Nine regulations, one supply chain, hundreds of ways to get it almost right.

The EU-side authorised CBAM declarant — the importer, or the indirect customs representative. The non-EU producer has no direct duty under the Regulation.

Commercially. Without your verified actual emissions the declarant must use default values, which carry a deliberate mark-up.

Whether your goods fall under an Annex I CN code, and your buyer’s aggregate import volume.

The EU operator who first places the product on the market. No EU statute binds the non-EU producer directly.

Your buyer cannot lawfully file a valid due-diligence statement without your plot-level geolocation and legality evidence.

Whether your product involves one of the seven commodities. There is no volume threshold — any quantity is in scope.

This one can bind you directly. Any supplier of an article containing a Candidate-List substance above 0.1% by weight owes an Art. 33 communication — including suppliers outside the EU.

Directly, and as a data demand. Your EU importer cannot register or answer without substance-level data from you.

What your articles contain. The Candidate List is updated roughly twice a year.

The economic operator placing the battery on the market. A non-EU manufacturer’s duties land on the EU importer.

As a combined data and verification demand — carbon footprint per model per plant, recycled content, due-diligence data, composition.

Battery category and capacity, and which phased duty has come into force.

EU manufacturers, importers and distributors of electrical and electronic equipment. A non-EU manufacturer’s obligations fall on the EU side.

As a material-declaration and testing demand, evidenced per homogeneous material.

Whether your product is in one of the eleven EEE categories.

The economic operator placing the product on the market — fixed per product group by its delegated act, so the obligated actor is not yet settled for most groups.

As a digital product passport data demand, once your product group’s delegated act applies.

Whether a delegated act covers your product group yet. Most do not exist.

Economic operators placing packaging or packaged products on the EU market. The obligations attach through the EU importer.

As a packaging data and testing demand — composition, substances of concern, recyclability, recycled content.

Your packaging formats. Applicable since 12 August 2026.

Only EU importers of 3TG as raw minerals or metals above the annex volume thresholds. Not finished-product manufacturers. A non-EU producer is not directly bound.

Not through the law. Through your customers, who cascade due-diligence requests as a contractual expectation.

Whether a buyer asks. A 3TG answer predicts being asked — it does not create a duty.

The reporting undertaking, not the supplier. A non-EU supplier is not directly in scope.

Your in-scope customer needs product carbon footprint data. A statutory value-chain cap limits what they may demand from companies outside CSRD scope.

Whether a buyer asks. Your own turnover and headcount are irrelevant here.