EU CBAM Starts Charging Soon: A Readiness Check for Korean Exporters
Key summary
The EU CBAM enters full implementation in 2026. This piece covers why suppliers that don't export directly to the EU are still affected through their client companies, a 4-step self-check for figuring out which preparation stage you're at, an assumption-based example for estimating cost, and three things to do right now plus reporting tips.
Signals from abroad · June 19, 2026 · 4 min read
Contents (7)
What if you had to pay a "carbon toll" at the border when you ship a product into the EU? A structure in which the more carbon is embedded in the product, the more expensive the toll — that is exactly what CBAM (the Carbon Border Adjustment Mechanism) is. From 2023 the stage was "just keep a record of how much you would owe," but from 2026 the stage in which you actually bear the cost begins. And this toll is not only a problem for companies that export to the EU directly.
The conclusion first
CBAM is a 'carbon toll' applied to imports into the EU in proportion to their carbon emissions. With the definitive phase beginning in 2026, importers in scope must purchase and surrender certificates on top of reporting emissions. Even if you do not export directly, if you supply a large corporate customer you are already within range of a 'request for carbon data'. The first step in responding is knowing which stage of preparation your company is at.
At a glance: what CBAM is
CBAM is a scheme that makes high-carbon products imported into the EU bear a carbon cost equivalent to that borne by goods produced inside the EU. Its purpose is to prevent carbon leakage — to stop companies moving production outside the bloc to escape regulation, and to level the competitive playing field inside and outside the EU.
| Item | Detail |
|---|---|
| Goods in scope | Six: steel, aluminium, cement, fertiliser, hydrogen and electricity |
| Reach of the impact | Both direct exports and indirect exports via a large corporate customer |
| Cost burden | The obligation to purchase and surrender certificates starts in 2026 |
| Expansion timetable | Free allocation is reduced in phases, with paid coverage expanding through to 2034 |
Currently in direct scope (steel, aluminium, cement, fertiliser, hydrogen, electricity)
The definitive phase in which the obligation to purchase and surrender certificates begins
When the reduction of free allocation is complete and paid coverage expands
Why "we do not export to the EU, so we are fine" is wrong
Many people at mid-sized manufacturers say this: "We only supply domestic large corporates, so CBAM is not our business." It sounds right, and it is wrong. The reason is simple.
Your large corporate customer pays the same toll. Which leaves the large corporate with little choice but to prefer suppliers whose toll comes out low. In fact, formal requests from the procurement teams of major large corporates asking suppliers for carbon emissions data have recently begun. In other words, mid-sized and small manufacturers doing business with large corporates are already indirectly within CBAM's sphere of influence.
Which stage is your company at: a four-stage self-check
Diagnose your internal state of readiness against the four stages below. Starting a CBAM response requires stage 3 as a minimum, but most mid-sized manufacturers are currently sitting at stage 1 or 2. Closing that gap within six to twelve months is the task in front of whoever is responsible.
Impact · Four stages of CBAM readiness — stage 3 is the minimum starting line for a response
Stage 1 · The concept is not shared
RiskA state in which the concept of carbon emissions has not yet been shared inside the company
- The "Carbon? What is that?" stage
- Discussion of a response has not even begun
Stage 2 · Company-wide figures only
RiskCompany-wide emissions are known, based on fuel and electricity consumption
- "How much carbon per tonne of product A" cannot be calculated
- Most mid-sized manufacturers sit here
Stage 3 · Per-product figures
No changeThe carbon footprint of the main product families has been calculated
- The minimum starting line for a CBAM response
- You can answer a customer's data request
Stage 4 · External verification complete
GainThird-party verification to ISO 14067 or the GHG Protocol has been completed
- You can respond to customer and EU requirements immediately
- The most trusted position a supplier can hold
How much does it cost: an assumption-based example
Let us run a rough simulation on an assumed company size. The figures below are an assumption-based example to aid understanding, and the actual cost varies considerably with the goods, the emissions, the EU carbon price and the exchange rate. They are not any real company's values.
