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CBAM definitive period since January 1, 2026 — certificates for 2026 imports are bought from 2027
International Trade Compliance — EU Carbon Border Tax

EU CBAM:
What Malaysian
Exporters Must
Do Now.

The EU Carbon Border Adjustment Mechanism is no longer a future threat — its definitive period began January 1, 2026. EU importers of Malaysian steel, aluminium, cement and fertilisers must cover the embedded emissions of those goods with CBAM certificates, which go on sale in 2027. For cement and fertilisers, where electricity emissions count, on-site solar is one practical, financeable way to reduce that share of your CBAM exposure.

2026 guide 20 min read For: Export Managers, CFOs, ESG Officers
Are You CBAM-Exposed?
Do you export iron, steel, or aluminum to EU?HIGH
Do you produce cement, fertilizers, or hydrogen?HIGH
Are EU buyers asking for embedded emission data?ACTIVE
Is your primary power source the TNB grid?0.740 tCO2/MWh
Do you supply Tier-1 components to EU OEMs?WATCH

Checked 2 or more? You need a CBAM Decarbonization Plan.

01What is EU CBAM and Why It Matters for Malaysia

The Carbon Border Adjustment Mechanism (CBAM) is the European Union's landmark policy to prevent “carbon leakage” — the practice of companies relocating carbon-intensive production to countries with weaker climate regulations. Under CBAM, EU importers must purchase “CBAM certificates” proportional to the embedded carbon emissions in goods they import from non-EU countries.

CBAM certificates are priced to match the EU Emissions Trading System (EU ETS) carbon price — currently trading at EUR 55–70 per tonne of CO2 equivalent (tCO2e) in Q1 2026. The key variable is the “embedded emission intensity” of your product — measured in tCO2e per tonne of output.

For Malaysian manufacturers, this creates a direct financial incentive to reduce the carbon intensity of their production — particularly the Scope 2 emissions from electricity consumption. Malaysia's TNB grid has an emission factor of approximately 0.740 tCO2e per MWh for Peninsular Malaysia (Suruhanjaya Tenaga, 2024 (provisional)), one of the higher emission factors in Southeast Asia. Solar electricity you generate and use on site avoids that grid factor for the share of your load it covers.

The CBAM Cost Formula

CBAM Certificate Cost =
Embedded Emissions (tCO2e) × EU ETS Carbon Price (EUR/tCO2e)
minus: Carbon Price Already Paid in Country of Origin
Near Zero
Malaysian Carbon Price
No mandatory carbon market yet
EUR 60/tCO2e
EU ETS Price (Q1 2026)
circa RM 305/tCO2e
≈ EUR 60/tCO2e
Net CBAM Levy (Malaysian goods)
At the full rate (reached in 2034) — no offset

Malaysia's disadvantage: Because Malaysia does not yet have a mandatory carbon pricing mechanism, the full EU ETS carbon price applies to embedded emissions in Malaysian exports — with no offset or credit. Every tonne of CO2 embedded in your product costs your EU buyer up to EUR 60 in CBAM certificates at the full rate. The charge phases in from 2026 as free EU ETS allowances are withdrawn and reaches 100% of embedded emissions in 2034. Reducing your emission intensity is the only way to reduce this cost.

02Which Malaysian Industries Are Affected

CBAM's initial scope covers six product categories. Malaysia is a significant exporter in several of these, particularly aluminum products, steel pipes and tubes, and fertilizers.

CBAM SectorKey Malaysian ExportersTypical Emission IntensityCBAM Cost/tonne Output (at full rate, 2034)
Iron & SteelHiap Teck, Southern Steel, Mycron Steel1.8–2.5 tCO2e/tonneEUR 108–150/tonne
AluminiumPress Metal, Alcom, Aluminium Extrusions6–12 tCO2e/tonneEUR 360–720/tonne
CementYTL Cement, Lafarge Malaysia, CMSB0.8–0.9 tCO2e/tonneEUR 48–54/tonne
FertilizersMalaysian fertilizer producers1.2–3.0 tCO2e/tonneEUR 72–180/tonne
HydrogenPETRONAS, emerging green H2 projects0–10 tCO2e/tonneEUR 0–600/tonne
ElectricityPower grid cross-border (limited scope)Grid-dependentEUR/MWh equivalent
Downstream Impact: Indirect CBAM Pressure

Even if your company is not directly in a CBAM-regulated sector, you may face indirect CBAM pressure. EU OEMs in automotive, construction, and industrial equipment are increasingly requiring their Tier-1 and Tier-2 Malaysian suppliers to provide Scope 3 emission data and demonstrate decarbonization roadmaps. Companies that cannot provide verified emission data risk being de-listed from European supply chains.

CBAM Timeline: From Transition to the Definitive Period
PeriodStatusObligation for Malaysian Exporters
Oct 2023 – Dec 2025 TransitionalQuarterly embedded emission reporting (no financial penalties). EU importers submit reports.
Jan 2026 onwards ← NOWDefinitive periodOnly authorised CBAM declarants may import. Embedded emissions in 2026 imports must be covered by CBAM certificates, which are sold from 2027.
2026–2034 Ramping UpFree EU ETS allowances phased out — CBAM burden increases annually as EU ETS free allocation drops.
2034 onwards Full CBAMZero free EU ETS allowances — full CBAM cost on 100% of embedded emissions.

