When an EU buyer asks for a CBAM pack: what the factory sends, who files (2026)

Bottom line:

From 1 January 2026 the CBAM definitive regime applies. The party who files and buys certificates is the EU importer or their customs representative, not the mainland plant and not the Hong Kong storefront company.
What the factory prepares is embedded-emissions data from the installation: whether this consignment’s code is listed, which production route, output, direct emissions (steel and aluminium are direct-led in the definitive period), precursors, and any carbon price already paid. Certificate prices follow EU allowance auctions. There is no fixed “euros per tonne” you can lock into a quote.
Without acceptable data the importer falls back to default values, which usually mean more certificates and a lower purchase price for you. You may describe monitoring progress. You may not say “clearance included” or “we already paid the EU carbon tax.” Rules are on the Commission’s definitive-regime page.

When the inquiry says “please send CBAM data,” three replies are common: attach an ISO 14064, say “we export through a Hong Kong company so there is no carbon tax,” or quote an all-in “we will clear it” price. All three mis-state who is responsible.

The buyer needs which installation made the goods, on which route, with how much verifiable embedded emissions, so they can file in the EU. How aluminium plants talk to EU project buyers is in the Foshan aluminium whitepaper. Who stands as importer is in DDP/DAP.

1. Who files: the 50-tonne line sits on the importer, not on your annual capacity

The Commission states that the definitive regime starts on 1 January 2026. EU importers of these goods, or their indirect customs representatives, apply for authorised declarant status. The current official explanation is that an importer above 50 tonnes of CBAM goods a year buys certificates, declares embedded emissions and surrenders the matching number.

When the buyer asks “have you paid it,” answer: emissions occur at our installation; we prepare the data; certificates follow your import volume and are filed by you or your customs representative. Writing “we already paid the carbon tariff” in chat is a false statement on their behalf.

Fifty tonnes is also not the factory’s yearly output. A plant that ships 5,000 tonnes of aluminium bar may sell to twenty EU importers. Whether anyone crosses the line is each importer’s own yearly total. Deciding “we ship under 50 tonnes so we skip the pack” fails at the first large account.

October 2023 to the end of 2025 was the transitional period: quarterly reports, no certificates. From 2026 importers buy certificates and declare annually. Exact cut-off dates follow the Commission’s current notices; have the buyer’s broker confirm them before you ship. What the factory prepares early is installation monitoring, not an EU tax invoice.

2. Is this consignment listed: match the code, not the Chinese product name

The definitive period covers cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. The list is nailed to CN codes. Saying “aluminium windows / screws / steel structures” does not auto-include or auto-exempt the shipment.

Settle this first	Who answers	If the answer is wrong
Does this consignment’s CN / HS sit in Annex I?	Documents + the buyer’s broker	Promising certificates out of scope — or saying “finished goods never count” when they do
Sold to an EU importer, or sold as a precursor to someone who then makes CBAM goods?	Sales	Precursors still need data; “we do not export to the EU” is not enough
Definitive period: direct only, or electricity as well?	EHS using the sector guide	Steel and aluminium are direct-led in the definitive period (sintered ore and other exceptions follow the guide). Copying the transitional split confuses the file
Production route (primary electrolysis / scrap remelt; BF-BOF / EAF)	Production	A wrong route skews verification and default comparison

The first inquiry reply asks the buyer’s target code and yearly tonne estimate, then sets how deep the pack needs to go. Do not quote an “all-in CBAM certification fee” first. Codes follow Annex I as updated; sector detail is in the Commission’s iron-and-steel and aluminium guides.

3. Seven items the factory sends — not a homemade euros-per-tonne rate

Importers and verifiers need numbers they can keep calculating, not a homemade price list. Certificate prices follow EU ETS allowance auctions (a quarterly average in 2026, later rhythm per the Commission). You cannot lock a euro figure into the unit price.

A pack the buyer can pass downstream should at least name:

Installation name, address and the operator’s legal name; if that is not the Alibaba.com contracting company, write the relationship (Hong Kong company signs, mainland installation produces).
Reporting period: the installation monitors the calendar year of production; how importers cite it is in the Commission’s guide for non-EU operators.
CN codes in scope, goods category and output on that route.
Production route and the source and quantity of precursors (alumina, scrap, pig iron, scrap steel).
Direct-emission boundary, method, activity data and factor sources; list indirect electricity only where that sector’s definitive rules require it.
Evidence of a carbon price already paid where the goods were produced — or a written “none.” Do not relabel some other domestic tax as a carbon price.
Verification status: not started / in progress / issued by a verifier on the EU-recognised path. Actual-value verification often includes a first-year site visit; details follow the current verification rules.

The Hong Kong company and the mainland installation must tell one story across contract, customs and bill of lading. How titles line up is in four flows. A pack that says “Hong Kong zero-emission trading company” while the pots sit in Nanhai cannot be declared. At destination that becomes another week of cargo held.