Assume a fictional semiconductor materials supplier, "Company A," as follows.
| Item | Assumed value |
|---|---|
| Annual revenue | KRW 300 billion |
| Direct exports to the EU | KRW 30 billion (10% of revenue) |
| Indirectly linked via large corporate customers | KRW 90 billion (30%) |
| EU-linked production volume | 12,000 tonnes a year |
Company A's revenue structure — share exposed to CBAM (assumption-based example)
On these assumptions, the expected annual CBAM cost works out at roughly 12,000 tonnes × 1.5 tonnes of excess carbon × an EU carbon price of EUR 100 × an exchange rate of KRW 1,450 ≈ about KRW 2.6 billion a year.
Assumption-based example — estimated annual cost in the early phase
Not an actual value; changes with the assumptions
Estimate for the later phase as free allocation is cut back (around 2034)
An example of the rise as paid coverage expands
If you have no feel for how large a sum KRW 2.6 billion is, you can measure it against these — the combined annual salaries of 30 employees, or 10-15% of annual operating profit, or the size of a year's R&D budget. More serious still is that as the EU phases out free allocation, this amount grows larger in the later years.
Three things to do right now
Roadmap · Three actions to start on now
Ask your customer formally
Within 2 weeks
Send a formal email to the procurement and ESG teams at your main large corporate customers asking "if you have supply chain carbon emissions management requirements, by when and in what format do we have to submit data?" That single email decides your timing and your priorities.
Set up an internal task force
Within 1 month
A small task force led by the environment and safety team, with one person each from production, procurement and finance. The first item on the agenda is "what data do we already have" — more of it than you would expect is already scattered across the departments.
Start reviewing renewable energy procurement
Within 2 months
The most powerful way to cut CBAM costs is to lower the carbon in the electricity your process uses. In other words, renewable energy procurement = lower CBAM costs. Roughly comparing the domestic options — green premium, RECs, PPAs and so on — lets you move fast at the next step.
- 1
Action 1
Within 2 weeksAsk your customer formally
Send a formal email to the procurement and ESG teams at your main large corporate customers asking "if you have supply chain carbon emissions management requirements, by when and in what format do we have to submit data?" That single email decides your timing and your priorities.
- 2
Action 2
Within 1 monthSet up an internal task force
A small task force led by the environment and safety team, with one person each from production, procurement and finance. The first item on the agenda is "what data do we already have" — more of it than you would expect is already scattered across the departments.
- 3
Action 3
Within 2 monthsStart reviewing renewable energy procurement
The most powerful way to cut CBAM costs is to lower the carbon in the electricity your process uses. In other words, renewable energy procurement = lower CBAM costs. Roughly comparing the domestic options — green premium, RECs, PPAs and so on — lets you move fast at the next step.
How to put it to your management
When someone on the ground takes this up to management, starting with technical terms loses their attention in the first paragraph. The expressions to avoid and the ones that hold attention split like this.
Expressions to avoid
Risk"CBAM, the EU's Carbon Border Adjustment Mechanism, applies to Scope 1 and 2 emissions in that…"
- Starting with technical terms → attention lost in the first paragraph
- What has to be decided is not visible
Expressions that hold attention
Gain"From 2026 a 'carbon toll' is attached to exports to the EU. Between our direct exports and our supply to large corporates, we are significantly exposed, and acting now can reduce the burden."
- 'How much do we have to pay'
- 'By when do we have to do what'
There are only two things at the heart of it — "how much do we have to pay," and "by when do we have to do what."
In summary
CBAM is an easy subject to put off as "not my problem yet." But the toll is already at the door, and a large customer's data request reaches the supplier first. What you have to do now is not grand — check where your company sits among the four stages, send your customer one email, and gather your internal data in one place. That preparation decides how fast you can respond when customer requirements arrive in earnest.
- [Source: Carbon Border Adjustment Mechanism (EU Commission, DG TAXUD)]
- [Source: Korea Energy Agency — K-RE100 and renewable energy procurement options guide]
Note: The figures in the text relating to costs, revenue, emissions and payback (the roughly KRW 2.6 billion example and so on) are assumption-based examples to aid understanding, and are not any real company's values. CBAM rules are subject to change in their implementing regulations, the goods covered and the timetable, so when acting in practice please check the latest official texts from the European Commission and the guidance of the competent domestic authorities.

OpenEnergy Editorial Team
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