Amachains OrdeThe problem: the data sits in a Brazilian plant
Under the definitive CBAM regime (Regulation (EU) 2023/956, in force since January 2026) the EU importer declares the embedded emissions of every good. But those emissions can only be measured inside the installation that made the good. Without that data, the importer falls back on the Commission's default values plus a mark-up — and pays for carbon the product may never have emitted.
Why actual data favours Brazilian goods
| Reporting year | Mark-up on the default value |
|---|---|
| 2026 | +10% (cement, iron and steel, aluminium, hydrogen) · +1% (fertilisers) |
| 2027 | +20% |
| 2028 onwards | +30% |
Defaults (Implementing Regulation (EU) 2025/2621) are set to reflect poorly performing installations. Brazil's grid emits around 0.1 t CO₂ per MWh, a fraction of coal-based grids, so indirect emissions measured at a Brazilian plant tend to land well below the default.
Most exposed Brazilian sectors
- Iron and steel — steelworks, forges and foundries exporting goods under CN chapters 72 and 73.
- Aluminium — primary and processed (chapter 76).
- Fertilisers — nitrogen fertilisers and ammonia.
- Hydrogen — relevant to Brazil's green hydrogen projects.
The exact CN code decides. Other articles of iron or steel under CN 7326 are in scope; cast articles of iron under CN 7325 are not.
What Amachains Orde delivers
Amachains Orde is a Brazilian carbon footprint and production traceability platform with a full CBAM module. The Brazilian producer runs it; the EU importer receives the output:
- Embedded emissions from real production data — direct (fuels and process emissions) and indirect (electricity) SEE, each line with formula, factors, provenance and the production entries it summed. A missing factor is a blocking issue, never a silent zero.
- Precursors traced by batch — which precursor lot went into which product lot. When the steel supplier also uses Orde, its frozen declaration is shared directly instead of falling back to a default.
- Frozen, versioned declarations — each version carries a SHA-256 hash of its content; any change creates a new version.
- The Commission's own Communication Template — the official workbook, opened and filled in, plus an
ORDE_Tracesheet in English with the declaration id, version, hash and calculation steps. - O3CI transcription sheet — the O3CI portal takes no file upload, so Orde prints every field in the portal's order, units and character set.
- Verification-ready audit package — template, calculation trail PDF, production entries, emission factors and a manifest with file hashes, plus time-limited link access for the accredited verifier to record their opinion. Orde does not verify its own figures.
- Actual vs. default comparison — the measured SEE against the official default for the same country and CN code, with the mark-up for the reporting year.
Buying CBAM goods from Brazil?
Point your supplier to Amachains Orde: real production data in, the official Communication Template out.
Frequently asked questions
How can an EU importer get actual emissions from a Brazilian supplier?
The supplier calculates the SEE of each good from its own production data and communicates it in the Commission's Communication Template. Orde produces that template, filled in, with a calculation trail and a frozen, hashed declaration behind it.
Why are actual emissions usually lower than defaults for Brazil?
Defaults reflect poorly performing plants and carry a 10–30% mark-up. Brazil's grid factor is around 0.1 t CO₂/MWh, so measured indirect emissions tend to be much lower.
Which Brazilian sectors are most exposed?
Iron and steel, aluminium and nitrogen fertilisers. Scope depends on the exact CN code in Annex I of Regulation (EU) 2023/956.
Does Orde verify the emissions?
No. It is verification-ready: it hands the accredited verifier an audit package and a time-limited link to record their opinion.
Can the importer see how the figure was built?
Yes. Every line breaks down into formula, factors, provenance and production entries, and the exported template carries an English trace sheet.
Informational content maintained by Amachains, updated September 2026. Not legal or regulatory advice; always check the current text of Regulation (EU) 2023/956 and its implementing acts. Portuguese version: Guia CBAM para exportadores brasileiros.