Answer box
China is the biggest non-EU exporter of CBAM-scope goods into the EU — flat and long steel, aluminium, and the fasteners, tubes and extrusions made from them. Large Chinese groups (Baosteel, HBIS, Chinalco) already have the measurement infrastructure for emissions reporting; mid-size mills and downstream shops vary widely. Mandarin supplier forms are planned but not yet live; the current flow collects data via the English portal, with on-screen prompts translated for key fields.
What the Chinese supply chain looks like
- Steel: BF-BOF route dominates (~ 85% of installed capacity), with the EAF share growing. BF-BOF carries sintered-ore precursor indirect emissions, which the engine applies automatically.
- Aluminium: primary smelting is grid-electricity-intensive. For CBAM, aluminium direct emissions only — electricity is not added — so the data points are fuels, PFCs and unwrought-aluminium origin.
- Downstream: fasteners (CN 7318), fittings (CN 7307), tubes (CN 7304/7306), extrusions (CN 7604) often use coil or billet from upstream Chinese mills.
What to ask
Same CBAM data points as any supplier:
- 12 months of fuel bills by type (natural gas, coal, coke, diesel).
- Production tonnes by 8-digit CN code.
- Precursor origin and emissions (crude steel, billets, unwrought aluminium).
- Monitoring plan version — most larger Chinese mills can produce one if asked.
- Prior verification experience (several Chinese bodies run the ISO 14064 verification but that is not the same as EU CBAM accreditation).
China ETS and the “carbon price paid” deduction
China’s national ETS covers power generation and is being extended to steel, aluminium, and other industrials. If a Chinese installation has effectively paid a carbon price under the China ETS, that amount can be deducted from the EU CBAM certificate liability — subject to documentary evidence and verifier opinion.
The China ETS allowance price has historically been much lower than the EU ETS, so the deduction is partial, not full. The amount changes with the respective market prices.
State of verification in China
- Several Chinese conformity-assessment bodies are seeking EU CBAM accreditation.
- As of October 2026, EU-accredited verifiers are travelling to China for first-year site visits.
- The practical constraint is travel and audit scheduling, not willingness.
Common importer concerns
- “Our supplier won’t share operational data.” Many mid-tier Chinese mills guard operating data closely. A conversation about why the data is needed, who sees it, and what the alternative cost looks like (default + mark-up) usually unlocks it.
- “How do we handle a trading company in the middle?” The declaration needs the installation that produced the goods, not the trader. CBAMWorks invites the actual installation; the trader can watch the progress but doesn’t own the data.
Related reading
- CBAM for steel importers
- Sourcing from China
- Rule tracker · ETS linkage and verification news