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CBAM 2026: The Electricity Data Your EU Buyer Will Ask For


Carbon compliance · Malaysia

Malaysia now has an official number for CBAM. In a parliamentary reply published on 4 August 2026, the Ministry of Investment, Trade and Industry put the 2026 compliance cost for the country’s iron and steel industry at RM970.7 million, citing a Malaysian Steel Institute study. The year before, Malaysia shipped about 752,000 tonnes of steel to the European Union, worth RM3.23 billion — roughly an eighth of everything the sector exported.

Here is the part that catches most plant managers out. That bill is not calculated on your electricity. For iron and steel, aluminium, hydrogen and electricity, CBAM declares direct emissions only. The power your furnace draws does not enter the certificate calculation at all.

It will still be asked for.

CBAM-05-plant
01 · The clock

Four dates, and none of them is sailing day

The definitive period opened on 1 January 2026. Since then, EU importers of CBAM goods have been recording embedded emissions quarter by quarter. No money changes hands in 2026: certificate sales do not start until 1 February 2027, on the Common Central Platform. The first annual declaration, covering calendar 2026 imports, is due by 30 September 2027.

The certificate price tracks the EU ETS auction average. The Commission published €75.36 per tonne of CO2e for the first quarter of 2026 and €75.28 for the second; from 2027 the price moves to a weekly average. There is also a platform fee of €0.05 per certificate bought.

What keeps the 2026 bill small is not the price. It is the CBAM factor. Free allocation under the EU ETS still covers 97.5 per cent of the domestic equivalent this year, so only 2.5 per cent of the embedded emissions is actually charged. That factor rises to 48.5 per cent by 2030, and reaches 100 per cent on 1 January 2034. Any exporter reading the 2026 number as the size of the problem is reading the first step of a curve.

Sales open
1 Feb 2027
Certificates sold on the Common Central Platform
First declaration
30 Sep 2027
Covers all calendar 2026 imports
2026 price
€75.28 – 75.36
Per tonne CO2e, EU ETS quarterly average
Free allocation 2026
97.5 %
So the CBAM factor is only 2.5 %

A useful way to read that last figure. At published 2026 prices, 752,000 tonnes of blast-furnace steel would carry a certificate bill in the low millions of euro — so the RM970.7 million estimate is mostly monitoring, reporting, verification and the decarbonisation spending behind them. The data work is the expensive part, not the paperwork.

CBAM-01-timeline
02 · What is priced

CBAM splits emissions in two, and the split decides whose electricity matters

Direct emissions come from the production process itself: fuel burned inside the installation, process emissions, purchased heat and cooling, and the embedded emissions of any CBAM precursor that went into the product. Indirect emissions are the emissions from the electricity consumed in production.

Only two of the six covered sectors pay for both.

Sector
Direct emissions
Indirect (electricity)
Iron and steel
Priced
Not priced
Aluminium
Priced
Not priced
Hydrogen
Priced
Not priced
Electricity (as a good)
Priced
Not applicable
Cement
Priced
Priced
Fertilisers
Priced
Priced

Two consequences are worth writing down before anyone specifies equipment. The first is that a Malaysian steel plant’s own power consumption is not in its CBAM certificate obligation. The same is true for aluminium, which sits in Annex II of the regulation — so Press Metal’s hydropower advantage in Sarawak, however large in reality, currently produces no benefit inside the aluminium CBAM calculation.

The second is that the production route decides how much of this touches you at all. Steel Industry Roadmap 2035 gives representative intensities of about 2.33 tCO2 per tonne for the blast furnace and basic oxygen furnace route and about 0.68 for the electric arc furnace. Malaysia produced steel entirely through electric arc furnaces until 2014; by 2022, blast furnaces accounted for roughly 72 per cent of output. Since September 2025 the roadmap has barred new BF/BOF plants, so the installed mix is now the one the sector will live with.

CBAM-02-scope
03 · The default path

The expensive mistake is not mis-reporting. It is not reporting

A declarant may declare either verified actual emissions or default values. Defaults carry a mark-up: 10 per cent in 2026, 20 per cent in 2027, 30 per cent from 2028.

For Malaysia the default path is unusually punitive, and the reason is narrow enough to be missed. Implementing Regulation (EU) 2026/1740 lists Malaysia in its country-specific default tables for cement, fertilisers, aluminium and hydrogen — but the iron and steel block contains ferro-alloys only. Malaysian hot-rolled coil declared on defaults therefore falls back to the "other countries and territories" value of 4.049 tCO2e per tonne on a BF/BOF benchmark route, before the 10 per cent mark-up.

Declaration route
What you declare
What it costs you
Verified actual data
Measured at your installation
No mark-up — but you must hold the raw records
Default values, 2026
4.049 tCO2e/t, generic route
Plus a 10 % mark-up
Default values, 2028 onward
Same fallback value
Plus a 30 % mark-up

Run those official parameters through a default-path calculation and the residual liability lands at roughly 3.1 tCO2e per tonne of coil in 2026 — about €235 a tonne at the first-quarter certificate price. That number measures nothing about how clean your furnace is. It is the price of having no measured data to hand over.

Getting off the default path takes one thing: installation-level data a verifier will accept, with the raw records behind it and a reporting period that can be reconstructed. That is a metering question before it is a reporting question.

