What to ask your Chinese supplier for CBAM: the letter, in English and Chinese

Ask in writing for eight things: the plant where each product is made, its 2026 records kept with the EU method, the steel plants it buys from, registration as an operator in the CBAM Registry, a verifier accredited in the EU, the verified report shared with you before summer 2027, an estimate now and a contact person. What your supplier calls its “CBAM certificate” is that verified emissions report: the certificates are what you buy. The letter, in English and Chinese, is below, ready to copy.

The letter, ready to send

What a supplier’s “CBAM certificate” is

CBAM certificates are bought by the authorised declarant, the EU importer, on the Commission’s common platform from 1 February 2027, and surrendered with its declaration. A Chinese factory has no CBAM certificates and cannot sell them.

What a factory can have, and what it almost always means by its certificate, is an emissions report for its installation, verified by a verifier accredited for CBAM by an EU national accreditation body. With that report you declare its actual emissions instead of the default value. The factory shares it with you through the CBAM Registry, or sends it to you if it is not registered.

None of these replaces it:

• A pre-verification statement from the transitional period, on 2025 data and with limited assurance. Good practice, but not the verification of 2026 data the declaration needs.
• A Chinese (CNAS) accreditation alone. The verifier has to be accredited for CBAM by an EU accreditation body (Delegated Regulation (EU) 2025/2551). A Chinese accreditation can help it get there, but does not replace it.
• A carbon footprint study or a consultant’s certificate. CBAM has its own calculation method and its own verification.

The eight asks, and why

1. The installation. Verification is per installation: one report per plant and per year. If your supplier is a trading company, the figure is that of the factory that makes the goods, and that is who you need to reach. In China, the identifier is the unified social credit code.
2. The 2026 records. The calculation method is in Implementing Regulation (EU) 2025/2547: a monitoring plan and an emissions report for the year. What was not measured or kept in 2026 cannot be verified in 2027.
3. Its steel plants. The steel the factory buys is a precursor and carries most of the CO₂. If the steel plant has no verified figure, that steel goes at the default value even when the factory is verified (see the next section).
4. Registration in the CBAM Registry. It is voluntary (Article 10 of Regulation (EU) 2023/956), on the O3CI portal, with EU Login. Once registered, the factory uploads its data once and shares it with all its customers; to find you it needs your EORI number. Without registration it has to send the full report to each customer.
5. Verification. The factory contracts it, and the first one includes a physical visit to the plant (Implementing Regulation (EU) 2025/2546). Verifiers started receiving CBAM accreditation around September 2026, and there will be a queue.
6. The report, shared. With a date, to leave a margin before your declaration on 30 September 2027.
7. An estimate now. It helps you negotiate 2027 prices and plan the quarterly certificate holding that starts in 2027. Ask for the factory’s own process and the steel separately.
8. A contact person. Without a name, the request gets lost between sales and quality.

Why the steel plant matters most

In a welded tube (CN 7306), almost all the CO₂ comes from the steel: in our example, of 1.7 t of CO₂ per tonne, 1.6 t come from the steel plant and only 0.1 t from the factory’s own process. So, with the certificate at €82.32 (the Q3-2026 price), the 2026 CBAM per tonne comes out as:

• Default value: about €203.
• Factory verified, steel at the default value: about €177.
• Factory and steel plant verified: about €20.

The figures are illustrative; yours, for your product and tonnes, are in the savings calculator and the CBAM cost per tonne guide. In practice: ask about the steel plants in the first letter, because the steel plant’s figure needs its own verifier too.

When to send it

• Now, in 2026. What the factory measures and keeps this year is what can be verified.
• From January 2027. Verifiers can issue the 2026 reports in the CBAM Registry.
• 1 February 2027. Certificates go on sale.
• Before summer 2027. The date we suggest in the letter for the shared report, with a margin.
• 30 September 2027. Your 2026 declaration and the surrender of certificates are due.

Send it to every supplier whose CN code is in CBAM. If you are not sure which, check them in the CN code checker.

How to check what you receive

The verification report follows a template set in Implementing Regulation (EU) 2025/2546. Check that it has:

• The verifier: accreditation number, EU national accreditation body, country, expiry and a scope that covers your goods.
• An opinion with reasonable assurance, not limited.
• The date of the site visit and the days on site.
• The installation and the year: the plant that makes your product, and 2026.
• The precursors: for each, whether it uses the default or an actual value, and if actual, who verified it.

If the supplier does not answer

It happens often: the letter reaches sales, nobody at the factory knows the method, and the answer is a consultant’s certificate. Three ways out:

• Declare at the default value and pass it into your price, knowing the mark-up rises to 20% in 2027 and 30% from 2028.
• Put it in the contract: an emissions threshold per supplier, with the CBAM above it re-invoiced. It is what large importers already do.
• Have someone work it with the factory in China, in Chinese. That is what we do at HeavyDeals: we prepare the factory’s and its steel plant’s data under the EU method for an accredited verifier to check (how it works). Send us your suppliers and we tell you, at no fee, which can have a verified figure for 2026.

Every figure and rule was checked against the sources above, on the date shown next to each; last review of this guide: 24 October 2026. The examples use illustrative figures, not today’s quotes. This is not legal or tax advice. Written with the help of AI and reviewed by the HeavyDeals team.