Selling to the EU from India

Not in force. Negotiations were concluded on 27 January 2026 and the agreement now has to be signed, obtain the consent of the European Parliament and be ratified on the Indian side. Until it applies, your goods pay the ordinary tariff or, where eligible, the GSP rate. Because there is no preference to claim yet, the customs classification decides your duty entirely; which makes getting the code right the single largest lever on landed cost.

Yes. Selling to EU consumers from outside the EU means the Responsible Person cannot be you or your Indian company; it must be an economic operator established in the EU. Most sellers from India appoint a paid Responsible Person service for this, usually for an annual fee per catalogue.

No: those cover India's side of the export. The EU checks something else entirely: whether a Responsible Person with a reachable address inside the EU is recorded for your product. Indian export registrations do nothing for EU requirements; two separate files, both needed.

Most likely because no valid EU Responsible Person is recorded against the listing. Amazon and other marketplaces have been enforcing this since 2025 and suspend listings that lack it; regardless of whether the product itself is safe. What the marketplace checks is the listing data, not your paperwork.

No: the most common mistake. A CE marking says something about conformity; it says nothing about whether a Responsible Person exists with a reachable EU address. They are two separate requirements, and marketplaces check both.

The name and contact address of both the manufacturer and the Responsible Person, plus something that identifies the specific product; a type, batch or serial number. Warnings and safety information must be in the language of every country you sell into. An English-only label is generally not compliant for most EU markets.

No: per-order shipping is still selling to EU consumers from outside the EU. You still need a Responsible Person with a physical EU address, documentation held for ten years, and labelling in the right languages; per product, from every supplier you use.

Coffee, rubber and wood are three of the seven commodities named in Regulation (EU) 2023/1115, so yes, and the work is the same for each: the geolocation of the plots the material came from, the production period, evidence that the land was not deforested after 31 December 2020, and a due diligence statement filed by the EU operator before customs. Indian coffee is the awkward case, because most of it comes from small holdings that pool through curers and traders, and the plot identity is normally lost at that first pooling step. Which articles are caught is decided by the HS codes in Annex I; check your own code against the current text. Dates: 30 December 2026 for large and medium operators, 30 June 2027 for micro and small enterprises.

The obligation sits with the authorised CBAM declarant, not with you, but the data has to come from you. That declarant is the importer established in a member state; where the importer is established outside the EU it is his indirect customs representative. The definitive regime applies from 1 January 2026.

Threshold. He is exempt for as long as the net mass he imports in a calendar year, added up over iron and steel, aluminium, cement and fertilisers, does not pass 50 tonnes (Article 2a, with the figure in Annex VII, point 1). Once he passes it in a calendar year, the obligations apply to the embedded emissions of that whole year. The threshold counts per importer, not per shipment and not per supplier. It does not apply to hydrogen or to electricity (Article 2a(4)): for those he is in scope from the first consignment, however small.

Authorisation. The goods may only be released for free circulation by an authorised CBAM declarant, or by his indirect customs representative (Article 4; application under Article 5). Transitional rule: where the application is submitted by 31 March 2026, he may keep importing during 2026 for as long as the competent authority has not decided. If it is refused afterwards, a penalty follows on the emissions imported in the meantime.

Certificates. There are no CBAM certificates on sale in 2026. Sales start on 1 February 2027 (Article 20(1)). For import year 2026 the CBAM declaration is filed and the certificates are surrendered by 30 September 2027 (Article 22). The cost counts in his margin from 2026, but the cash leaves in 2027.

What he will ask you for. Which goods are in scope is decided by the CN code in Annex I: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. For those he chooses how the embedded emissions are determined: from the actual emissions of the installation, or from default values (Article 7(2)). He is not required to ask you first, and not required to show that actual data cannot be obtained. It is a cost calculation, not a penalty. Default values are set at the average emission intensity of the exporting country, raised by a mark-up fixed in implementing acts; where reliable data for the exporting country is missing, the average emission intensity of the ten exporting countries with the highest emission intensity is used instead. Against that, only actual emissions have to be checked by an accredited verifier (Article 8(1)), so working from default values saves him that verification. Your figures are worth buying when your installation is cleaner than the country average plus mark-up by more than the verification costs; for an installation dirtier than that average, the default value can be the better deal for him.

Wood packaging. Under Regulation (EU) 2016/2031, the plant health law, wooden pallets, crates, cases, drums and dunnage arriving from outside the EU have to be heat treated or fumigated to the ISPM 15 standard and carry the ISPM 15 mark: the IPPC logo, the country code, the code of the treatment provider and the treatment code, burned or stencilled into the wood in a frame. It has nothing to do with what is inside the box, which is why it surprises people: a perfectly compliant product is refused entry, or held at the importer's cost, over the crate it travelled in. Packaging made entirely of processed wood such as plywood, particle board or OSB is outside it. Inspect the mark on the pallets your forwarder supplies before loading, not after; an unmarked pallet found at the border is a problem you cannot fix from another continent.

Companies that act as your Responsible Person in the EU for an annual fee, including for sellers who stay outside the EU entirely. The provider list on the main page says who they are and what each covers; editorial and unpaid. Or ask us to introduce you to three.