The first annual declaration under the European Union’s Carbon Border Adjustment Mechanism (CBAM) is due on 30 September 2027. However, that declaration covers goods imported during 2026. The definitive regime began on 1 January 2026, making preparation a current business task rather than a future filing exercise.
The European Commission stresses three priorities: identify covered imports, decide how embedded emissions will be reported, and coordinate the people who will supply and verify the information. For Malaysian exporters, this translates into a practical need to align production records with EU customer requirements.
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Start with the goods, not the industry label
CBAM covers selected goods in cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Product coverage must be checked against the relevant customs classifications and the legislation, rather than inferred from a company’s broad industry description.
A useful starting point is a product-and-customer register. List the products supplied to the EU, their customs classifications, the customer or importer, and the production installation. Use that register to organise a scope review and record any classification questions for specialist advice.
Understand the threshold and whose threshold it is
A single annual mass-based threshold of 50 tonnes generally exempts importers whose covered imports do not exceed that quantity. Electricity and hydrogen are exceptions and do not benefit from this mass-based exemption.
For a Malaysian supplier, the important point is that the threshold concerns the EU importer’s imports, not just one supplier’s sales. Do not conclude that a customer is exempt because an individual order is small. Ask the customer to confirm its position and the information it needs.
Choose the emissions-data approach early
Where actual values are used, verification is required. Applicable calculation rules must still be checked for the specific goods; electricity, in particular, has separate conditions.
The practical decision should be agreed with the customer. Assess the availability of production information, the effort needed to prepare a defensible calculation, verification arrangements and the commercial implications of the reporting approach. Do not assume that an internal carbon estimate is automatically suitable for CBAM.
Build a coordinated preparation plan
- Confirm scope: check product classifications and identify the relevant EU declarant.
- Agree the reporting basis: clarify whether actual or applicable default values will be used.
- Identify data owners: assign responsibility for production records, calculations and customer communication.
- Plan verification: where actual values are intended, identify a suitably accredited verifier and agree a timetable.
- Schedule delivery: establish internal review and customer handover dates before the filing deadline.
These are recommended management steps, not a substitute for the legal requirements. Their purpose is to turn separate customer requests into one controlled internal process.
Know the milestones
- Certificate sales begin on 1 February 2027.
- The first declaration and certificate surrender are due by 30 September 2027 for 2026 imports.
- Quarterly certificate-holding obligations begin in 2027.
Make readiness a supply-chain priority
For Malaysian exporters, the most useful first action is a structured discussion with EU customers. Confirm covered products, reporting expectations and evidence requirements, then translate the answers into an internal work plan. The annual deadline is the endpoint; reliable product information, clear ownership and coordinated verification are the preparation behind it.
Prepare your business for CBAM
CBAM preparation starts with understanding how the requirements affect your products, your EU customers and your internal processes. If your business exports to the EU, now is the time to identify information gaps and establish a clear preparation plan.
At Bernard Business Consulting Sdn. Bhd., we welcome the opportunity to discuss your business’s CBAM readiness, the challenges you face and the next steps to consider. Contact us today to explore how we can support your preparation and help you move forward with greater clarity.
