EUR 75.36 Per Tonne — What the First CBAM Certificate Price Means for UK SME Suppliers

The EU published its first CBAM certificate price on 7 April 2026: EUR 75.36 per tonne of CO2 equivalent. If you’re a UK manufacturer or supply chain manager, you might assume this doesn’t affect you. It does.

CBAM—the Carbon Border Adjustment Mechanism—creates a pricing cascade that flows down supply chains. Your customer (likely an EU manufacturer) now faces a financial obligation based on the carbon intensity of their inputs. That means they will ask you for emissions data. They may ask soon. And if you can’t provide it, they will buy from someone who can, or assign a penalty default value that inflates your cost of goods.

This is not an environmental compliance story. It’s a procurement and cost story.

The data cascade: how CBAM reaches your UK SME

CBAM doesn’t directly apply to UK operations yet. But it applies to EU importers—and by extension, to the companies that supply them.

Here’s how it works in practice:

1. An EU importer (your customer) must report CBAM exposure on all their covered goods (steel, cement, aluminium, fertiliser, electricity, organic chemicals) when they cross the EU border, starting in full enforcement January 2028.
2. That importer must calculate the carbon content of their imports. They can either report their own emissions, or—if they don’t have them—use EU default values.
3. Default values carry a 10% uplift penalty. This makes them expensive. So the importer asks their supplier (you) to provide verified, activity-level emissions data instead.
4. If you don’t respond—or respond with spend-based estimates instead of real activity data—the importer uses the default. Your cost of goods goes up. Your margin erodes. You lose competitiveness.

This cascade has already begun. Major EU manufacturers are now rolling out CBAM data requests to their supply bases. SMEs that can’t answer are being deprioritised.

What data your customer actually needs

When a CBAM data request lands, it will ask for one of three things:

1. Scope 1 and 2 emissions data (kg CO2e per unit or tonne). This is actual measured or calculated activity data: energy consumed in production, electricity used, fuel burned. The format matters: EU regulators expect emissions per functional unit (per tonne of product, per unit produced).
2. Product-level breakdown. Your customer needs to know which of your products fall under CBAM scope. Currently, six product categories are covered: iron and steel, cement, aluminium, fertilisers, electricity, and organic chemicals. (Expanded scope will add more in 2027–2028.)
3. Documentation trail. Invoices, production records, energy bills. Auditors will verify. “We estimate it’s probably around 2 tonnes” will not work. You need traceable, third-party verified data.

The reporting window is tight. UK SMEs must be ready to provide this data by September 2027 if they supply covered goods to EU customers. That’s less than 18 months away.

The 50-tonne exemption: Goods imported with a carbon intensity below 50 kilograms CO2e per tonne are exempt from CBAM. Some low-carbon products—renewable energy, recycled metals, low-carbon cement—may fall below this threshold. If your product does, you have breathing room. If not, you need data now.

Common mistakes when responding to CBAM data requests

We’ve already seen UK SMEs stumble. The three most common errors:

1. Providing spend-based estimates instead of activity data

“We spend £X on electricity, so that’s Y tonnes of carbon.” Wrong. CBAM requires activity data: kilowatt-hours consumed, production volumes, specific process emissions. Your customer’s auditors will reject spend-based estimates. You’ll be assigned the default value.

2. Ignoring the request or delaying response

Some suppliers assume CBAM won’t affect them, or that it only applies to large manufacturers. Not true. If you make or process any covered good—even a component that goes into a larger assembly—and it ships to an EU customer, CBAM applies. Ignoring a data request now signals poor supply chain maturity. By 2027, that will cost you orders.

3. Assuming it doesn’t apply because you’re UK

CBAM applies to imports into the EU, regardless of origin. Brexit doesn’t exempt you. If your goods cross the Channel, CBAM applies to them. Your customer is now liable for the carbon cost, and they will pass the expectation for verified data down to you.

How CYF helps

Compare Your Footprint produces activity-level emissions data for UK manufacturing SMEs. Rather than wrestling with spreadsheets or rough estimates, you can generate verified, methodology-compliant emissions data that your customer’s auditors will accept. CYF also provides a benchmark dataset so you can contextualise your emissions against similar manufacturers in your sector—useful both for responding to CBAM requests and for identifying internal efficiency opportunities.

See our CBAM readiness guide for UK manufacturers for a step-by-step workbook.

What to do now

1. Audit your product portfolio. Which of your goods fall under CBAM scope? Check the six covered categories above.
2. Anticipate data requests. If you supply EU manufacturers, assume you’ll receive a CBAM data request by Q3 2026. Prepare activity-level emissions data (energy, production volume, process-specific inputs) in a format your customer can use.
3. Validate your current data. Do you have traceable, third-party verified emissions figures? If not, start now. The 18-month runway to September 2027 is tighter than it looks.
4. Build it into your supply contract. Make emissions reporting a standard requirement. Lock data provision into your T&Cs so there’s no ambiguity when the request comes.

The EUR 75.36 certificate price is the proof point. CBAM is no longer theoretical. It’s live, priced, and spreading through supply chains. UK SME suppliers have a small window to prepare. Use it.

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By Alice Roberts, Senior Analyst, Compare Your Footprint