What to Do When Your Indian Steel Supplier Refuses to Give Emission Data

Key Takeaways

• Emission data is crucial for CBAM compliance when exporting to the EU.
• Engage in open communication with your supplier to understand their reluctance.
• Explore alternative sources for emission data if your supplier remains uncooperative.
• Leverage CBAM compliance services like CarbonSettle to manage your compliance needs effectively.

Introduction

As Indian exporters prepare for the implementation of the EU's Carbon Border Adjustment Mechanism (CBAM), obtaining accurate emission data from suppliers, particularly in the steel sector, is becoming increasingly vital. However, many Indian MSMEs face challenges when their steel suppliers refuse to provide necessary emission data. This article aims to guide Indian manufacturers and compliance officers through actionable steps to address this issue while ensuring compliance with Regulation (EU) 2023/956.

Why Is Emission Data Important for CBAM Compliance?

Emission data is essential for calculating the carbon intensity of products exported to the EU, particularly for sectors like steel, which face strict carbon regulations. Under CBAM, starting from January 2026, companies must report their emissions to determine the carbon tax applicable on their imports. The failure to submit accurate emission data can result in financial penalties and hinder export opportunities in the EU market.

What Should You Do First If Your Supplier Refuses to Provide Emission Data?

If your steel supplier refuses to provide emission data, the first step is to engage in a constructive dialogue. Reach out to them to understand the reasons behind their reluctance. They may be unaware of the importance of emission data for CBAM compliance or may have concerns about confidentiality or data security.

Key Actions:

• Initiate a Conversation: Clearly explain why emission data is critical for your exports to the EU.
• Provide Context: Share information about CBAM and its implications for both parties.
• Address Concerns: Assure them that their data will be handled confidentially and only used for compliance purposes.

How to Collect Emission Data from Alternative Sources?

If your supplier remains uncooperative, you can explore alternative methods to collect the necessary emission data. Here are some strategies:

1. Use Industry Standards

Refer to industry standards and benchmarks for emissions associated with steel production. Organizations like the World Steel Association publish average emission factors that can serve as a guide.

2. Collaborate with Other Suppliers

If you have multiple suppliers for steel, consider reaching out to others who may be more willing to share their emission data. This can also serve as a comparative analysis for your compliance reporting.

3. Engage Third-Party Auditors

Consider hiring third-party auditors who specialize in carbon emissions. They can assess your supplier's processes and provide verified emission data based on industry standards and practices.

4. Data from Utility Providers

Obtain data from utility providers such as MSEDCL, UGVCL, or TANGEDCO, which may have information on the carbon intensity of electricity used in the production process.

What Are the Legal Implications of Not Having Emission Data?

Failing to secure emission data can lead to significant legal and financial repercussions under the EU's CBAM regulations. Starting in 2026, companies that do not comply with emission reporting requirements may face:

• Financial Penalties: Non-compliance can result in fines that significantly impact your bottom line. For example, penalties can range from €100 to €500 per ton of CO2 equivalent not reported.
• Market Access Issues: Without proper emission data, your products may be barred from entering the EU market, severely limiting your export opportunities.
• Reputation Damage: Non-compliance can harm your company's reputation and relationships with EU importers.

How to Approach Your Supplier Again?

If initial discussions do not yield results, consider a more structured approach to re-engage your supplier. Here are some strategies to facilitate this process:

1. Formal Request

Send a formal request for emission data, clearly outlining the regulatory requirements and the importance of compliance. Include a deadline for their response to emphasize urgency.

2. Offer Support

Assure your supplier that you are willing to assist them in understanding the CBAM requirements. This may include providing them with resources or connecting them with CBAM consultants.

3. Highlight Mutual Benefits

Discuss how compliance can benefit both parties, including potential market advantages and improved business relationships with EU clients.

What If Your Supplier Continues to Refuse?

If your supplier remains unwilling to provide emission data, you may need to consider alternative options:

1. Change Suppliers

If feasible, look for alternative suppliers who are more compliant and willing to share emission data. This may involve sourcing from regions or companies that prioritize transparency in their operations.

2. Work with a CBAM Compliance Service

Engaging a dedicated CBAM compliance service like CarbonSettle can help manage your compliance needs. Our team specializes in navigating the complexities of CBAM regulations, ensuring you have access to verified emission data and streamlined reporting processes.

2026 Regulatory Impact for Indian Exporters

The definitive phase of CBAM starts in January 2026, when Indian exporters must fully comply with emission reporting requirements. During this period, companies will need to submit detailed reports on their products' carbon emissions, which will directly impact the carbon tax applied to their imports.

Financial Obligations

• Carbon Tax Rates: The carbon tax rates will be determined based on the emissions reported. For instance, if your product has a carbon intensity of 0.5 tons of CO2 per ton of steel, and the carbon tax is €50 per ton, you will incur a tax of €25 per ton of steel exported.
• Potential Savings: By accurately reporting emissions and utilizing verified data, companies can save up to 40% on CBAM taxes compared to default values set by the EU.

How CarbonSettle Can Help

Navigating CBAM compliance can be challenging, especially when faced with uncooperative suppliers. That's where CarbonSettle comes in. As India's #1 end-to-end CBAM compliance service, we take your entire CBAM headache away. Our dedicated team handles everything from collecting your factory data—such as electricity bills, fuel invoices, and production logs—to generating EU-ready verified reports and coordinating with your EU importer.

By partnering with CarbonSettle, you can ensure compliance while potentially saving up to 40% on CBAM tax versus EU default values. You don’t need to learn any software or hire additional compliance staff; we manage it all.