Is exporting a loss? How should Chinese enterprises respond to the EU's "green test"

On January 1, 2026, the EU Carbon Border Adjustment Mechanism (CBAM) entered the substantive charging stage, and the first boot of the global "carbon tariff" landed.

The comprehensive implementation of this policy has also become a new test that Chinese export enterprises must face directly. A green trade transformation involving cost accounting, technological upgrading, and supply chain restructuring is accelerating, from basic raw materials such as steel and aluminum to downstream industries such as automotive components and mechanical equipment.

Facing the cost pressure of 'real gold and silver'

The implementation of CBAM has brought certain challenges to Chinese enterprises. ”Wang Xiaohong, a researcher at the China International Economic Exchange Center, said that the competitiveness of high energy consuming and high emission products from some traditional industries in the EU market may be weakened. Huang Yanxiang, CEO of Carbon Balance Technology, revealed the harsh reality with data: "Compared with the transition period, Chinese companies are now directly facing the 'real gold and silver' carbon tax cost. Companies that have not done a good job of carbon tax estimation may even directly face the situation of 'export equals loss'. According to the default value method, for every ton of CBAM steel products exported, they may have to pay an additional 130-4670 yuan. ”

How should this account be calculated? Huang Yanxiang explained that although the CBAM certificate is cleared by EU importers, the importers will transfer some or all of the costs to Chinese suppliers through methods such as disguised product price reductions and contractual agreements on carbon tax sharing ratios. The current carbon tax calculation is divided into two methods: default value method and actual value method. Enterprises need to fully understand the costs and expenses of both mechanisms. However, the default parameter set designed by the EU is not entirely suitable for Chinese companies. If the default value method is used for accounting and payment, Chinese products are likely to be at a price disadvantage. However, using actual values for calculation also poses challenges such as the need for professional accounting of implicit carbon emissions, the need for third-party institutions to review accounting results, and difficulty in obtaining upstream data, "said Huang Yanxiang. In the proposal released by the European Union in December 2025, CBAM products were expanded to include downstream products that are steel and aluminum intensive, including mechanical equipment and parts, automobiles and their components, household appliances, electrical equipment, metal products, etc. It is expected to be implemented from January 1, 2028. Many related industries and companies that are not familiar with this may panic and think that taxes will be imposed on the entire product. However, in reality, CBAM only calculates the implicit carbon of precursor materials such as steel and aluminum in downstream products, and other categories of materials do not need to be calculated. ”Huang Yanxiang gave an example, "For example, for car doors produced in China, CBAM only calculates the implicit carbon emissions of the steel plates used in the production of the doors, and the process of processing the steel plates into parts or assembling them is not within the scope of control. Nevertheless, some industry insiders believe that Chinese companies still face increased costs and technological barriers in areas such as carbon accounting and green standard certification. This impact is systemic, with a short-term increase in costs, a medium-term risk of market share being squeezed by companies from other countries, and a long-term possibility of forcing the entire industry landscape to reshape.

Seeking the development path of low-carbon transformation

Beyond challenges, there are also opportunities for transformation. Wang Xiaohong believes that CBAM will encourage Chinese enterprises to accelerate the adjustment and optimization of their trade structure. ”She pointed out that on the one hand, the proportion of exports of high energy consuming and high emission products may gradually decrease, while on the other hand, the proportion of exports of green and low-carbon products is expected to increase. How should Chinese enterprises respond and seize challenges and opportunities? We should treat 'carbon' as the underlying asset and build a solid foundation for 'carbon data', "Huang Yanxiang suggested. Enterprises can build a full level and multi-dimensional digital carbon management system from the product level, organizational level to the supply chain level, and create a real, transparent, and traceable 'carbon asset' ledger.

At the same time, enterprises should prioritize low-carbon concepts and integrate them into multiple aspects such as research and development, production, and management. By developing green design schemes, introducing low-carbon raw materials, and optimizing energy structure, the "carbon intensity" of products can be reduced from the source, making low-carbon the second core competitiveness beyond product performance. This can also avoid potential trade carbon barriers and turn "compliance costs" into "brand premiums".

In addition, enterprises need to connect the "ecological carbon chain", work together with upstream and downstream to build a "green supply community", strengthen the penetrating collaboration of the industrial chain, connect with upstream raw material enterprises and downstream customers through carbon data platforms, promote the green transformation of upstream suppliers, and help downstream customers achieve their carbon goals. This deep supply chain binding can not only share the cost of green compliance, but also form a "green ecological barrier" that competitors find difficult to replicate in the short term. Wang Xiaohong suggests that enterprises should adopt multidimensional response strategies: firstly, accelerate green technology innovation and increase research and development investment in clean energy, energy-saving and emission reduction technologies; Secondly, it is necessary to improve the green standards and certification system. Enterprises should actively participate in the formulation and improvement of domestic green standards, and promote the establishment of a green product standard system that is in line with international standards; Once again, it is important to expand the green trade market. While consolidating the EU market, companies should actively expand into other international markets and reduce the risk of dependence on a single market.