Central Asian exporters that get CBAM-ready will gain an edge on the EU market

For manufacturers in Kazakhstan and Uzbekistan, the European Union’s carbon rules have stopped being a distant regulatory debate and become a direct commercial variable. Kazakhstan alone exports more than €600 millions of steel and aluminium to the EU every year, and over half of its aluminium production is sold into European markets. According to a European Union assessment, the Carbon Border Adjustment Mechanism (CBAM) could add over €100 million a year to the cost of Kazakhstan’s steel exports if emissions are calculated on default values – with the heaviest impact on steel bars and rods, where the CBAM charge alone could exceed the value of the product itself. For fertiliser producers in Uzbekistan, ammonia and nitrogen products sit squarely within the same mechanism.

CBAM is an EU regulatory tool whose relevance to global trade will keep growing over the coming years. It applies to goods entering the EU from third countries that are not part of the EU Emissions Trading System (EU ETS). Products exported from Central Asia to European markets – primarily steel, iron and aluminium, alongside cement, fertilisers, electricity and hydrogen – are increasingly assessed for their CO₂ footprint before they even reach the EU border. Manufacturers in Kazakhstan and Uzbekistan, where Rohlig SUUS Logistics operates, as well as in neighbouring markets, are therefore directly in scope.

Because of the reporting obligations placed on their EU customers, the impact on pricing and the potential supply-chain risks, CBAM is a challenge for many companies across the region – including those in Kazakhstan and Uzbekistan that want to remain competitive suppliers to the European market. This is why it is worth partnering with experts who not only understand the mechanics of CBAM, but can translate its requirements into clear actions and tangible business value across transport and export processes.

Emissions reporting paves the way to European-market success

CBAM entered its operational phase on 1 January 2026, replacing quarterly reporting on the CO₂ emissions embedded in the goods imported from Central Asia, with a single annual declaration. Under the Omnibus simplification package adopted by the EU in October 2025, however, the actual purchase and surrender of CBAM certificates has been postponed to 1 February 2027, when authorised declarants will begin acquiring certificates covering emissions embedded in goods imported during 2026; the first annual declaration and certificate surrender are due by 30 September 2027. Producers and exporters across Central Asia that begin preparing now – collecting accurate emissions data, standardising their reporting and archiving supporting documentation – will directly reduce their buyers’ future certificate costs and strengthen their own position as reliable, competitive suppliers to the EU.

EU buyers are also required to document their attempts to obtain actual emissions data from suppliers. In practice, this means exporters in Kazakhstan, Uzbekistan and across the region are increasingly expected to keep records of that correspondence and respond promptly to data requests: a well-documented, cooperative supplier is far less likely to expose an EU buyer to additional scrutiny, and stands a better chance of retaining the relationship. As European buyers consolidate their supplier base around partners who can prove a low and well-documented carbon footprint, this is precisely where a Central Asian producer can win share rather than lose it.

For an exporter, the key requirement is to provide complete and accurate emissions data that can be verified by an accredited verifier. The verifier may review the production installation and assess whether the reported methodology complies with CBAM requirements before issuing a verification statement that allows the EU importer to use actual emissions data. If verified data are not available, the importer may still fulfil its CBAM obligations using the applicable default values, although this can result in higher reported emissions and, consequently, higher CBAM costs.

CBAM to cover a broader scope of products, with simplifications on the way

The Omnibus package simplified certain administrative and reporting obligations under CBAM. The changes are intended to ease the burden, particularly on smaller importers, while improving the transparency and predictability of the system for exporters and their EU buyers alike.

One of the key changes is a new annual threshold of 50 tonnes of imported CBAM goods. Many smaller EU buyers – and, by extension, the smaller producers in Kazakhstan, Uzbekistan and elsewhere in the region that supply them – are now exempt from CBAM’s reporting and certificate obligations, significantly reducing the number of exporters affected. Procedures for importer authorisation, emission-calculation methods and data-reporting standards have also been simplified.
From 2027, EU buyers will be able to declare emission-related costs already paid in third countries using published average national values. This is particularly relevant for the region: Kazakhstan has operated its own emissions trading system since 2013, and Uzbekistan is developing carbon-pricing instruments of its own. Recognising CO₂ costs paid domestically at the EU border reduces the risk of double carbon taxation for exporters from Central Asia – and rewards those who can document what they have already paid at home.

The Omnibus package also signals the direction of travel: CBAM will gradually expand to cover additional sectors and products. More producers across Central Asia, including those outside the currently regulated industries, should therefore begin assessing how CBAM will affect their access to the European market.

Resilience and a competitive advantage through compliance

At Rohlig SUUS Logistics, which operates across Europe as well as in Kazakhstan and Uzbekistan, we understand the challenge producers and exporters across Central Asia are facing. We provide comprehensive support to companies preparing their goods for the EU market under CBAM: our experts monitor regulatory updates and legal interpretations, help exporters collect and structure the emissions data their European buyers require, and support communication with those customers. We also deliver practical tools – emissions-data templates and correspondence forms – to simplify reporting for both sides, and we support clients in exceptional cases, for example when reporting deadlines are at risk or additional coordination between exporters, importers and accredited verifiers is required.

For companies in Kazakhstan, Uzbekistan and across Central Asia, CBAM is not merely another environmental regulation – it marks a shift in the global trade paradigm. For some producers it may become a barrier to the EU market. For those who prepare early and adapt strategically, it can become a source of competitive advantage over other manufacturers in the region. The Omnibus package offers additional breathing room, but not an exemption from responsibility. That is why a logistics partner who understands the mechanism – and knows how to turn it into a business asset – matters more than ever for producers and exporters operating cross-border and targeting European markets.