If your factory exports iron and steel, aluminium, cement, fertilisers, hydrogen or electricity to the European Union, you need to understand CBAM. The Carbon Border Adjustment Mechanism (CBAM) is becoming increasingly important for EU export compliance . Since 2026, CBAM has entered its definitive phase.This makes accurate production and emissions data an important part of EU export compliance.

For Indian manufacturers, CBAM requires more than understanding carbon emissions. Businesses need reliable records covering production, energy consumption, raw materials, manufacturing processes and embedded emissions.

This guide, prepared by UA Consultants, explains the key records Indian manufacturers should organise to improve their CBAM compliance and EU export readiness.

What Is CBAM in Simple Words?

CBAM (Carbon Border Adjustment Mechanism) is an EU regulation designed to address carbon leakage by applying a carbon price to certain carbon-intensive imported goods.

The current CBAM sectors include iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. Indian manufacturers exporting these products may need to provide emissions-related information to their EU customers to support CBAM reporting.

Why CBAM Data Readiness Matters for Indian Exporters

Manufacturers already maintain records for production, customs, GST and quality requirements. CBAM adds another layer involving energy use, emissions and production-process data.

If these records are scattered across departments or incomplete, responding to EU buyer requests can become difficult. Organising CBAM data in advance can improve accuracy and reduce last-minute compliance work.

10 Records Indian Manufacturers Must Organise Before EU Export

1. Product-Wise Production Data

Maintain records of the quantity of each CBAM-covered product manufactured during the relevant period. Where possible, separate data by product type or production process to connect production volumes with the emissions associated with exported goods.

2. Bill of Materials and Raw Material Details

Keep a Bill of Materials (BOM) listing major raw materials and precursor materials used in production. Include relevant supplier and quantity details to support emissions calculations and provide better traceability of your manufacturing inputs.

3. Energy Consumption Records

Record electricity and fuel consumption used during manufacturing, including sources such as natural gas, coal or grid electricity. Regular energy records provide important information for calculating emissions associated with CBAM-covered products.

4. Emission Factors

Maintain the emission factors used for fuels, electricity and relevant materials, along with their sources. This helps keep CBAM emissions calculations consistent, transparent and easier to review when information is requested.

5. Direct Emissions Data

Keep records of emissions generated directly by your manufacturing installation, including relevant fuel combustion and industrial process emissions. Where possible, connect the data to the specific production process or installation.

6. Purchased Electricity Data

For grid electricity, maintain electricity bills, consumption records and applicable emission-factor information. These records can support emissions calculations and provide the underlying data needed for CBAM reporting where applicable.

7. Installation-Level Process Information

Document the production processes, technologies and equipment used at the manufacturing installation. This helps ensure that emissions data is linked to the correct production activity rather than being treated only as a company-wide figure.

8. Supplier and Precursor Material Data

If you use precursor or semi-finished materials, collect relevant supplier emissions information where available. Supplier data can improve the accuracy of CBAM calculations and help provide reliable information to your EU customers.

9. Export and Customs Documentation

Keep HS/CN codes, invoices, packing lists and shipping documents properly organised. Consistent product descriptions and classification can help determine whether exported goods fall within the applicable CBAM categories.

10. Audit Trail and Supporting Records

Maintain calculation sheets, production records, energy bills, supplier information and emission-factor references together. A clear audit trail makes it easier to verify data, identify inconsistencies and respond to questions from EU customers.

How Indian Manufacturers Can Start Getting CBAM Ready

Getting CBAM-ready does not have to happen all at once. Start by assigning one person to coordinate CBAM data, such as someone from the export, compliance or sustainability team. Then create a simple system for storing production, energy, emissions and supplier records.

It is also important to contact raw material and precursor suppliers early. Their emissions information may take time to collect, so early communication can make the overall CBAM compliance process easier.

Manufacturers that organise their data before EU buyers request it can respond more confidently and reduce last-minute compliance problems.

Frequently Asked Questions (FAQs)

1. Which Indian industries are currently covered by CBAM?

CBAM currently covers iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. Indian manufacturers exporting covered goods to the EU should assess whether their products fall within the applicable CBAM product categories.

2. Does CBAM apply to small and medium manufacturers?

CBAM obligations depend mainly on the goods being imported and the applicable EU rules, not simply on the size of the manufacturer. Indian SMEs exporting covered products should therefore assess the requirements applicable to their products and shipments.

3. What if actual emissions data is not available?

Where actual emissions data is unavailable, the applicable CBAM rules may require the use of default values or other prescribed calculation methods. This can affect the emissions reported and, consequently, the carbon cost for the EU importer.

4. How often should CBAM records be updated?

Production, energy and emissions records should be maintained regularly rather than collected only when an EU buyer requests them. Monthly or periodic updates can make CBAM reporting more accurate and easier to manage.

Final Thoughts

CBAM is changing how Indian manufacturers prepare for the European market. The best approach is to treat CBAM data readiness as an ongoing compliance process, not a last-minute paperwork exercise.

By organising production data, raw material information, energy records, emissions calculations and supporting documents, manufacturers can make it easier for their EU customers to meet CBAM reporting requirements.

If you need support with CBAM compliance, emissions data preparation or EU export requirements, UA Consultants can help Indian manufacturers understand the requirements and organise their compliance process more effectively.