Carbon Trade Gateway
Incorporation in progress · India
CBAM Embedded Emissions Compliance Platform for Indian Steel Exporters

What Carbon Trade Gateway Does

Carbon Trade Gateway is a compliance SaaS platform that collects installation-level production and fuel data from third-country operators of iron and steel installations, computes their specific embedded emissions in accordance with the methodology prescribed in Commission Implementing Regulation (EU) 2025/2547, and produces a complete, verification-ready documentation package enabling the Authorised CBAM Declarant to fulfil their declaration obligations under Article 6 of Regulation (EU) 2023/956.

The platform's primary output is the 'Verifier's Package', a structured documentation bundle formatted to the taxonomy defined in Commission Delegated Regulation (EU) 2025/2546, Annex II, Sections 2.3–2.10. Every data element collected, every calculation performed, and every document generated is organised around the verification workflow, not the operator's convenience. The objective is zero additional documentation requests from the accredited verifier. The platform also generates a 'Emissions Communication Summary Report' structured to the EC Installation Communication Template published under Commission Implementing Regulation (EU) 2025/2547.

What CBAM Costs Indian Steel Exporters

The Mechanism

Under Article 22 of Regulation (EU) 2023/956, EU importers of iron and steel goods must hold CBAM certificates equal to the embedded emissions in every tonne imported. A 1,000-tonne shipment of hot-rolled coil carrying 1.85 tCO₂/t SEE generates a CBAM certificate obligation of 1,850 certificates. At the current EU ETS carbon price of approximately €65 per certificate, the importer's liability is approximately €1,20,250 per shipment, passed back to the exporter as a deduction from the contract price.

The Default Value Penalty

Operators who cannot produce verified actual monitoring data are permitted under EU Regulation 2025/2621 to use published default values. However, default values carry a mandatory mark-up penalty: 10% above the sector benchmark in 2026, rising to 20% in 2027 and 30% from 2028 onward. For a mid-size Indian EAF exporter shipping 10,000 tonnes per quarter, the difference between actual monitored data and the penalised default value typically represents ₹18–42 lakh in additional CBAM certificate cost per quarter, compounding every year the operator delays measurement.

The Submission Deadline

Under Article 6 of Regulation (EU) 2023/956, the Authorised CBAM Declarant must file a CBAM declaration by 31 May following each calendar year. A missing or rejected embedded emissions report from the Indian exporter prevents that filing. The EU importer's penalty for a missing declaration is €10–50 per tonne of unreported emissions under Article 26 of the CBAM Regulation, a direct financial consequence passed to the exporter through contract penalty clauses.

What the Platform Does Today

Stated plainly. Scoped to v0.1 steel sector.

DATA COLLECTION
Guided monthly data entry for fuel consumption, process inputs, electricity use, and production volumes per CN code, per installation.
SEE CALCULATION
Specific Embedded Emissions computed per CN code using the full EU 2025/2547 methodology, direct (combustion + process + waste gas) and indirect (electricity, BEE state-grid EF).
FAA COMPUTATION
Free Allocation Adjustment computed using benchmark values from EU 2025/2620, differentiated by production route, Column A/B, alloy grade, and reporting period.
VERIFIER'S PACKAGE
Five-document output bundle: Monitoring Plan, Installation Description, Emissions Report, Production Summary, EU Importer Summary structured to EU 2025/2546 Annex II taxonomy.
OVERPAYMENT CALCULATOR
Rupee-denominated calculation of the financial cost of using default values versus actual monitored data, surfaced to the operator in the platform UI.
CN CODE ENGINE
Automatic classification of 8-digit CN codes to aggregated goods category, grade family, and complexity flag, eliminating manual misclassification risk.
DEFAULT VALUE OVERRIDE ALERT
Automatic flag when operator-submitted data would default to penalised values, with rupee-denominated cost of delay surfaced before submission.
MULTI-TENANT ISOLATION
Each installation's data is logically isolated at the database row level with enforced tenant context, no cross-contamination of emissions data between customers.
AUDIT TRAIL
Append-only submission and payment event logs with SHA-256 document content hashing, immutable record for verifier and regulator review.

Which EU Regulations We Implement

The platform's calculation engine, output documents, and verification workflow are grounded in the following EU legal instruments, cited by article and annex. This is not general ESG reporting. Every formula, every document field, and every data element maps to a specific provision.

EU 2023/956
The CBAM Regulation. Articles 3–6 (definitions, scope and annual declaration obligation), Article 22 (CBAM certificate obligation), Article 35 (Authorised CBAM Declarant reporting duty), Article 26 (penalties). This is the parent legal instrument.
EU 2025/2547
Commission Implementing Regulation — Calculation Methodology. Direct and indirect emissions equations, Annex II system boundaries by production route, Annex III SEE attribution equations (Eq. 55–63), Annex VIII default emission factors and NCVs. The platform's calculation engine implements this regulation in full.
EU 2025/2620
Commission Implementing Regulation — Free Allocation Adjustment. Benchmark values (BMg) by CN code, production route, Column A/B integration level, alloy grade, and time period. The platform's FAA computation uses the Annex table directly.
EU 2025/2621
Commission Implementing Regulation — Default Values. Country-specific and global default embedded emissions values. The platform uses these to compute the mandatory mark-up penalty (10%/20%/30%) and the operator's overpayment exposure in rupees.
EU 2025/2551
Commission Delegated Regulation — Verifier Accreditation and Document Taxonomy. Annex II Sections 2.3–2.10 define the required document set. The platform's Verifier's Package output is structured to this exact taxonomy.
EU 2025/2546
Commission Delegated Regulation — Verification Principles. The 5% materiality threshold and verification report template. The platform's emissions report format is designed to enable verifier sign-off with minimal additional requests.
Sagar Pujari
Sagar Pujari
Founder & CEO, Carbon Trade Gateway

Sagar holds a Bachelor's degree in Electronics and Telecommunication Engineering and has built his professional practice at the intersection of cybersecurity, regulatory compliance, and software engineering. His compliance work has included hands-on implementation and advisory engagements to ISO/IEC 15408-1, the Common Criteria and EAL evaluation methodologies for information technology security, a standard that demands the same structured, evidence-based approach to system verification that CBAM reporting now demands of Indian exporters. That disciplinary foundation informs how CTG is built: as a system designed for audit, not convenience.

CTG did not emerge from a market thesis. It emerged from reading Regulation (EU) 2023/956 and its implementing acts in full, and recognising that the compliance obligation they impose on third-country operators is a precise engineering problem, not a reporting exercise. The calculation methodology defined in Commission Implementing Regulation (EU) 2025/2547 runs to sixty-three equations across eight annexes. That gap was the starting point.

CBAM is not a disclosure exercise where approximation is acceptable. A miscalculated Specific Embedded Emissions value, an incorrect emission factor, or a missing source stream in the operator's report translates directly into a financial penalty for the EU importer, and through contract terms, back to the Indian exporter. That is not a compliance failure. That is an engineering failure, and it is the founder's responsibility to ensure it does not happen. The standard CTG holds itself to is therefore the same standard the regulation imposes: calculation accuracy traceable to a cited equation, documentation complete enough for a trained verifier to sign without a second request, and an audit trail immutable from the moment data is entered. That standard is not the easiest position to build from. It is the only position that is defensible when an EU customs authority reviews a declaration. A platform that ships approximations is not a compliance tool. It is a liability dressed as one.

Speak with the Founding Team

If you are an EU steel importer, an Export Promotion Council official, or an accredited CBAM verifier evaluating compliance tooling, use the form below.

sagar.pujari@carbontradegateway.com