CBAM-03-default
04 · Who asks

Three parties will ask, and none of them is the certificate

Your buyer’s own report
EU importers report supply-chain emissions and calculate product carbon footprints for their customers. Those calculations normally include purchased electricity. A plant drawing 20 GWh a year on the Peninsular grid carries about 14,800 tonnes of CO2e from power alone. None of it reaches a CBAM certificate for steel. All of it reaches a document your buyer signs, with your name on it.
Kuala Lumpur, not Brussels
MITI’s response to the mechanism centres on a carbon Measurement, Reporting and Verification (MRV) system for the steel industry, alongside energy efficiency and renewable energy. An MRV that has to run every year needs metered data at process level. Estimates fail the first time somebody asks to see the basis.
EECA 2024, at home
The domestic obligation is already in force: installations above 21,600 GJ a year appoint a registered energy manager, run an energy management system and face an audit cycle. We have written about what that reporting needs before. The same process-level data serves both filings.
Region
Grid factor, 2024
What it means for a product carbon footprint
Peninsular Malaysia
0.740 kg CO2e/kWh
Where most Malaysian steel and manufacturing load sits
Sabah
0.539 kg CO2e/kWh
Lower, but still fossil-heavy
Sarawak (hydropower)
0.199 kg CO2e/kWh
A factor of 3.7 lower than the Peninsula — worth proving, if you can

Which factor your buyer applies to your product depends on what you can prove about where your power came from, and when. That proof is a metered, time-stamped record — not a statement.

CBAM-04-grid
05 · Metering points

Where the meters go

Every filing above needs the same shape of number: energy per process, over a defined period, traceable to a reading. Four metering positions produce it.

Where
Device
What it answers
Incoming supply
APM521 panel meter
The boundary the monitoring plan is written around
Process feeders and lines
ADL3000-E three-phase meter
Energy per process — the denominator behind any per-tonne figure
PV or storage connection
ADL400N-CT bidirectional meter
Which kilowatt-hours were yours, and which were bought
Record, organise, export
Acrel IoT EMS cloud platform
One dataset, held by reporting period and exportable

The ADL3000-E is a DIN-rail three-phase meter for low-voltage distribution: active energy Class 0.5S, reactive Class 2, voltage and current harmonics from the 2nd to the 31st, four tariff rates, frozen data, and RS485 Modbus-RTU into the EMS or SCADA you already run. It is the part that turns a plant total into a per-line number.

The ADL400N-CT covers the position that decides the grid-factor argument. It measures forward and reverse active and reactive energy through split-core coils — 80 A, 120 A, 200 A or 300 A — on a 35 mm rail, with CE, MID, UL and RoHS behind it. Where a plant has its own generation, that bidirectional record is what separates self-generated kilowatt-hours from purchased ones.

Accuracy
Class 0.5S
ADL3000-E active energy; reactive Class 2
Measurement
U, I, P, Q, S, PF, F
Plus 2nd–31st voltage and current harmonics
Bidirectional
Forward & reverse
ADL400N-CT active and reactive, split-phase
Certificates
CE, MID, UL, RoHS
ADL400N-CT energy metering, per certificate on file

One boundary worth stating plainly. We do electrical measurement. Fuel, steam and process-mass data — the inputs that carry most of a blast furnace’s direct emissions — come from instrumentation we do not make, and a CBAM monitoring plan needs those too. What sub-metering supplies is the electricity half, and the platform to hold it next to whatever else your verifier asks for.

06 · Next two quarters

What to do before February 2027

Phase 1
Define the boundary
Write down the installation, the CN codes produced, and which processes sit inside each. Everything downstream depends on this line being drawn once, and consistently.
Phase 2
Meter the processes
Start with the incoming supply and the three to five lines that carry the bulk of the load. A mid-sized aluminium plant that did this properly ended up with 332 meters across its shops — not because someone over-specified, but because "energy per tonne" is not answerable from a single incomer.
Phase 3
Hold it by period
Set the platform to store by day, month and year per circuit and export to a spreadsheet, so a verifier can be handed a reporting period rather than a screenshot.
CBAM-06-switchroom
07 · Questions

Questions we are asked

Q: Does CBAM require my electricity data?
Not for steel or aluminium. Only direct emissions are declared for those sectors; indirect emissions are priced for cement and fertilisers. What will ask for your electricity data is your buyer’s product carbon footprint, Malaysia’s carbon MRV, and EECA 2024.
Q: Then why meter electricity at all?
Because the alternative to measured data is default values, and defaults are marked up — 10 per cent in 2026, 20 per cent in 2027, 30 per cent from 2028. Malaysian hot-rolled coil has no country-specific default at all, so it falls back to a value that has nothing to do with your plant.
Q: Can you calculate my carbon emissions?
No. We meter and record energy. The conversion to CO2e belongs to your verifier or your carbon accountant, using the factor that applies to your grid and your reporting period. What we supply is the defensible input: metered kilowatt-hours per process, held by period, with the raw records behind them.
Q: Do we have to replace the TNB meter?
No. The utility meter and the bill remain the official reference for what you purchased. Sub-metering explains how that purchased energy was distributed inside the plant, which is the part the bill cannot show.
Q: Where should the first meters go?
On the incoming supply, and on the lines that carry the load you would be asked about — melting, rolling, finishing, compressed air, and any on-site generation. Start from what your buyer is likely to question, not from what is easiest to reach.
Next step
Send us your process list, the incoming current on each line, and whether you have on-site generation.
We will come back with the metering points, the CT sizes, and how to hold the data by reporting period so a verifier can use it.

Post time: Sep-30-2026