Signals from abroad

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 more carbon a product contains, the more expensive the toll — CBAM is a 'toll levied on carbon'.

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.

ItemDetail
Goods in scopeSix: steel, aluminium, cement, fertiliser, hydrogen and electricity
Reach of the impactBoth direct exports and indirect exports via a large corporate customer
Cost burdenThe obligation to purchase and surrender certificates starts in 2026
Expansion timetableFree allocation is reduced in phases, with paid coverage expanding through to 2034
6goods

Currently in direct scope (steel, aluminium, cement, fertiliser, hydrogen, electricity)

2026

The definitive phase in which the obligation to purchase and surrender certificates begins

2034

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.

Large corporates prefer 'suppliers whose toll comes out low' — which is why suppliers are within CBAM's reach too.

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

Risk

A 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

Risk

Company-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 change

The 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

Gain

Third-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.

ItemAssumed value
Annual revenueKRW 300 billion
Direct exports to the EUKRW 30 billion (10% of revenue)
Indirectly linked via large corporate customersKRW 90 billion (30%)
EU-linked production volume12,000 tonnes a year

Company A's revenue structure — share exposed to CBAM (assumption-based example)

Direct exports to the EU10%
Indirectly linked via large corporate customers30%
Everything else (domestic and so on)60%

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.

about 2.6 billionKRW/year

Assumption-based example — estimated annual cost in the early phase

Not an actual value; changes with the assumptions

about 5-6 billionKRW/year

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

  1. 1

    Action 1

    Within 2 weeks

    Ask 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. 2

    Action 2

    Within 1 month

    Set 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. 3

    Action 3

    Within 2 months

    Start 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.

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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