Vietnam launched a pilot Emissions Trading Scheme in August 2025. Many exporters read that as good news for CBAM: pay for carbon at home, deduct it in Europe. The direction is right. The timing is not. For the next few years, the number that decides your EU margin is not a Vietnamese carbon price. It is whether your EU customer can declare your actual emissions instead of the default.
This piece builds on a detailed analysis by CBAM Guide, “CBAM Vietnam: Circumvention Monitoring and the New 2025 ETS”, which we credit with thanks. We take its figures and ask the question a managing director or CFO actually has to answer: what does this cost us, when, and what can we do about it?
Why this matters for Vietnam specifically
Steel is almost all of Vietnam’s CBAM exposure. According to Eurostat, the EU imported about 2.94 million tonnes of CBAM-covered iron and steel from Viet Nam in 2025, worth around €2.36 billion, making Vietnam the eighth-largest origin. Coated flat steel alone accounted for more than one million tonnes. Aluminium and cement are small by comparison.
The legal duty sits with the EU importer. But the importer can only lower its bill with data that comes from you. That makes CBAM a sales and finance issue in Hai Phong, Ha Tinh or Ba Ria-Vung Tau, not only a customs issue in Rotterdam.
The Vietnamese ETS: a good foundation, not yet a deduction
The pilot ETS under Decree 119/2025/ND-CP covers 34 thermal power plants, 25 iron and steel facilities and 51 cement plants. It runs to 2028, and allowances are allocated free of charge throughout the pilot.
Article 9 of the CBAM Regulation allows an EU importer to deduct a carbon price “effectively paid” in the country of origin. Three things must line up before that helps you: the Commission must adopt the implementing rules (still a draft as of October 2026), the Vietnamese price must actually be paid and documented at installation level, and your EU customer must claim it with certified evidence from you.
With free allocation, a mill only pays for a shortfall it buys. Early trading on the Hanoi exchange opened at roughly USD 5 per tonne of CO₂e. Against an EU certificate price of €82.32 for Q3 2026, even a recognised deduction would cover only a small slice for now.
The ETS is worth building on. It is not a reason to wait. What it gives you today is a monitoring discipline, not a discount.
The cost curve your customer is already calculating
Take hot-rolled flat steel (CN 7208). The EU default value for Vietnam assumes the blast furnace route, 2.350 tCO₂e per tonne. With the 10% mark-up for 2026 and after the free allocation adjustment, CBAM Guide calculates about €103 per tonne for 2026 imports. For 2030, with a 30% mark-up and much less free allocation, the same tonne costs about €193, at an unchanged certificate price.
Put that next to an average EU border value of roughly €540 per tonne for this product and the problem is clear. On default values, carbon becomes a cost line of around 19% in 2026 and over 35% in 2030. No commercial team can absorb that by negotiating harder.
Note: some earlier market summaries quoted much lower 2026 figures, a few euros per tonne. Those were based on actual emissions and older prices. On today’s defaults and today’s certificate price, the numbers are far higher. That gap is the whole point of this article.
Your production route only counts if you can prove it
Blast furnace steel (BF-BOF) carries roughly 2.0 tCO₂ per tonne. Scrap-based electric arc furnace steel (EAF) carries roughly 0.5. That is a structural advantage for EAF producers, but only if the EU importer reports verified actual values. On default values, EAF steel from Vietnam is charged as if it came from a blast furnace.
Our own illustration, using the same benchmark and price: a BF-BOF mill with verified actual data of 2.0 tCO₂ would cost its customer roughly €55 per tonne in 2026 and around €107 in 2030, about half the default figure. A verified EAF producer could land close to zero in both years. Same product code, same border, completely different landed cost.
Two Vietnamese mills can quote the same ex-works price and still sit €190 per tonne apart in the buyer’s spreadsheet by 2030. The difference is evidence.
Anti-circumvention: genuine production must be visible
Article 27 targets trade patterns with no economic reason other than avoiding CBAM. As of October 2026 the Commission has not named Vietnam as a monitored pattern. But re-rollers and coating lines that buy imported hot-rolled coil or slab carry that precursor’s emissions into the calculation, and EU importers will ask for origin and transformation records.
The penalty side is not abstract either. An authorised declarant that fails to surrender certificates pays €100 per missing certificate, indexed, and still owes the certificates. Importers do not want that risk from a supplier who cannot document what happens inside the plant.
What a Vietnamese exporter should do in the next six months
- 1.
Run the numbers per product and customer
Calculate default versus actual cost for your top EU products for 2026, 2028 and 2030. This turns CBAM from a compliance topic into a board-level margin discussion.
- 2.
Build one monitoring plan, use it twice
Align your ETS monitoring with the EU method for installation-level emissions. The same meters, records and owners should feed both the Vietnamese scheme and your CBAM data pack.
- 3.
Document precursors and origin
If you buy coil or slab, know its origin and embedded emissions. Keep transformation and value-addition records that show real manufacturing.
- 4.
Book verification early
Accredited verifiers must visit the site, and none is established in Vietnam yet. The first annual declaration is due by 30 September 2027. Capacity will be tight.
- 5.
Put it into the contract
Agree with your EU buyers which data you deliver, in what format, and how verified data is reflected in price. Evidence that saves your customer money is a commercial asset.
Know your number before your customer does
Our free CBAM Readiness Assessment shows which of your products are in scope, what default values would cost your EU buyers, and where your data gaps sit. It takes about 15 minutes and ends with a review by our CBAM team.
Start the free CBAM Readiness AssessmentFurther viewing
Vietnam Today’s discussion “The Point: CBAM 2026 - Challenges & Opportunities for Vietnam’s Businesses” gives a good local view of how Vietnamese companies are reading the definitive period. Worth watching alongside the numbers above.
Watch: CBAM 2026 for Vietnam’s businesses
A short local briefing from Vietnam Today. Use it for orientation, then check the rules and values that apply to your own goods and installation.
Sources and editorial references
- CBAM Guide, “CBAM Vietnam: Circumvention Monitoring and the New 2025 ETS” (cbamguide.com/countries/vietnam), published April 4, 2026, updated October 13, 2026; figures as of October 2026
- Regulation (EU) 2023/956, Articles 9, 26 and 27, as amended by Regulation (EU) 2025/2083 (EUR-Lex)
- Implementing Regulation (EU) 2025/2621 (default values) and 2025/2620 (benchmarks)
- Eurostat Comext, EU imports of CBAM goods from Viet Nam, 2025
- Decree 119/2025/ND-CP and International Carbon Action Partnership (ICAP), Vietnam ETS overview
- Vietnam Today, “The Point: CBAM 2026 - Challenges & Opportunities for Vietnam’s Businesses” (YouTube)
This article is our own analysis. Figures and facts from third parties are attributed to the sources listed; all rights remain with their owners. The BF-BOF and EAF scenarios are illustrative and do not replace a calculation for your installation.
Dr. Elvis Mujagić
Dr. Elvis Mujagić is Partner and Head of CBAM at wis.dom|bridge™. He advises companies on CBAM cost exposure, implementation and the link between carbon data, sourcing and financial planning.
