On 1 January 2026 the European Union’s Carbon Border Adjustment Mechanism (CBAM) entered its definitive phase, ending the transitional reporting period that ran from 2023. For Thai manufacturers that sell into Europe — particularly steel, aluminium and cement producers — CBAM is no longer a paperwork exercise. It now carries a real cost, measured in the embedded carbon of every tonne shipped.
- What the CBAM definitive phase changes
- Why this matters for Thai exporters
- How embedded emissions are calculated — and why defaults hurt you
- What Thai exporters should do now
- The documentation and language gap
- Where CBAM and your SET disclosure meet
- Frequently asked questions
- Turn CBAM readiness into a commercial edge
What the CBAM definitive phase changes
During the transitional period, EU importers only had to report the emissions embedded in covered goods. From 2026 they must also pay for them by surrendering CBAM certificates priced against the EU Emissions Trading System. The obligation sits with the EU importer — the “authorised CBAM declarant” — but the data those importers need, the verified embedded emissions of each product, has to come from you, the exporter.
The core obligations now: importers bringing more than 50 tonnes of in-scope goods into the EU each year must hold authorised CBAM declarant status, file an annual carbon border declaration of verified embedded emissions, and surrender matching certificates. The first declaration and certificate surrender falls due on 30 September 2027 for 2026 imports, and every 30 September thereafter. Importers below the 50-tonne threshold are now fully exempt.
On 1 January 2026 the European Union’s Carbon Border Adjustment Mechanism (CBAM) entered its definitive phase, ending the transitional reporting period that ran from 2023.
CBAM 2026 for Thai Exporters | Definitive Phase GuideWhy this matters for Thai exporters
CBAM covers six categories: iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. Kasikorn Research Center estimates the mechanism could affect around 3.8% of Thailand’s exports to the EU in 2026 — roughly 28 billion baht — with iron, steel and aluminium feeling it first. For steel, compliance is expected to add 1,300–1,500 baht per tonne, about 1.5–1.7% of product value.
The competitive risk is simple: EU buyers will factor CBAM cost into purchasing decisions. An exporter that can hand over clean, verified, well-documented embedded-emissions data makes itself the easier supplier to keep. One that cannot will see CBAM costs estimated conservatively — against it.
How embedded emissions are calculated — and why defaults hurt you
CBAM is settled on the embedded emissions of each covered product: the direct emissions from your production process and, for certain goods, relevant indirect emissions such as the electricity consumed. Where an exporter cannot supply verified, actual figures, the EU importer may have to rely on default values — and those defaults are deliberately set at conservative, high-emission levels. In effect, the absence of good data is priced against you. The exporter who can substantiate lower actual emissions with a verified dataset hands the EU buyer a cheaper compliance cost, and becomes the more attractive supplier for it.
This is why the underlying carbon accounting has to be product-level and defensible, not a plant-wide average retrofitted onto individual shipments. A credible บัญชีก๊าซเรือนกระจก (GHG) that allocates emissions to specific products is the foundation on which every CBAM declaration your customers file will rest.
What Thai exporters should do now
- Measure embedded emissions at product level. CBAM is calculated per tonne, so you need a defensible บัญชีก๊าซเรือนกระจก (GHG) covering direct and relevant indirect emissions for each covered product.
- Get the data verified. Declarations rely on verified figures; unverified or default values tend to penalise the exporter.
- Document in English to EU standards. Your customers’ declarants need the data in a form their authorities accept — accurate English documentation, consistent with your wider sustainability reporting.
- Align CBAM data with your ESG disclosure. The same emissions figures appear in your sustainability report, your CBAM submissions and your climate disclosure — they must agree.
The documentation and language gap
CBAM is, at its core, a data-and-documentation problem. Thai producers usually hold their emissions records, methodologies and verification statements in Thai, while their EU customers — and the customs authorities behind them — work in English. Any inconsistency between the Thai source data and the English submission is a compliance risk. Othello International’s ESG advisory and bilingual Thai–English translation teams help exporters build that bridge: accurate, verifiable, ISO 17100-grade English documentation that matches the underlying Thai records exactly.
Where CBAM and your SET disclosure meet
For SET-listed exporters, CBAM should not be run as a siloed export-compliance task. The embedded-emissions data you assemble for European customers is the same Scope 1 and Scope 2 data that belongs in your IFRS S1 and S2 climate disclosure and your 56-1 One Report. Treating them as one dataset, disclosed consistently in both Thai and English, removes a common source of contradiction: a plant reporting one emissions figure to an EU buyer and a different one to investors. When a rating provider or an EU customs authority can see that your numbers reconcile across every document, your disclosure — and your commercial position — is stronger for it.
Frequently asked questions
Does CBAM apply directly to Thai companies? The legal obligation to declare and surrender certificates sits with the EU importer. But because that importer needs verified embedded-emissions data for your products, the practical burden — and the competitive advantage of getting it right — falls on you as the exporter.
Which products are covered? The definitive phase covers iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. If you export any of these into the EU, you are affected; specifics of scope and thresholds should be confirmed against current EU guidance.
What happens if we don’t provide emissions data? Your EU customer falls back on default values set at conservative, high-emission levels — raising their CBAM cost and weakening your position as a supplier. Verified actual data is how you avoid that penalty.
Turn CBAM readiness into a commercial edge
CBAM is here, and the first real deadline — 30 September 2027 — is closer than it looks once a full year of verified product-level data must be assembled. Thai exporters who treat 2026 as the preparation year will be in a far stronger position than those who wait for their EU customers to ask. Othello International combines งานที่ปรึกษา ESG with disclosure-grade bilingual documentation for SET-listed exporters. Talk to our team to benchmark your CBAM readiness.
Related ESG guides
- The 56-1 One Report ESG Section: What SET-Listed Companies Must Include (2026)
- IFRS S1 and S2 in Thailand: What SET-Listed Companies Must Disclose (2026)
- SET ESG Ratings Explained (2026): Criteria, Results, and the Shift to FTSE Russell
- Scope 1, 2 & 3 GHG Inventory for Thai Companies (TGO-Aligned)
- Double Materiality Assessment, Explained for Thai Issuers
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