CBAM in Practice: Embedded Emissions & De Minimis

If you import carbon-intensive goods into the EU, CBAM changes how you account for their carbon footprint at the border. The mechanism is sometimes confused with the Digital Product Passport (DPP), yet the two are distinct instruments. This article explains what embedded emissions are, how the de minimis threshold works, and where CBAM meets DPP data.

What CBAM is

CBAM, the Carbon Border Adjustment Mechanism, is Regulation (EU) 2023/956. It is a carbon-pricing mechanism applied at the EU border to imports of certain carbon-intensive goods.

The aim of CBAM is to level the cost of emissions between EU production and imports. As a result, goods brought in from outside the EU do not gain an advantage simply because they were made where emissions are priced lower. The full regime applies from 1 January 2026.

Embedded emissions: what you must report

The heart of CBAM is embedded emissions — the emissions bound up in producing an imported good. These are not the emissions from transport or from use, but the ones locked into the production process itself.

Importers must report the emissions embedded in the goods they bring in. In practice this means gathering data on how and where a good was produced and what carbon footprint that entails. Reliable data from suppliers therefore becomes a central part of the reporting.

The de minimis threshold: an exemption for small volumes

CBAM provides a de minimis exemption for low-volume imports. The idea is simple: if you bring in very small quantities of covered goods, the obligations should not be disproportionate to the scale of your activity.

The reported threshold is roughly below 50 tonnes per year (Regulation (EU) 2025/2083), but treat that figure as source-stated rather than iron-clad. What matters most is the concept: there is a line below which a small importer can be exempt from the full obligations. It is always worth checking the current legal position for your own situation.

CBAM is not a Digital Product Passport

The crucial distinction: CBAM is not a Digital Product Passport and does not use the DPP registry. It is separate emissions reporting and border pricing, built on its own procedures and its own system.

The DPP stems from ESPR (Regulation 2024/1781) and concerns the structure of product data across the life cycle. CBAM, by contrast, concerns accounting for emissions at import. Conflating the two instruments leads to wrong conclusions about a company's obligations. We also cover this in ESPR, batteries and CBAM.

Where CBAM meets DPP data

Although they are separate systems, one resource connects them: emissions and environmental data. The carbon-footprint information a company compiles for CBAM can also feed the environmental fields of a product passport.

• Emissions data from production is useful for CBAM reporting.
• The same environmental information can populate DPP fields.
• A single, organised data source cuts duplicated effort.

This is a data synergy, not a merger of obligations — each instrument keeps its own rules and its own purpose.

How to gather emissions data in practice

Reporting embedded emissions starts with your suppliers. They know the production process and can hand over the data needed for the calculations, so it is worth agreeing the format and scope with them in advance rather than chasing it at the last minute.

It helps to settle early what information you will need:

• the origin and place of production of the goods,
• data on the manufacturing process and the energy used,
• the carbon footprint attributed to a unit of the imported good.

Good practice is to keep this information in one organised place rather than scattered spreadsheets. That makes the data easier to verify, update and reuse — including beyond CBAM reporting itself.

How to prepare organisationally

It helps to treat emissions data as a lasting company asset rather than a one-off report. Organised data from suppliers and from your own production is easier to reuse many times over.

A company that builds a reliable environmental data base gains twice: it reports CBAM more smoothly and prepares better for DPP requirements. The same data also helps substantiate environmental claims, which we cover in green claims and greenwashing.

Key takeaways

• CBAM (Regulation (EU) 2023/956) is a carbon-pricing mechanism at the EU border; the full regime applies from 1 January 2026.
• Importers report embedded emissions — the emissions bound up in producing imported goods.
• A de minimis exemption exists for small volumes (reported as roughly below 50 t/yr, Regulation 2025/2083) — worth verifying.
• CBAM is not a DPP and does not use the DPP registry — they are separate instruments.
• Emissions data can serve both CBAM reporting and the environmental fields of a passport.

See how CyfroPass helps you organise environmental data and build a Digital Product Passport. Visit cyfropass.pl and start with your first product.