4. Without actual values, the buyer pays more

Importers may use your actual values or, without acceptable data, fall back to Commission default values. Defaults are built conservatively. The same tonne usually needs more certificates. Buyers are costing landed goods, not collecting green posters.

“Monitoring is not finished; use defaults” can be an internal bridge. It cannot be a showcase claim. The detail page must not say “CBAM compliant, buyer need not declare.” Using defaults does not remove the declaration duty.

Actual values stand when the boundary is clear, power and materials can be traced, and a verifier recognises the route. Renaming a lab CO₂-concentration sheet or an ISO 14001 certificate as a “CBAM report” will not survive verification, but the chat promise is already out. What may enter an attribute field is the same rule as agent-readable fields: if it cannot be checked, it is not a fact you can keep.

Default values are a Commission Excel file. Open the current workbook before quoting any “euros per tonne.” Do not recycle a WeChat estimate.

5. What you may write on the showcase and in chat

Buyers will look for certification, carbon and CBAM. A false claim is more dangerous than an empty field.

Where	You may write	Do not write
Attributes	Alloy / grade, route, installation location, emissions data (yes / in progress)	CBAM certified; carbon tariff included; EU ETS already paid
Detail page	Monitoring-boundary summary, verification status, named EHS or documents contact	Clearance guaranteed; our defaults beat every peer
Quote annex	Pack contents, missing items, an internal catch-up sketch (not an official deadline)	A guessed euro tax baked into the unit price
Chat	The declarant is the importer; we supply installation data; your broker models default-value cost	Hong Kong company so tax-free; membership fees include carbon compliance

Alibaba.com membership buys a storefront file. It has nothing to do with CBAM. Membership still goes to ALIBABA.COM HONG KONG LIMITED — see who receives the fee. Do not shorten a lead time while you wait for a verification report; see lead-time promises.

6. If the pack is incomplete, stop — do not promise and backfill

Code not in Annex I: write that this consignment is not prepared as CBAM goods in the current period. Do not invent a report to look professional.
In scope, monitoring incomplete: say how far actual values have gone, which fields you can send now, and that default-value risk is the importer’s to model. Do not lock a “guaranteed pass” price.
The buyer wants DDP “including carbon tax”: first name who is importer and who is authorised declarant. Taking DDP does not mint EU declarant status. Terms sit in DDP/DAP.
Goods already sailed and the port wants emissions data: freeze that batch’s output, power and precursor documents on a timeline. Do not rename the route after the fact.
Anyone selling “we will obtain EU certificates and guarantee clearance”: check whether they sit on the authorised-declarant or recognised-verifier path the Commission describes. Corpable does not run that filing and does not collect those fees.

Implementing rules and default tables will move. Before you ship or quote, open the Commission’s definitive-regime page and let the buyer’s broker calculate against the current file. A tax amount in WeChat is not a contract number.

Questions teams actually ask

Does CBAM mean a Chinese factory pays a carbon tariff to the EU?

The factory does not buy the certificates. From 1 January 2026, EU importers or their customs representatives who exceed the current official threshold of 50 tonnes of CBAM goods a year need authorised declarant status, report embedded emissions and surrender certificates. The plant, as installation operator, prepares production and emissions data that can be checked.

We extrude aluminium / process steel. Must we always send a pack?

Match the consignment’s CN code against cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Do not decide from a Chinese product name. Some windows and steel articles are listed; some further-downstream goods are not in the current scope. Use the Commission’s current list, not “a peer said we must file.”

We have no verifier yet. Can we answer with default values?

You may tell the buyer that actual monitoring is still underway and their broker should model defaults. Do not describe defaults as “we are already compliant.” Defaults usually make the importer buy more certificates, and that cost comes back as price pressure. Verifier and site-visit rules follow current Commission guidance.

May the showcase say “CBAM certified / carbon tariff included”?

No. The factory is not the authorised declarant and cannot surrender certificates for the buyer. The showcase may state installation address, production route and whether emissions data can be provided. Writing “we guarantee clearance” claims you already performed the importer’s legal duty.

The contract seller is a Hong Kong company; the line is in the mainland. Whose name goes on the pack?

Report the installation where the emissions occur. A Hong Kong seller does not create a Hong Kong installation with zero emissions. Name the plant, its address, its operator, and the link to the contracting company. How contract, customs and bill-of-lading titles line up is in the four-flows guide.

Will Corpable file CBAM or guarantee clearance?

No. Corpable explains the Alibaba.com path and how to answer the inquiry. We do not file in the EU, sell certificates, or promise clearance or a tax amount. Verification goes through an EU-recognised verifier. Rules and default tables follow the Commission Taxation and Customs Union pages as updated.