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Less than 43 days have passed since the first declaration! EU carbon tariffs increase across the board, causing export companies’ carbon costs to rise sharply

2026年是欧盟碳关税正式落地实施的首年,相关监管规则近期迎来密集调整,不仅双重申报截止日期接连临近,更出台了扩围监管品类、严打转口避税等多项收紧举措,国内钢铁、铝、建材等多个出口欧盟的企业需尽快完成碳数据合规准备,避免因申报逾期或数据不合规产生数十万元级别的额外支出。

For foreign trade-related companies exporting steel, aluminum, building materials and other categories, please note that the European Union has recently officially finalized new carbon tariff regulations, and the deadline for double declarations is coming one after another. If relevant preparations are not made in time, you will directly face the risk of overpaying huge carbon fees.
At present, there are still many factories that are completely unaware of the relevant rule changes and only respond urgently when overseas customers demand relevant data. In serious cases, unnecessary losses of hundreds of thousands of yuan may even occur.

One or two hard declaration gates
There are only 43 days left for the first pass

2026 is the first year that the EU carbon tariff is officially implemented. Relevant companies in the six major export categories have two time nodes that must not be missed: The first step is to submit quarterly carbon emission monitoring data on July 31. Although this reporting operation is completed by the EU purchaser, the core emission data must be provided by the domestic production factory. If it cannot provide its own real measured data, the EU will
Directly applying the industry’s highest emission default value to calculate carbon costs, the carbon fees that companies need to pay will directly increase a lot; the second step is to complete the full-year formal declaration on September 30, and complete the 2026 full-year carbon data must be submitted at the end of September 2027. If companies have not yet established a carbon emissions statistical ledger, the subsequent data collection and third-party verification processes will be in a hurry, and it is very easy to report overtime violations.

EU Carbon Tariff Declaration Process Instructions

2. The EU suddenly increases the weight
Three major changes directly affect domestic export business

The European Council finalized the carbon tariff strengthening plan on June 12, and the rules are comprehensively tightened. It is expected to be effective early next year with a high probability.
The first change is that downstream processed products must also be included in carbon tariff control: currently, the EU carbon tariff only controls six types of raw materials: steel, aluminum, cement, fertilizer, electricity, and hydrogen. After the new regulations are implemented, all deep-processed steel and aluminum products will be included in the scope of supervision, and a large number of related processing plants will have new reporting obligations; the second change is to completely block the way for third-country re-exports to avoid carbon tariffs. Previously, many companies
Semi-finished products are shipped to Vietnam and Malaysia for simple processing and then sent to the EU to avoid carbon costs. The new version of the anti-circumvention rules will strictly inspect transit processing. Through cross-border data exchange verification, the risk of transit tax avoidance has increased significantly. The third change is the readjustment of cross-border electricity carbon emission accounting standards. The calculation rules for carbon emissions generated by electricity production have been updated, and the accounting logic of high-energy-consuming factories must be reorganized.

Schematic diagram of the expansion of EU carbon tariff control categories

3. Export enterprises calculate carbon data
4 core points must be kept in mind

The European Union has officially updated its carbon emission accounting standards, and accounting errors will directly lead to the invalidation of the declaration.
First of all, the functional units must be determined, that is, unified calculation units, such as per ton of steel and per square meter of aluminum plates, and the standards must be confirmed with overseas customers in advance; secondly, the accounting scope must be full, including emissions from in-house production, emissions from purchased electricity, and carbon embodied in upstream raw materials, and no items can be left out.
; Third, multi-product factories must have fixed allocation rules. If a production line produces multiple products, they must have a unified set of allocation methods, which cannot be changed at will throughout the year; fourth, equipment must be calibrated regularly and records kept, energy consumption measuring instruments must be calibrated on time, and all data ledgers must be kept intact for verification.

4. Enterprises should do these things immediately
Avoiding high carbon costs

Multiple policy pressures are superimposed. Waiting and watching means increasing export costs in vain. Enterprises must take action as early as possible: first, they must organize the annual water, electricity and fuel consumption documents, calculate the true carbon emissions of products, and issue actual measured data; secondly, they must dock
Third-party agencies must complete carbon data verification and obtain an officially recognized verification report; third, they must check whether their products fall into the expanded downstream categories and plan low-carbon transformation in advance; fourth, they must re-evaluate the overseas transit processing model to avoid the risk of penalties brought by anti-circumvention review.
The sooner you complete the carbon data compliance verification, you can use your own true low-emission values to declare and save a lot of carbon tariff expenses.

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