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Navigating the compliance with the new CBAM regulation can be complex — but you don’t have to do it alone. As Customs, CBAM, and trade consultants managing the Global Centre of Excellence within PwC for CBAM, we’re here to guide companies through every step of the transition.
Carbon Border Adjustment Mechanism (CBAM) Advisory Services
CBAM explained
Carbon Border Adjustment Mechanisms (CBAMs) address the climate challenge by imposing a carbon price on certain high-emission imports to prevent carbon leakage. These mechanisms encourage global businesses to monitor and reduce carbon emissions across operations while enabling fair competition within and outside the EU. Beyond the initial importers, users of these goods may face higher prices as suppliers pass on CBAM costs, affecting supply chain economics.
Several countries, such as the UK and Canada, are considering adopting CBAM. The EU has already implemented its CBAM, complimenting the EU Emissions Trading System (ETS). EU CBAM initially applies to goods like cement, steel, aluminium, fertilisers, electricity, and hydrogen. And the European Commision has recently announced that they will review if they will expand the scope to more downstream products. The mechanism is a pivotal element in the growing suite of regulations and policies under the Green Deal, pushing companies towards greener practices and helping them navigate the complexities of the new sustainable business environment in Europe.
EU CBAM commenced in 2023, with the first report due beginning 2024, and full financial implications starting in 2026 and phasing in until 2034 (whereby it is currently suggested that CBAM certificates should be bought as of 2027). As mechanisms like CBAM become more common, companies must innovate and adapt. Compliance not only aligns businesses with international sustainability standards, but also positions them competitively in a low-carbon economy.
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EU CBAM Explanatory
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Transcript
Do you import goods in scope of CBAM, or do you supply CBAM component materials to your clients that are part of CBAM goods?
Current goods covered by CBAM: cement, iron (e.g. screws and bolts), steel, aluminium, fertilisers, electricity, hydrogen. The full list can be found in the CBAM regulation's Annex.
Yes No
CBAM will not be directly applicable to your imports. However, stay informed about future updates as the scope of CBAM is expected to expand to include additional goods. Speak with us to learn more.
Where are you based?
Talk to:
Nguyen Hoang Nam
Sustainability and Climate Change (ESG) Leader and Partner, Assurance Services, PwC Vietnam
For more related content, check out our latest thought leadership.
The CBAM applies to import goods of EU companies, and Vietnamese exporters are required to provide accurate, verifiable emissions data to their EU customers/importers applied from 2026 onward. Answer the following questions to discover your readiness level.
Understanding relevant regulatory requirements thoroughly helps achieve compliance and assess costs. Conducting an impact assessment identifies potential cost increases and operational changes due to necessary CBAM regulations.
Yes No
Do you have an overview of the data that is required to provide to your EU customers/importers and do you have the data available?
Readily available data is crucial for accurate CBAM reporting and compliance. EU customers/importers must use their import data and collect actual emission data from their non-EU suppliers (e.g. Vietnamese exporters). Non-EU suppliers must communicate data to clients and sometimes collect it from their own suppliers.
Yes No
Beginning readinessYour organisation is at the initial stage of CBAM compliance readiness. You should further build your knowledge and develop your processes. As CBAM continues to evolve, Vietnamese exporters need a strong
understanding of data required and act as soon as possible to effectively manage
compliance risks and capture emerging opportunities. Speak with us to learn more.
Advanced readinessYour organisation has taken important steps towards CBAM compliance. You are gathering necessary data and conducting preliminary assessments. Continued efforts and training will help you achieve full compliance and optimise your processes. Speak with us to learn more.
Leading readinessYour organisation is well-prepared for CBAM compliance. You have the necessary data, and training in place, and are actively engaging with suppliers and clients regarding CBAM impacts. You are positioned to handle the regulatory requirements effectively and lead the way in compliance. Speak with us to learn more.
Where are you based?
Talk to:
Nguyen Hoang Nam
Sustainability and Climate Change (ESG) Leader and Partner, Assurance Services, PwC Vietnam
For more related content, check out our latest thought leadership.
How PwC can help Vietnamese exporters
Vietnamese exporters face several challenges under CBAM, the requirement to provide accurate, verifiable emissions data to their EU customers/importers applied from 2026 onward. Here's how we support you:
1
Immediate actions
In the near term, Vietnamese exporters must focus on building data readiness, strengthening processes and ensuring accurate, verifiable emissions reporting.
Read more2
Strategic actions
At the same time, organisations need to take a broader, strategic view—embedding governance, aligning reporting with business priorities and accelerating decarbonisation—to remain competitive in the EU market.
Read moreImmediate actions
- Capacity building
- Data collection & controls
- Embedded emission calculation
- Data verification
Capacity building
- Translate the complex regulatory obligations into simple actions for the exporter (e.g. communication templates).
- Upskill about CBAM requirements and reporting preparation.
Data collection & controls
- Determine the overlap between the existing GHG calculations and the EU ETS methodology.
- Benchmark GHG data maturity: verification, audit, investor-readiness.
- Review and develop processes, controls related to data collection, quality, access, and analysis.
- Identify types of calculations needed for CBAM.
- Determine the missing information and necessary modifications in calculation.
Embedded emission calculation
- Support with the extensive calculation methodology to determine actual emission values (based on EU ETS methodology).
- The CBAM reporter can be expanded with a calculation module, allowing the supplier to simply provide embedded emission data.
Data verification
- Prepare for data verification through upskilling to deliver creditable actual data.
- Active assistance in communication with the customers (EU importers) and accredited CBAM verifiers.
Strategic actions
- Reporting Landscape
- Governance
- Decarbonisation
Reporting Landscape
- Identify key value drivers, enablers, constraints, barriers & ambitions (with timelines) for mandatory and voluntary reporting.
- Assess across reporting ecosystem to identify areas of overlap and synergies in data collection, management & analysis.
- Link reporting ambitions to company sustainability policy, action plans.
Governance
- Build a responsible supply chain governance and accountability structure across functional teams: designate responsible person(s), integrate carbon emissionrelated risks into the company’s enterprise risk management framework
- Alert Board of Directors to emerging Sustainability disclosure requirements and risks.
Decarbonisation
- Broader discussions to mitigate GHG emissions across the value chain.
- Identify decarbonisation options, aiming to low-embedded emission goods.
PwC CBAM Reporter
CBAM Reporter is a structured digital accelerator to help streamline and automate your CBAM reporting obligations. The PwC approach identifies what matters: a human-led, tech powered solution to collect the data and submit the CBAM report.
Key functions of the CBAM Reporter:
- Offer a calculation module, allowing the supplier to simply provide embedded emission data
- Automated collection and integration of emissions data from various sources, including suppliers and producers.
- Monitoring of requests, suppliers' responses and progress of data collection.
- Automated preparation and submission of quarterly CBAM reports.
- Data visualisation of all collected information.
PwC insights
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Get in touch
Nguyen Hoang Nam
Sustainability and Climate Change (ESG) Leader and Partner, Assurance Services, PwC Vietnam
Tel: +84 28 3823 0796