EU CBAM · Polish importers
Poland borders Ukraine, Belarus and Russia. CBAM goods cross here.
CBAM goods: steel, aluminium, cement and fertilisers from eastern non-EU origins. One rejected XML delays the full declaration set.
Reg (EU) 2023/956 Annex I · IR (EU) 2025/2620 · IR (EU) 2025/2621
Republic of Poland
KOBiZE · National Centre for Emissions Management
Sector exposure: four goods classes
Crude steel, hot-rolled and flat product, alloy and finished steel under Chapters 72 and 73. Poland draws heavily from Ukrainian and other eastern-border mills, many with high default embedded factors.
Primary and secondary aluminium under Chapter 76. Indirect emissions follow the grid intensity of the smelting country, making the origin-grid factor critical to the declared figure.
Calcined clays, cement clinker, Portland and hydraulic cements under Chapter 25 (2507 · 2523). Clinker is the emission-dominant precursor for the declared embedded-emissions figure.
Ammonia, nitric acid, urea and NPK fertilisers under Chapters 28 and 31. Precursor chemistry and N₂O process emissions drive the declared embedded-emissions figure.
Scope per Annex I to Regulation (EU) 2023/956. Each goods line carries its own emissions basis and schema-validation path. One rejected supplier XML in any class delays the complete Polish declaration.
Common questions
Frequently asked.
Why is CBAM a particular burden for Polish importers?
Poland is a major entry point for CBAM-covered goods reaching the EU across its eastern land borders, and a heavy-industry economy that draws iron and steel, aluminium, cement, fertilisers and hydrogen from many non-EU suppliers at once. A Polish declarant is rarely managing a single sector or a single origin; it is coordinating embedded-emissions evidence across several goods categories and dozens of installations into one declaration. The volume and breadth of the supplier base - not any one calculation - is what makes the obligation heavy.
Who is the competent authority for CBAM in Poland, and does Carbon Mandate file for me?
Poland’s national competent authority for CBAM is the National Centre for Emissions Management (Krajowy Ośrodek Bilansowania i Zarządzania Emisjami, KOBiZE), which administers authorised CBAM declarant status. The declaration itself is submitted through the EU CBAM Registry, where you remain the declarant of record. Carbon Mandate does not file. We are a preparer, not a filer: we check every incoming supplier XML against the EU CBAM schema, coordinate the supplier pipeline, and hand your filing team an audit-ready evidence pack to submit yourselves.
What happens when a Polish importer’s suppliers cannot evidence actual emissions?
The declaration falls back to default values, which carry a markup: +10% in 2026 under the standard schedule of Regulation (EU) 2025/2621, rising to 20% and 30% in later years (fertilisers are the sole reduced exception). The uplift is applied to the declared embedded factor on every tonne where actual data is missing, and is surrendered in CBAM certificates. Across a Polish importer’s full multi-sector book, the cost of unevidenced data compounds quickly. Collecting actual supplier data removes the markup.
Live demonstration
See the XML prepared live - in 20 minutes
No slides. No sales pitch. We open a live CBAM file from your sector, run the same checks we run on every declaration, and show you the XML file we produce.