points for hardware companies. 02 Establish a process for collecting embedded-emissions data from non-EU suppliers of covered materials, since supplier-specific data is generally more favorable than default values. 03 Register as an authorised CBAM declarant ahead of the definitive regime’s deadlines if you import covered goods directly, or confirm your customs agent/importer of record is handling this on your behalf. 04 Model the cost impact of CBAM certificate purchases into your sourcing and pricing decisions — this is a genuine, recurring cost input, not a one-time compliance fee. 05 Monitor scope expansion announcements, since additional downstream product categories are expected to be added to CBAM coverage over time. ## Frequently asked questions ### Does CBAM apply to finished electronics or hardware products directly? The initial CBAM sectors focus on carbon-intensive raw materials and basic goods — iron, steel, aluminium, cement, fertilisers, hydrogen, and electricity — rather than finished consumer electronics. However, hardware companies importing covered raw materials, castings, or certain intermediate components are directly exposed, and scope expansion over time may bring more downstream goods into coverage. ### What is the difference between the transitional period and the definitive regime? During the transitional period, importers only had to report embedded emissions data quarterly with no financial obligation. Under the definitive regime, importers must register as authorised CBAM declarants and purchase CBAM certificates matching the embedded emissions of covered imports on an annual basis. ### Can I use my supplier’s actual emissions data instead of EU default values? Yes, and it is generally advisable to do so — default values set by the European Commission tend to be conservative (higher), which increases certificate costs. Obtaining verified, supplier-specific embedded-emissions data is usually more favorable once your supply chain can provide it. ### Who is responsible for CBAM compliance — me or my customs broker? The importer of record (or, once the definitive regime applies, the authorised CBAM declarant) bears legal responsibility for CBAM reporting and certificate obligations. A customs broker or freight forwarder may handle the mechanics on your behalf, but the underlying compliance obligation and cost exposure sit with the importing company. **Disclaimer:** This page is an educational resource only and does not constitute legal or trade advice. CBAM implementation dates, covered-sector scope, and certificate pricing mechanisms continue to develop — verify current requirements against official EU CBAM guidance and consult qualified trade counsel before making sourcing decisions. 🇪🇺 CE Marking roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇪🇺 CE Marking compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. 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