Smaller Indian manufacturers may face difficulties maintaining access to European customers where they cannot provide sufficiently detailed product emissions data for the EU Carbon Border Adjustment Mechanism, according to reporting by Carbon Pulse.
The issue extends beyond investment in lower-emission equipment. Manufacturers also need systems for measuring production, collecting information from upstream suppliers and converting those records into the emissions data required by European customers for CBAM purposes.
The reporting describes a potential threat to market access rather than a quantified number of orders that have already been cancelled.
India expands domestic framework for low-carbon steel
India is developing its own framework for lower-emission steel production. In a 28 July parliamentary answer, the Ministry of Steel said that 90 steel units had received certification under the national Green Steel Taxonomy during the 2025-26 financial year, representing 12.4 million tonnes of production.
The ministry also identified four hydrogen pilot projects and India’s Carbon Credit Trading Scheme among measures supporting the steel sector’s transition.
These initiatives form part of India’s domestic industrial policy. Certification under the national framework does not, by itself, establish that an Indian shipment contains all the evidence required for an EU CBAM import declaration.
Upstream data creates challenges for smaller processors
For smaller manufacturers and processors, emissions-data requirements can extend beyond their own production facilities. A company purchasing steel through a trader rather than directly from a mill may depend on another business for information relating to the installation where the steel was produced.
Likewise, low fuel consumption at a finishing facility does not necessarily provide the information needed to establish the emissions associated with the steel used as an input.
European buyers therefore face a choice between managing gaps in supplier documentation and sourcing from producers able to provide a more complete CBAM compliance file. This creates an incentive for suppliers to strengthen emissions records even where immediate spending on emissions-reduction equipment is not financially feasible.
Export readiness increasingly depends on emissions records
For smaller Indian companies, conventional export credentials such as quality approvals, delivery reliability and competitive pricing may not be sufficient if the European buyer requires emissions information that the supplier cannot substantiate.
The distinction is particularly relevant as companies prepare for EU CBAM requirements. The ability to document existing production can become a prerequisite for supplying the European market, independently of whether a manufacturer has already invested in major emissions-reduction measures.
For some smaller firms, maintaining European orders may therefore begin with making existing production and emissions measurable, before undertaking further reductions in the emissions intensity of that production.
