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Regulations & Tax · 29 Sep 2026

EU Carbon Border Adjustment Mechanism (CBAM): Key Considerations for Vietnamese Exporters

An overview of the EU Carbon Border Adjustment Mechanism (CBAM), affected industry sectors, and transition roadmaps for Vietnamese exporters.

Cơ chế điều chỉnh biên giới carbon (CBAM) của EU: Những điều doanh nghiệp xuất khẩu Việt Nam cần lưu ý
Photo: 振中 潘 / Pexels
Key points

What Is CBAM and Why Does It Matter to Vietnamese Enterprises?

The Carbon Border Adjustment Mechanism (CBAM) is a landmark environmental policy of the European Union (EU). The core objective of CBAM is to ensure parity between EU producers—who are subject to stringent emissions standards—and non-EU manufacturers. By levying a carbon price on imported goods based on the greenhouse gas emissions embedded in their production, the EU aims to prevent 'carbon leakage', where companies relocate manufacturing to jurisdictions with less stringent environmental regulations.

For Vietnam, the EU represents one of its foremost export markets. The implementation of CBAM is not merely a new technical barrier, but also a decisive indicator of the global green trade transition. Businesses failing to adapt in a timely manner risk encountering elevated costs and forfeiting competitive advantages within this market.

Cơ chế điều chỉnh biên giới carbon (CBAM) của EU: Những điều doanh nghiệp xuất khẩu Việt Nam cần lưu ý
Photo: K / Pexels

Commodity Groups Covered Under CBAM

In its initial phase, the EU focuses on industry sectors carrying the highest risk of carbon leakage and significant emissions intensity. Below is the list of key commodities Vietnamese enterprises must monitor:

Commodity SectorImpact Characteristics
Iron and steelThis sector faces the most substantial impact due to significant export volumes from Vietnam to the EU.
AluminiumAluminium and aluminium alloy products are subject to regulatory coverage.
CementAlthough direct export volumes to the EU are relatively limited, cement manufacturing entails exceptionally high emissions intensity.
FertilisersChemical fertilisers for agricultural applications.
ElectricityApplies to cross-border electricity transmission and trade (with less direct impact on Vietnam compared to other sectors).
HydrogenAn emerging energy commodity promoted by the EU, yet still subject to emissions oversight.

Please note that this scope may be expanded by the EU in the future to encompass downstream goods or other sectors such as plastics and chemicals.

Implementation Roadmap: From Reporting to Financial Enforcement

The CBAM mechanism is not implemented overnight; rather, it is phased in to allow commercial entities adequate preparation time:

1. Transition Phase

During the transitional phase (01/10/2023 – 31/12/2025), importers of covered goods into the EU are only required to submit quarterly reports detailing the embedded greenhouse gas emissions of their products (including direct and indirect emissions) without having to surrender financial carbon charges. The objective is to collect data and familiarise stakeholders with carbon accounting methodologies. Starting in 2026, Vietnamese enterprises must furnish EU importers with verified actual emissions data for the annual CBAM declaration; in the absence of primary data, importers may be compelled to rely on default values, which are typically less favourable.

2. Definitive Phase

The definitive phase commences on 01/01/2026: only authorised CBAM declarants are permitted to import CBAM goods exceeding the threshold of 50 tonnes/year, and they must surrender CBAM certificates corresponding to embedded emissions. Certificates will be sold starting 01/02/2027; the 2026 price is calculated on a quarterly average, and from 2027 onward on a weekly average of EU ETS auction prices. If an installation operator has effectively paid a carbon price in the country of origin (which is not rebated upon export and is independently verified), this amount may be deducted from the required CBAM certificate surrender liability.

Challenges and Opportunities for Vietnamese Exporters

CBAM compliance poses several challenges while simultaneously unlocking new commercial opportunities:

VPL: Partnering with Shippers in the CBAM Era

At Viet Power Logistics (VPL), we understand that international regulatory shifts such as CBAM can present operational challenges for your enterprise. As an international freight forwarder, VPL supports our clients with:

The green transition is no longer discretionary; it is a mandatory pathway to sustaining international competitiveness. VPL stands ready to accompany your enterprise in navigating and succeeding within the high-potential yet demanding EU market.

References
  1. Cổng thông tin Hải quan Việt Nam

This article is for general information and was compiled by VPL from public sources at the time of publication. Regulations may change – please contact VPL for advice on your specific shipment.

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