Selling to the EU from Malaysia

No, not in force. Talks have been under way and the EU has been actively advancing agreements across ASEAN, but nothing applies today. Your goods pay the ordinary tariff. That makes the customs code and the origin rules more, not less, important; there is no agreement to fall back on.

Directly. Palm oil is on the EUDR list: geolocation of the plantation plots, proof of no deforestation after 31 December 2020, and a due diligence statement before customs. Delayed to 30 December 2026 for large operators; but the plot data collection must start now.

Yes: GPSR applies to consumer electronics regardless of the product's technical complexity. The Responsible Person must be established inside the EU; a Malaysian company cannot take the role.

Medical devices have their own regime (MDR 2017/745, and IVDR 2017/746 for diagnostics); with authorised representative requirements, notified-body involvement for higher-risk classes, and UDI registration. GPSR sits on top as the general safety net; the sector rules are stricter.

Rubber is one of the seven commodities named in Regulation (EU) 2023/1115, alongside cattle, cocoa, coffee, oil palm, soya and wood, so it carries the same duties as palm oil does. Whether a particular article is caught is decided by its HS code in Annex I, which covers derived rubber products as well as the raw material; look your own code up in the current Annex rather than in a summary of it. What the EU operator needs from you is identical in both cases: the geolocation of the plots the rubber was tapped on, the production period, and evidence that the land was not deforested after 31 December 2020. He files the due diligence statement before customs and he cannot file it without that data.

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.

The provider list or ask for three introductions.