03How Solar Reduces Your CBAM Exposure

The embedded emissions in your products are calculated using your total greenhouse gas emissions divided by production output. Electricity from the TNB grid is the main source of Scope 2 emissions for most manufacturers. Solar electricity used on site displaces that grid electricity for the share of your load it covers — it has a lifecycle emission factor of approximately 20–40 gCO2e/kWh, versus 740 gCO2e/kWh for the Peninsular grid. Under the CBAM Regulation, indirect emissions from electricity count towards the CBAM charge only for cement and fertilisers; for iron and steel, aluminium and hydrogen only direct emissions are charged. For those sectors solar still lowers your electricity bill and Scope 2 footprint, but not the CBAM certificate cost itself.

Illustrative arithmetic: 500 kWp Solar on an Electricity-Intensive Plant (where indirect emissions are in scope)

Without Solar
Annual electricity from TNB grid2,400 MWh
Grid emission factor (Peninsular)0.740 tCO2e/MWh
Annual Scope 2 emissions1,776 tCO2e
Annual production output5,000 tonnes of product
Emission intensity (Scope 2 component)0.36 tCO2e/tonne
CBAM levy at full rate (EUR 60/tCO2e × 0.36)EUR 21.60/tonne
With 500 kWp Solar
Solar generation (annual)630,000 kWh
Grid electricity reduced to1,770 MWh
Scope 2 emissions (post-solar)1,310 tCO2e
Emission intensity (Scope 2 component)0.26 tCO2e/tonne
CBAM levy reduction per tonneEUR 5.59/tonne
Annual CBAM savings at full rate (466 tCO2e × EUR 60)EUR 27,960/yr
Total Annual CBAM Savings
EUR 27,960 × RM 5.10/EUR exchange rate
≈ RM 142,600/yr
additional to energy cost savings

Compounding value: As the EU ETS carbon price is projected to rise to EUR 80–100/tCO2e by 2028–2030, and as CBAM free allowances are phased out, the CBAM savings from solar become proportionally larger over time where indirect emissions are in scope. Carbon-price projections are estimates, not guarantees.

04RECs: Documenting Your Renewable Generation

Your solar generation can also be registered for Renewable Energy Certificates (RECs) through a recognised REC registry. Each REC represents 1 MWh of renewable generation and can be kept for your own market-based Scope 2 and ESG reporting, or sold. RECs are not carbon credits, and they do not by themselves change how CBAM calculates indirect emissions — confirm the treatment with your EU importer and its verifier.

Generate RECs

Register your solar system with a recognised REC registry. For every MWh generated, one REC can be issued.

1 REC per MWh
generated
Price & Market

REC prices vary by registry, buyer and contract. Ask the registry or buyer for current prices before counting on REC income.

Varies
by registry & buyer
Generation Data

A 1 MWp solar system generates roughly 1,260 MWh a year in this guide's example, so roughly 1,260 RECs. Trexon provides the monitored generation data.

~1,260
MWh per 1 MWp/year
Generation and Scope 2 Reduction by System Size
System SizeAnnual GenerationRECs/YearScope 2 Reduction (0.740 t/MWh)
200 kWp252 MWh252186 tCO2e
500 kWp630 MWh630466 tCO2e
1 MWp1,260 MWh1,260932 tCO2e
2 MWp2,520 MWh2,5201,865 tCO2e
5 MWp6,300 MWh6,3004,662 tCO2e

05ESG Reporting: Bursa Malaysia Sustainability Obligations

Bursa Malaysia has progressively strengthened sustainability reporting requirements for listed companies. As of 2026, Main Market listed companies must publish Climate-Related Disclosures aligned with TCFD (Task Force on Climate-related Financial Disclosures), including Scope 1, Scope 2, and material Scope 3 emissions.

Company CategoryDisclosure RequirementEffective DateSolar's Role
Main Market (Top 100 by market cap)TCFD-aligned climate-risk disclosures (check Bursa's current requirements)From FY2026 (phased)Reduces reported Scope 2 intensity; mandatory for investor credibility
Main Market (all others)Sustainability Statement (per Bursa's current requirements)Per Bursa timelineLower absolute Scope 2 figure improves ESG rating
ACE Market listedSustainability StatementComply-or-explainDemonstrates low-carbon trajectory to investors
Non-listed (EU supply chain)CBAM embedded emission reporting (via EU importer)Jan 2026 (active)Lower CBAM certificate cost where indirect emissions are in scope (cement, fertilisers)

RE100 Commitment

Joining RE100 (committing to 100% renewable electricity) provides powerful market differentiation. Trexon can size a phased rooftop solar plan and supply monitored generation data for your annual reporting.

