CBAM Compliance for Saudi Exporters: What’s Required in 2026
- Sep, 13, 2026
The EU’s Carbon Border Adjustment Mechanism (CBAM) — Regulation (EU) 2023/956 — entered its definitive enforcement period on 1 January 2026. For Saudi manufacturers and exporters of CBAM-covered goods, this is no longer a future concern: it is an active compliance requirement with a fixed reporting timeline and real financial consequences for non-compliance.
2026
The Carbon Price at the EU Border
CBAM requires importers of certain carbon-intensive goods into the EU to report the embedded greenhouse gas emissions of those goods, and — from the definitive period onward — to purchase CBAM certificates corresponding to the carbon price that would have been paid had the goods been produced under EU carbon pricing rules. It is, in effect, a border carbon price levied on imports from jurisdictions without equivalent carbon pricing.
Which Saudi Exports Fall Under CBAM?
CBAM currently applies to six goods categories. Saudi exporters in steel, cement, aluminium, and fertiliser production with significant EU trade exposure fall directly within scope.
“The cost of not verifying emissions is usually far higher than the cost of getting a proper GHG inventory and third-party verification done.”CBAM Default Value Analysis · EU Commission · 2025
What Happens Without Verified Emissions Data?
Default Values Are Typically 2–3× Higher Than Real Emissions
If a Saudi producer does not supply verified actual embedded emissions data, the EU importer must use default values set by the European Commission. These defaults are typically two to three times higher than real production emissions for well-run facilities.
For a mid-sized steel exporter producing roughly 10,000 tonnes annually, the gap between default and verified actual values can exceed EUR 1 million per year in CBAM certificate costs — based on industry estimates of default-value premiums. In practice, this means the cost of not verifying emissions is usually far higher than the cost of getting a proper GHG inventory and third-party verification done. Exporters relying on default-value treatment are also structurally less competitive than suppliers with verified data, as EU buyers absorb the higher certificate cost and negotiate pricing accordingly.
What Does CBAM-Defensible Verification Actually Require?
Facility-level GHG inventory
Covering direct and relevant indirect emissions, aligned with the CBAM implementing regulation methodology — which draws on IPCC Tier 1–3 approaches and EU ETS-equivalent boundaries. This is the foundation everything else rests on.
Product-level embedded carbon calculation
Cradle-to-gate for most CBAM goods, following the specific calculation rules set out in EU Implementing Regulation 2023/1773. General-purpose carbon accounting is not automatically CBAM-compliant — the methodology is specific and must be applied correctly at the product boundary level.
Third-party verification by an accredited body
Verification must be conducted by a body accredited to ISO 17029 and ISO 14065, confirming that the emissions data is accurate and the methodology was correctly applied. Note: ISO 14064 certification alone does not satisfy CBAM on its own — but an existing ISO 14064-aligned inventory puts you in a substantially stronger starting position.
Documentation retention for audit
CBAM declarations and supporting evidence must be retained for audit purposes. EU importers are required to reference verifiable records in their quarterly and annual declarations — which means Saudi producers must maintain records in a format that supports the importer’s filing obligations.
Dates Saudi Exporters Must Track
What Saudi Exporters Should Do Now
Identify CBAM exposure
Confirm which CN codes in your export mix fall under the six covered categories. This is the prerequisite for all subsequent steps — scope before methodology.
Build or update the facility GHG inventory
Establish actual, defensible emissions data at the facility level — aligned with CBAM implementing regulation methodology. Relying on default values is not a cost-neutral position; it is an active competitive disadvantage.
Engage third-party verification early
Verification capacity in the region is limited and lead times are growing. With the September 2027 declaration deadline approaching, early engagement is a practical necessity, not a nice-to-have.
Align internal reporting with EU methodology
General-purpose sustainability reporting is not automatically CBAM-compliant. The calculation rules under Regulation 2023/1773 are specific — product-level boundaries, IPCC tier alignment, and embedded emissions scope must all be correctly applied.
How VerdeVista Supports CBAM Compliance
Facility-Level GHG Inventory Development
ISO 14064-1 aligned GHG inventories, structured for CBAM compliance from the outset — covering Scopes 1 and 2 with relevant Scope 3 embedded emissions at the product boundary.
ISO 14064 Verification Readiness
Pre-verification gap analysis and documentation preparation, ensuring your inventory is ready for third-party verification by an ISO 17029 / ISO 14065 accredited body.
EU Methodology Alignment
Translating ISO-aligned GHG work into CBAM-specific product-level embedded carbon calculations under EU Implementing Regulation 2023/1773 — closing the gap between general sustainability reporting and regulatory compliance.
Declaration Support & Documentation
Structuring the underlying data and supporting records to enable EU importers to file accurate quarterly and annual CBAM declarations — and to withstand audit scrutiny from EU authorities.
Request a CBAM compliance consultation
VerdeVista supports Saudi manufacturers and exporters with GHG inventory development, ISO 14064 verification readiness, and CBAM compliance advisory — drawing on ISO 14064-1/2/3, ISO 14067, and IPCC Tier 1–3 methodologies aligned with EU CBAM requirements.
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