The EU’s Carbon Border Adjustment Mechanism entered its definitive phase on 1 January 2026. Almost all of the Thai coverage since has been about cost — the price of a certificate, the size of the bill. Very little of it has been about the sentence that will decide whether a Thai exporter’s first declaration actually survives verification.
It sits in Commission Implementing Regulation (EU) 2025/2547 of 10 December 2025, which lays down the methods for calculating emissions embedded in goods. Article 10 sets out what a non-EU installation operator must produce. Its fourth paragraph is one line long.
The operator’s emissions report shall be submitted in English.
Commission Implementing Regulation (EU) 2025/2547, Article 10(4)Not may be. Not should be, where practicable. Shall. For the first time, a carbon regime that reaches directly into a Thai factory has written the language of the deliverable into the law itself.
The line in the regulation nobody translated
To see why Article 10(4) matters, it helps to be precise about who does what. The authorised CBAM declarant is the EU importer. The operator is you — the installation in Thailand that made the goods. Under Article 10(1), where embedded emissions are calculated from actual emissions rather than default values, the operator prepares an emissions report and a summary containing at least the information in the Commission’s templates at Annex IV. Under Article 10(2) and (3), that report goes to the verifier — through the CBAM registry if the operator is registered there, and by other means if not.
So the chain is short, and it starts at your gate. Your EU customer cannot invent your emissions data, and it cannot reconstruct it from your Thai-language sustainability report. The number has to come from you, in the Commission’s format, in English, and it has to withstand an accredited verifier who will read it in English too.
This is a different species of obligation from the ones Thai sustainability teams are used to. The SEC’s 56-1 One Report is filed in Thai. Ratings agencies read whatever you happen to publish. CBAM is the first regime touching Thai industry that names the language in the operative text and attaches a customs consequence to getting it wrong.
What CBAM actually asks a Thai factory for
The content requirement is heavier than a single carbon number. The regulation requires the operator to define system boundaries per production process and attribute emissions to specific goods — Article 6 provides that specific embedded emissions “shall be determined by attributing direct and, where relevant, indirect emissions of the production processes to the specific goods in accordance with Annex III.” In practice that means assembling and documenting:
Documented methodology for the installation, transparent enough that an independent reviewer can follow it — and repeat it in later years.
Inputs, outputs and emissions mapped to each production process, not to the company as a whole.
Direct emissions, plus indirect emissions from electricity consumed, for the goods where the regulation requires them.
Embedded emissions of precursor materials, including verification reports from the installations that produced them.
Read that last item twice, because it is where most Thai supply chains will break. A steel fabricator cannot complete its own CBAM report without documentation from whoever made its input steel. Those same upstream suppliers are increasingly being asked for an EPD as well, which is a different document built from overlapping data. The obligation propagates upstream, and every hop has to arrive in a form an EU verifier will accept.
Your TGO carbon footprint is not a CBAM report
Here is the part most advisory firms will not put in writing, and we would rather you hear it from us than discover it at verification: a TGO-certified carbon footprint does not satisfy CBAM. That is not our opinion. It is the European Commission’s own guidance for installation operators outside the EU:
The scope of the CBAM is principally related to the rules of the EU ETS and therefore has differences to other methods for calculating product carbon footprints such as the “GHG Protocol” or ISO14067.
European Commission — Guidance document on CBAM implementation for installation operators outside the EUThe boundaries genuinely differ. A CFO under ISO 14064-1 measures the organisation. A CFP under ISO 14067 measures a product cradle-to-gate, and is dominated by the upstream value chain. CBAM measures something narrower and stranger than either: installation-level emissions, on a methodology derived from the EU Emissions Trading System, attributed to a defined production process, with prescribed treatment of precursors.
| TGO CFO / CFP | CBAM operator’s report | |
|---|---|---|
| Unit measured | Organisation (CFO) or product (CFP) | Production process at one installation |
| Methodology | ISO 14064-1 / ISO 14067, GHG Protocol | Derived from EU ETS rules — Annex III |
| Upstream scope | Full cradle-to-gate value chain | Prescribed precursor emissions only |
| Who verifies | TGO-registered verifier | EU-accredited verifier — Art. 8 |
| Language | Thai, or Thai and English | English — required by Art. 10(4) |
None of which makes your TGO work wasted. The metering, the activity data, the emission-factor governance, the internal discipline of having been verified before — that is the infrastructure a CBAM report is built on, and a company that has completed TGO CFO certification starts this exercise years ahead of one that has not. What it is not is a substitute deliverable. Sell yourself the overlap in data, not an equivalence of output. The same discipline applies when those numbers travel onward into your disclosure and your ratings.
One further honesty: verification only bites where actual emissions are declared. An importer may use the Commission’s default values instead, and default values do not require an accredited verifier. But defaults carry a mark-up and are, by design, unflattering — which is precisely the mechanism that pushes EU buyers to come and ask you for real, verified, English-language numbers.
How exposed is Thailand, really?
Now the corrective, because the number in wide circulation is wrong. You will have seen “฿28 billion of Thai exports at risk” quoted across Thai business media. It originates from a commercial bank research house, not from government, and it does not reconcile with Thailand’s own official trade data.
The Ministry of Commerce’s Trade Policy and Strategy Office (TPSO) puts Thai exports of CBAM-covered goods to the EU at US$354 million in 2024 — around 0.1% of total Thai exports, with Thailand ranked 33rd among the EU’s suppliers of CBAM goods. The circulating ฿28bn figure is about 2.4 times TPSO’s entire measured trade value, and it conflates exposed trade value with compliance cost. Those are different quantities by two orders of magnitude.
