Your quotation is competitive. Your delivery record is good. Then an EU buyer asks for verified embedded emissions, and the sales team sends a company sustainability presentation. That document may be perfectly genuine. It still may not answer the buyer’s CBAM question. The commercial problem is not simply whether your plant is efficient, but whether the importer can use evidence of that efficiency.
Alberto shared a Terawatt Times Institute report dated March 21, 2026 that places Vietnam’s annual CBAM exposure at around €580 million. The report raises an important question about carbon data and competitiveness. We would not use its headline as a confirmed national liability or as the starting figure for a client quote.
Why we are not repeating €580 million as an established bill
An aggregate estimate depends on the product basket, trade volumes, production routes, emissions boundaries, certificate prices and free-allocation adjustment. Those inputs must be reproducible before a number becomes decision-grade. The TTI summary also uses high aluminum footprint figures without establishing that every emissions component belongs in the current CBAM calculation.
That distinction matters. Under Annex II of the CBAM Regulation and the Commission’s definitive aluminum guidance, the relevant aluminum goods count direct emissions, not the full electricity-related footprint often quoted in corporate carbon comparisons. Indirect emissions can be commercially important without belonging in the same certificate calculation. Steel requires its own sector-specific treatment.
The Commission describes an annual declaration and certificate-surrender system for the EU importer, not a uniform tax paid on every shipment at the border. The supplier should understand how that annual exposure influences the buyer’s purchasing decisions, without turning a country estimate into an invoice.
Replace the national headline with one real order
- 1.
Confirm the goods and importer obligation
Start with the CN code, origin, quantity, importer and relevant scope rules. A broad description such as “metal components” is not enough. The mass threshold applies at importer level across relevant covered goods; it is not a separate exemption for each supplier or shipment.
- 2.
Compare the legally usable evidence options
Calculate the applicable default-value case and, where available, the verified actual-emissions case. Include the correct production route, relevant precursors, free-allocation adjustment and price period. Actual emissions do not automatically mean a lower result.
- 3.
Find the commercial owner of the difference
Ask whether the buyer expects you to absorb carbon costs, accept a price reduction, pay for verification or provide data as a condition of purchase. A customer saving is not automatically extra supplier profit. The contract decides who benefits.
Your best carbon statistic is the one that helps a buyer choose your documented offer over an undocumented alternative.
A supplier footprint is not yet a usable CBAM data pack
A product carbon footprint certificate, an ISO-aligned study and a corporate sustainability report can contribute evidence. None should be assumed to replace a CBAM-compatible calculation and the required verification. The buyer needs traceability from installation and production records to the covered product, including relevant precursor emissions.
- Identify the producing installation and the production route, not only the exporting company.
- Retain production quantities, fuel and process records, measurement evidence and calculation assumptions for the relevant reporting period.
- Obtain usable precursor data where purchased steel, aluminum or other covered inputs form part of the product’s embedded emissions.
- Agree verification responsibility, data delivery dates and correction procedures with the EU importer.
- Keep declarations consistent with product, customs and commercial records; investigate unexplained changes before sending them.
When does paying for better evidence make sense?
Compare the credible difference in the buyer’s certificate requirement with the full cost of creating and maintaining usable data. Include internal staff time, meters, supplier follow-up, calculation support and independent verification. Use the same products, period and price assumptions in both cases.
Then ask what the evidence protects beyond a possible certificate saving: a key account, repeat orders, access to a procurement shortlist or a defensible price discussion. These are commercial opportunities, not guaranteed outcomes. Better data can also reveal that your actual route is more carbon-intensive than you thought.
The next action belongs to sales, finance and production together
Pick the EU customer and covered product that matter most to your business. Put the commercial terms, production records and emissions assumptions on one table. Identify the missing evidence and its owner. That exercise will usually tell you more than another national exposure headline.
The strategic lesson in TTI’s report is worth retaining: carbon evidence increasingly affects purchasing decisions. The financial numbers need a stricter test. Your factory should not exit a market, change suppliers or buy expensive verification support because a country-level estimate looks alarming.
Can your EU customer use the data you already have?
Start with the CBAM Readiness Assessment to identify product exposure and missing evidence. The automated results overview is free. A full report and expert review are separate paid services, and do not replace independent verification.
Start the CBAM Readiness AssessmentSources and editorial references
- Terawatt Times Institute, Preston Hayes, Ethan K. Marlow and Maya Robinson, “CBAM Country Intelligence Vietnam 2026: Expansion or Exit, Institutional Vacuum, and Audited Tradability”, March 21, 2026. Its aggregate liability estimates are discussed, not adopted as verified findings. https://terawatttimes.org/cbam-country-intelligence-vietnam-2026/
- European Commission, “CBAM definitive regime”, consulted November 10, 2026, publication date not specified. https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en
- European Commission, “Guidance document 5E: Sector-specific guidance document on aluminium”, August 14, 2026. https://taxation-customs.ec.europa.eu/document/download/590e983b-c937-41ea-bb9f-810c29e70e1e_en
- Regulation (EU) 2023/956, May 10, 2023, Articles 7 and 9 and Annex II, as amended. https://eur-lex.europa.eu/eli/reg/2023/956/oj
This article is our own analysis of material shared by Alberto. Third-party rights remain with their owners. No national exposure estimate or company saving is independently certified here. Product classification, calculations and verification must be checked for the actual goods and installation.
Dr. Elvis Mujagić
Dr. Elvis Mujagić is Partner and Head of CBAM at wis.dom|bridge™. He helps manufacturers and importers connect emissions evidence, sourcing decisions and carbon-cost exposure.
