"We Make Semiconductors, So CBAM Isn't Our Problem" — Check Your Export Declaration First

You have probably waved this away at some point: "we make semiconductor components, so CBAM is somebody else's problem." That is only half right. CBAM does not look at your company. It looks at your product. On 14 August the European Commission released its practical guidance documents all at once, so there is now something concrete to check against.

The Commission has now written the guidance itself

On 14 August 2026 the European Commission's Directorate-General for Taxation and Customs Union (DG TAXUD) published its CBAM guidance. Until then, what circulated in Korea was mostly secondary commentary, and most of it described the transitional period. These documents are primary material for the definitive period.

Guidance No. 2 in particular is written, from its title onwards, for non-EU operators. It is effectively the only document in which the Commission itself explains the procedure by which a Korean plant hands emissions data to an EU importer.

What is covered is a product, not a sector

Annex I of the CBAM Regulation lists the covered goods by CN code. Pulling out only the parts that matter to a semiconductor supplier:

The usual misunderstanding about timing

"It's a 2027 matter, so let's prepare next year" is the most dangerous reading.

The cost is fixed in 2027, but the period it covers starts in January 2026. If you do not accumulate verifiable emissions data now, you cannot build it retroactively in 2027.

The small-volume exemption is not ours to judge

A 2025 amendment created an exemption for imports below 50 tonnes a year. But the text of the Regulation states that this 50 tonnes is calculated per importer, per calendar year, adding up all goods.

Even if we ship only 30 tonnes, if that importer takes another 40 tonnes from a different supplier, the whole volume becomes covered. In other words, whether the exemption applies cannot be worked out from our own export volume alone.

And the obligation does not sit with us

The party legally obliged to declare and pay is the EU importer. This is not a structure in which a Korean supplier acquires a direct compliance obligation.

That said, the importer cannot file a declaration without our emissions data. So from a supplier's point of view the accurate way to put it is this — not "we have an obligation", but "if we cannot supply the data, the business relationship gets difficult".

The order in which to check whether you are covered

The scope may widen

In December 2025 the Commission proposed extending CBAM to finished goods with a high iron, steel or aluminium content. Machinery, industrial equipment and fabricated metal products are among those discussed; the Council agreed its general approach in June 2026, and the responsible European Parliament committee completed its vote in July.