But do not mistake “small in aggregate” for “safe.” Thailand’s exposure is extraordinarily concentrated. On TPSO’s Jan–Oct 2025 figures, iron, steel and steel products account for 84.5% of CBAM-covered exports to the EU and aluminium for 15.5% — together, essentially all of it. Cement and fertilisers are rounding errors; electricity and hydrogen are structurally zero. And within steel, a single line dominates: fasteners — screws, bolts, nuts, washers under HS 7318 — at US$93.7 million, about a quarter of Thailand’s total CBAM exposure on their own.
That concentration is the actual story. This is not a macroeconomic problem for Thailand; it is an existential documentation problem for a specific and identifiable set of fabricators — and they are overwhelmingly in downstream finished products, exactly the goods where embedded-emissions data is hardest to assemble and where the default-value mark-up hurts most.
The 2026–27 clock
The definitive-phase timetable has moved more than once, and several summaries still circulating are simply out of date. The current position, from Regulation (EU) 2025/2083 of 8 October 2025:
Two mechanics deserve flagging. The 50-tonne de minimis introduced by the 2025 amendment is a cliff edge, not an allowance: Article 2a(2) provides that an importer who exceeds it becomes subject to all obligations “in respect of all emissions embedded in all goods imported in that calendar year” — the whole year, retroactively. The Commission’s design intent is that roughly 90% of importers fall out of scope while about 99% of embedded emissions stay in. For a Thai supplier that cuts both ways: your smallest EU customers may quietly leave the regime, while your largest ones are fully inside it and will push the data request down to you.
And the penalty is set by reference to the EU ETS excess emissions penalty — EUR 100 per tonne at its 2013 base, indexed since by the European index of consumer prices. Importing without authorisation attracts three to five times that amount, and paying it does not extinguish the surrender obligation.
English is becoming the working language of assessment
Step back from CBAM and a pattern appears that we think is under-discussed in Bangkok. Three entirely separate assessment regimes, built by different institutions for different purposes, have each arrived at English as the working language — by three different routes.
| What it reads | Where language stands | |
|---|---|---|
| CBAM · EU regulation | The operator’s emissions report, per production process | English required by law — Art. 10(4) |
| S&P Global CSA | Questionnaire plus supporting evidence | “The official language of the CSA is English”; other languages may be machine-translated, accuracy expressly disclaimed |
| FTSE Russell ESG Scores | Public disclosure only — no questionnaire | Six key research languages named; Thai is not among them |
Precision matters here, so let us be careful where others are not. FTSE Russell does not require English — its own FAQ states that it “recognizes the importance of local languages” and that provision has been made for others. What it does say is that the key languages covered are English, French, Spanish, German, Japanese and Chinese. Thai is not on that list. That is an argument about risk, not about requirement, and anyone telling you FTSE mandates English is overselling.
S&P Global is blunter, because it publishes a dedicated language policy: English is the official language of the assessment, non-English public documents are accepted but may be run through automated translation, and S&P expressly disclaims responsibility for errors in that translation. Read that as a practitioner rather than a lawyer and the implication is plain — if you do not control the English version, something else will produce one, and no one will be accountable for what it says.
Which brings the three regimes to the same practical place from three different directions. Under CBAM the English document is a legal deliverable. Under the CSA it is the difference between evidence you wrote and evidence a machine approximated. Under FTSE it is the version most likely to be legible to an analyst team whose documented language coverage does not include Thai. The English edition is the one being read — and increasingly it is being read by someone with the power to score you, price you, or stop your goods at a border.
- Establish which of your EU customers will exceed 50 tonnes — they are the ones who will need an operator’s emissions report from you.
- Map your installation by production process, not by company or by product, and reconcile that boundary against your existing CFO or CFP.
- Chase your precursor suppliers now. Their verification reports are the long pole and they sit outside your control.
- Build the emissions report and monitoring plan in English from the outset — retrofitting a translation onto a finished Thai document is how terminology drifts and verifiers raise findings.
- Treat the English edition as a regulated deliverable, not an internal courtesy: it is read by a verifier, an EU customer and a customs authority.
- Ignore the ฿28bn headline. Size your own exposure by CN code and EU customer — the national aggregate tells you nothing about your risk.
Get your carbon numbers ready for the border — and for the score
Othello builds the English-language carbon and disclosure documentation Thai exporters are now judged on: TGO CFO/CFP work, ISO 17100 certified technical translation, and the ESG advisory that connects them. Start with a review of where your English edition actually stands.
Review your CBAM exposureThe companies that will struggle in September 2027 are not the ones with high emissions. They are the ones who can prove the least about the emissions they have — in the language the person assessing them can read. See where translation risk actually bites → · Build the bilingual edition properly → · Track the full 2026–27 regulatory calendar →
Sources, all verified against primary documents on 19 August 2026: Commission Implementing Regulation (EU) 2025/2547 of 10 December 2025, Articles 6 and 10; Regulation (EU) 2025/2083 of 8 October 2025 amending Regulation (EU) 2023/956, Articles 2a, 6, 8, 20, 22 and 26 and Annex VII; Directive 2003/87/EC Article 16(3)–(4); European Commission, Guidance document on CBAM implementation for installation operators outside the EU; Trade Policy and Strategy Office, Ministry of Commerce (Thai CBAM trade data, computed from Global Trade Atlas); S&P Global, Language Policy for the Corporate Sustainability Assessment, February 2026; FTSE Russell, ESG Scores and Indices FAQ v1.5, December 2025, §1.8. Certified technical translation to ISO 17100.
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