The EU Carbon Border Adjustment Mechanism covers iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. For Thai exporters the operationally significant issue is not the levy rate — it is the data you must hand to your EU importer.
What "embedded emissions" means
CBAM asks for embedded emissions per unit of exported goods: direct process emissions, plus emissions from heat and electricity consumed, and for some product groups the embedded emissions of precursor materials as well.
The difficult part is that this is not an organisation-level figure. It is per product, per installation, per production route. A plant producing several product codes from a shared line needs an allocation basis it can defend.
Three things usually prepared wrong
Using a company average instead of product-level data
Many plants already hold an ISO 14064-1 organisational inventory and assume dividing by total output is sufficient. It is not — it washes out the differences between products with materially different energy intensity.
No sub-metering by process
If electricity is measured only at the point of intake, allocation to individual processes becomes a very weak estimate. Investing in sub-meters on the main production lines usually pays back faster than expected, because the same data serves both CBAM and energy cost management.
Starting too late
Verifiable data requires a historical trail. Beginning to collect in the month your importer asks means you will not have data for the period they need.
The preparation order we recommend
- Identify the CN codes you export to the EU and confirm whether they fall in CBAM scope.
- Map the boundary of each relevant production process and establish where energy is actually metered.
- Set an allocation basis for shared energy and heat, with the reasoning documented.
- Run one full calculation cycle on real data and have a verifier look at it before the live submission.
- Make data collection a standing monthly routine rather than a one-off project.
The upside
Exporters who get as far as product-level emissions figures usually find the same dataset answers other questions too: Scope 3 data requests from buyers, product carbon footprint labelling, and the disclosure requirements arriving behind them. It is worth treating as more than a compliance cost.
This article is published for general information and does not constitute professional advice on any specific matter. To discuss your organisation’s situation, please contact our team.