Science-Based Targets (SBTi)

Many EU buyers now require suppliers to hold SBTi-aligned emission reduction targets. Monitored solar generation data supports your reported progress toward Scope 2 targets.

065-Step CBAM-Proof Your Factory Action Plan

Step 01Immediate

Map Your Embedded Emissions

Commission a Scope 1, 2, and 3 GHG inventory for your factory. Identify which production processes have the highest embedded emission intensity per tonne of output. This becomes your CBAM calculation baseline.

Engage an accredited carbon accountant or CBAM verifier.

Step 0230 days

Quantify Your CBAM Exposure

Based on your EU export volumes and embedded emission intensity, calculate annual CBAM certificate cost at current EU ETS price. This provides the financial justification for your decarbonization investment.

Use the formula: Annual Exports (tonnes) × Emission Intensity (tCO2e/tonne) × EUR 60/tCO2e × RM/EUR rate (this is the full-rate cost; the charge phases in until 2034).

Step 03Plan now

Deploy Industrial Solar (Priority: Scope 2)

Scope 2 emissions from electricity are usually the easiest to reduce. Rooftop solar displaces grid electricity for the share of your load it covers; how much depends on your roof and load profile. It lowers the CBAM certificate cost only where indirect emissions are in scope (cement, fertilisers).

Request a site assessment from Trexon Energy for the solar sizing and energy-cost savings case.

Step 04Post-commissioning

Consider RECs for ESG Reporting

Register your solar system with a recognised REC registry if RECs suit your ESG or customer reporting. Check with your EU importer and its verifier how (or whether) they are recognised for CBAM before relying on them.

Trexon provides the system generation data the registry asks for.

Step 05Quarterly

Provide Embedded Emission Reports to EU Buyers

Give your EU buyers accurate embedded emission data (including your electricity source data where indirect emissions are in scope). Without your actual data they may have to use default values, which are usually higher.

Trexon can export your solar system's monitored generation data for your emissions reporting.

Trade Policy Insight // Trexon Energy

“CBAM has permanently changed the calculus for Malaysian exporters. Carbon is no longer an externality — it has a price, enforced at the EU border. Factories that cut grid electricity use will lower their Scope 2 intensity; whether that lowers CBAM cost depends on the product sector. Worth modelling now.”

TE
Trexon Energy Advisory Team
CBAM-Ready Solar Strategy for Malaysian Exporters

07Frequently Asked Questions

Which Malaysian industries are most affected by EU CBAM in 2026?
The six sectors covered by CBAM are: (1) Iron and Steel, (2) Aluminium, (3) Cement, (4) Fertilizers, (5) Electricity, and (6) Hydrogen. Malaysian manufacturers in these sectors exporting to the EU are directly affected. Downstream industries supplying EU OEMs in automotive, construction, and industrial equipment face indirect pressure through supply chain ESG requirements.
How does solar energy reduce my CBAM exposure?
Solar electricity used on site displaces grid electricity, which has an emission factor of 0.740 tCO2e/MWh in Peninsular Malaysia (Suruhanjaya Tenaga, 2024 (provisional)). A 500 kWp solar system generating 630,000 kWh/year avoids about 466 tCO2e/year of Scope 2 emissions. Under the CBAM Regulation, indirect emissions from electricity count towards the CBAM charge only for cement and fertilisers; for iron and steel, aluminium and hydrogen only direct emissions are charged. Where indirect emissions are in scope, 466 tCO2e at EUR 60/tCO2e is about EUR 27,960 a year of CBAM certificate cost for your EU buyers.
What are RECs and how do they help with CBAM reporting?
Renewable Energy Certificates (RECs) are issued per MWh of renewable generation through a recognised registry and support market-based Scope 2 and ESG reporting. They do not by themselves change how CBAM calculates indirect emissions, which uses grid emission factors unless the electricity comes from a direct technical link or a qualifying power purchase agreement — confirm the treatment with your EU importer and its verifier.
Is CBAM reporting mandatory for Malaysian exporters right now?
Yes. The definitive period began on January 1, 2026: EU importers of CBAM-regulated goods must cover the embedded emissions of their 2026 imports with CBAM certificates, which are sold from 2027. Malaysian exporters who do not provide accurate embedded emission data face their EU buyers being charged at default (maximum) rates, increasing your product's landed cost in the EU and damaging price competitiveness.
What is Bursa Carbon Exchange and how do I sell RECs?
Bursa Carbon Exchange (BCX) is Bursa Malaysia's voluntary carbon market, launched in 2022–2023. RECs are issued through a recognised REC registry, one per MWh of renewable generation, and can be retained for ESG reporting or sold. Registration rules, fees and prices vary by registry and buyer, so check them with the registry directly; Trexon can provide your system's generation data.
Does solar alone make us fully CBAM-compliant?
No. CBAM covers the direct emissions of your production processes and of key precursor materials, and — for cement and fertilisers only — indirect emissions from electricity. Solar lowers only the electricity component, by the share of your load it covers. It is a practical, financeable step, but full CBAM reporting needs a complete embedded-emissions calculation.

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