First CBAM declaration for 2026 imports is due 30 September 2027. Is your supplier data ready? →
CBAMWorks

Playbook

What to do when a supplier won't send CBAM data

A practical playbook for EU importers whose non-EU suppliers aren't responding to CBAM data requests. Default values, mark-up and a nudge framework.

Updated 2026-10-19

Warehouse with shelving

The honest baseline

Under CBAM you can report with default values plus the yearly mark-up:

  • +10 % for 2026
  • +20 % for 2027
  • +30 % for 2028 and after

Defaults are set deliberately high, and the mark-up grows every year. If your supplier is in a cluster with high emissions (older BF/BOF route, coal-heavy grid, no PFC data for aluminium) the default plus mark-up could be noticeably more than real data — but not always.

A nudge sequence that actually works

  1. Pick the right channel. English email loses to a 1-minute WhatsApp message in their language.
  2. Explain the stakes in one sentence. “Without this, we have to use EU defaults, which cost N € more per tonne.”
  3. Offer the template. Suppliers who sell to several EU buyers can share one data pack with all of them. Many engage once they realise the data has reuse value.
  4. Set a short, specific deadline. Not “soon” — a date, with a reminder sent two days before.
  5. Escalate to a short call. A 15-minute call usually fixes it. Have someone who can take questions in Hindi or Gujarati on hand.

When to give up and use defaults

  • When the supplier is clearly a smaller fraction of your tonnes than the cost of chasing them. The de-minimis still applies at your end (50 tonnes per importer per year, combined across scope).
  • When the supplier can’t produce a monitoring plan at all. Verification won’t pass later anyway.