Article 1 · Scope
Applies to imports of cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. Definitive Phase requires verified embedded emissions for every consignment.
● PPWR now, CBAM next
Start with PPWR. CBAM follows on the same supplier data.
Carbonorm covers PPWR today. CBAM, the EU's carbon border rules, is coming in Wave 2 (November 2026). The supplier data you collect for packaging feeds it directly.
● Sound familiar?
Where CBAM data gets stuck.
01
Default values are a fallback
Without installation data from your suppliers, you fall back on default values. Those are based on averages, not on your supplier's plant. Real data from each installation is what you can defend.
02
Supplier silence on emissions
One supplier sends installation data, another sends default values, a third sends nothing. Mixed evidence is hard to defend in a single declaration.
03
Two-tool fatigue
One tool for packaging, another for carbon border adjustment. Two supplier portals, two data models, two audit trails, and suppliers confused by duplicate requests.
● PPWR and CBAM, shared supplier data
Two regulations. Often the same suppliers.
Carbonorm covers PPWR today, with CBAM planned for Wave 2 (November 2026). CBAM will draw on the same supplier records you build for PPWR, so you do not collect the same evidence twice.
PPWR-only tools
Packaging only- Recyclability grading
- DoC generation
- No emissions data model
- Separate supplier portal needed for CBAM
CBAM-only tools
Emissions only- Embedded emissions tracking
- CBAM XML export
- No packaging compliance
- Separate system needed for PPWR
Carbonorm
PPWR now · CBAM planned for Nov 2026- Supplier evidence collected once, for PPWR now and CBAM from Wave 2
- Every figure traces back to its supplier document
- Data stored in the EU (Frankfurt, backup in Stockholm)
- Start with PPWR today, add CBAM when it launches
● Regulation coverage
CBAM Regulation 2023/956, article by article.
Each point below names the article it comes from, so you can check it against the regulation text.
Article 6 · CBAM declaration
Design for recycling
Authorised declarants submit a yearly CBAM declaration covering the embedded emissions in their imports and the CBAM certificates surrendered.
↳ RecyclabilityArticle 7 · Embedded emissions
Recycled content
Direct and indirect emissions per tonne of goods, calculated using approved methodologies. Actual data from installations preferred over defaults.
↳ PCRArticle 8 · Verification
Embedded emissions reported by third-country operators must be verified by an accredited verifier before inclusion in the CBAM declaration.
Article 26 · Penalties
Penalties apply to declarants who do not surrender enough CBAM certificates. Check the amounts in the current text of the regulation.
● Planned workflow
Coming in Wave 2: from supplier data to your CBAM declaration.
01
Collect
Emissions data will be requested through the same supplier links you use for PPWR. Missing fields will be flagged per supplier.
02
Reconcile
Each product will show which figures come from installation data and which rely on default values, so you know what to request.
03
Verify
The dataset will be ready to share with your accredited verifier, each figure traced to its source document.
04
Declare
Your data will be prepared for the CBAM declaration. We will confirm the export format before launch.
● PPWR today, CBAM in Wave 2
Already managing PPWR? CBAM will build on the same data.
If your packaging team already uses Carbonorm to collect supplier evidence and prepare declarations, CBAM will build on that. It is planned for Wave 2 (November 2026) and will use the same supplier links and records.
● CBAM FAQ
Common questions about CBAM compliance.
What is CBAM and who does it affect?+
The Carbon Border Adjustment Mechanism (EU Regulation 2023/956) applies to EU importers of cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. If you import any of these goods into the EU, you need to report embedded emissions and, from 2026, purchase CBAM certificates.
How do CBAM certificates work?+
The definitive phase began in January 2026. Certificates cover the embedded emissions in your imports, one certificate per tonne of CO2, priced in line with the EU ETS. The deadlines for buying and surrendering them are set in the current text of the regulation; check them on EUR-Lex before you plan around a date.
What happens if I rely on default emission values?+
During the Transitional Phase, default values from the European Commission are accepted. After the Definitive Phase, default values are progressively restricted. Verified installation-specific data reduces your certificate cost and avoids penalty surcharges.
How does Carbonorm handle both PPWR and CBAM?+
Carbonorm covers PPWR today. CBAM is planned for Wave 2 (November 2026) and will use the same supplier records and supplier links, so suppliers you already work with for packaging do not have to be onboarded again.
Can I start with PPWR and add CBAM later?+
Yes. Carbonorm covers PPWR today, and CBAM is planned for Wave 2 (November 2026). The supplier data you collect for packaging feeds it directly.
What is the penalty for non-compliance?+
Article 26 of the CBAM Regulation sets penalties for declarants who do not surrender enough CBAM certificates. The amounts are set in the current text of the regulation, so check it on EUR-Lex before you plan around a figure.
Which imports carry the highest CBAM exposure?+
It depends less on the sector than on the installation. In every covered sector, emissions per tonne vary with the production route and the energy mix. Your exposure follows from your suppliers' installations, which is why their real data matters.
Does Carbonorm generate the CBAM XML for customs brokers?+
Not yet. CBAM support is planned for Wave 2 (November 2026), and we will confirm the export format before launch. Until then, the supplier data you collect for PPWR is the base it will build on.
We manufacture outside the EU — say in Turkey — and export through an EU subsidiary. Who carries the CBAM obligation?+
The CBAM declarant is the authorised declarant on the EU side — typically your importing subsidiary or an indirect customs representative — which files the declaration and surrenders the certificates. But the embedded-emissions data has to come from the third-country installation that actually produced the goods. So the obligation splits: the EU entity is accountable to the authorities, while your non-EU plant has to measure and supply verified emissions per consignment. The practical task is building that data bridge — production data from the Turkish (or Indian, or Chinese) facility, mapped to the EU declarant's filing. CBAM support in Carbonorm is planned for Wave 2 (November 2026). The aim is to collect installation-level data from your plant and prepare it for the EU declarant and their verifier.
● CBAM Resources
Go deeper on carbon border compliance.
Regulatory deep dives, sector analyses, and practical guides for teams navigating CBAM alongside PPWR.
Deep Dive
PPWR + CBAM overlap: where packaging meets carbon
Companies importing packaged goods face both regulations simultaneously. This analysis maps the overlapping data requirements and shared compliance workflows.
Read the analysis →Guide
PPWR compliance: the complete guide
Start with packaging. The supplier data you collect for PPWR is the base you build on for CBAM.
Read the guide →CBAM · planned for November 2026
Get your supplier data in order now.
Start with PPWR today. The supplier contacts and evidence you build now are what CBAM will draw on when it arrives in Carbonorm in Wave 2 (November 2026).
● PPWR available today● EU data residency● CBAM planned for Nov 2026
PPWR Article 6
Applies from 31 May 2027
Definitive phase began
2026
Accredited verification
Art. 8
Free allocations end
2034
Certificate price tracks
ETS