What should an Indian MSME exporter prepare?

For businesses: a practical checklist

1. Check your CN codes. Confirm with your EU buyer whether each product's 8-digit code is in CBAM Annex I.
2. Talk to your EU buyer early. Ask which data they need, in what format, and whether they will declare actual or default values. Remember that your buyer, not you, carries the legal duty.
3. Start monitoring now. Record fuel, electricity, raw materials, precursors (for example, steel billets or wire rod you buy) and production output per installation and per product. The Commission's Q&A tells operators to take concrete steps in 2026 to monitor and calculate embedded emissions.
4. Ask your suppliers for precursor data. If they cannot give it, you may combine your own actual process data with default values for precursors.
5. Plan verification. Actual values must be verified by an accredited CBAM verifier. The Commission expected the first accreditations around September 2026 and verification work in early 2027 for the first declaration.
6. Consider registering in the CBAM registry as a third-country operator, which the Commission says makes it easier for declarants to use your verified data.
7. Keep evidence: invoices, meter readings, fuel bills and production logs, kept for audits.
8. Watch the rules. Default values, the downstream extension and the carbon-price-paid rules are all changing in 2026-2027.

Be careful with paid "CBAM certificates" or "CBAM compliance guaranteed" offers. The Commission's Q&A warns importers to check private offers of paid verification services; only accredited CBAM verifiers can verify emissions.