An EU trader or distributor asked for your CBAM data
Traders and distributors who import your goods into the EU are importers under CBAM. They usually need your data for many shipments at once.
Quick answer
An EU trader that imports your goods in its own name is the CBAM importer for them, and most traders exceed the 50-tonne threshold. Send embedded emissions per installation and product code, precursor origins and your verification plan, and agree how your data may be shared.
What this request is
A request from a trading company, stockist or distributor, often covering several products and many shipments, sometimes via a supplier portal or spreadsheet.
Why your buyer is asking
Whoever imports the goods into the EU carries the CBAM obligation. Traders import from many suppliers, so they're usually above the 50-tonne threshold that exempts small importers, and they need data for every product line.
What to send
- Data per installation and product code for the period
- A clear link between your products and the codes on their import declarations
- Precursor origin information
- Your verification plan
Be careful about
- Being asked for data on shipments that went through another trader
- Your data being passed to end customers without agreement
- Mixing data for goods made at different installations
A reply you can adapt
Please find attached our CBAM data for [period], covering [product codes] produced at [installation]. The figures are [provisional / verified].
Please use this data only for your CBAM declaration and let us know if you intend to share it with your customers.
Kind regards,
[name]
Keep a copy of everything you send. The same buyer will ask again next year, and other buyers will ask for the same data.
Got a request you're not sure about?
Send us what your buyer sent. We'll tell you what they need and what it will take, free, within one week.
Send your requestFrequently asked questions
Is a trader the CBAM importer?
If it imports the goods into the EU in its own name, yes, it carries the CBAM obligation for those goods.
Does the 50-tonne threshold apply to traders?
Yes, per importer across all CBAM goods. Most traders exceed it.
Can the trader share my data with its customers?
Agree this up front. Ask for your data to be used only for CBAM purposes.
Sources
- European Commission: CBAM definitive regime
- European Commission: CBAM communication and news (guidance, templates, default values)
- European Commission: CBAM Registry and reporting (including the module for non-EU installation operators)
This guide explains the rules in plain language. It isn't legal advice; see our disclaimer. Always check the current official texts and your buyer's instructions.