Poland and Romania accounted for 10.3% of the EU’s 2025 extra-EU imports under current Carbon Border Adjustment Mechanism (CBAM) codes, equivalent to roughly €11.5 billion, based on rounded Eurostat-derived country shares. Poland represented 6.1% of those imports and Romania 4.2%.
The two countries sit at the intersection of European industrial production, eastern supply routes and cross-border electricity trade. Both have direct demand for imported materials and supply wider European value chains. Steel and aluminium feed construction, machinery, household appliances, automotive components and metal fabrication; fertilisers serve agricultural markets, while electricity imports have a distinct commercial and regulatory profile.
Customs values do not necessarily show where imported goods are finally consumed. Materials can enter through neighbouring EU member states before reaching Polish or Romanian factories, while goods cleared locally may be distributed onward. A contractor buying steel from a regional warehouse could therefore face an indirect carbon-related cost without having a CBAM certificate obligation.
For importers serving multiple customers, an auditable method to allocate imported quantities and associated emissions evidence is relevant to managing supply-chain exposure. Buyers comparing lower-priced material from a higher-emissions plant with costlier material supported by credible verified data need to assess landed cost and contracting risk. Investors will also watch whether the mechanism can encourage better supply quality and environmental data without undermining manufacturing competitiveness.
Country-level analysis should identify leading CN8 items and origins, then trace importers, processors, distributors and buyers in manufacturing clusters. Poland warrants attention to high-volume metal processing and fertiliser distribution. Romania, an EU neighbour to Serbia and other Energy Community markets, merits separate scrutiny of electricity and industrial feedstock routes from the Western Balkans, including how those routes affect electricity-import evidence and carbon-price exposure.
The EU has proposed expanding CBAM downstream to selected manufactured products; the change could affect their treatment from 2028 if adopted. The analysis needs to distinguish direct customs liability from wider supply-chain exposure across eastern Europe’s industrial markets.
