CBAM (EU) + Thailand Carbon Tax Compliance
CBAM (EU) + Thailand Carbon Tax Compliance · § CrossBorder
What to know before you act
Thai exporters of steel, aluminium, fertiliser, cement, hydrogen or electricity to the EU must supply embedded-emissions data to EU importers under CBAM, while Thailand develops its own carbon pricing. We handle contracts and law — sales terms allocating data duties and cost burden, confidentiality for production data, and tracking Thai developments; emissions calculation needs specialist verifiers.
Timing and external dependencies: CBAM phases and scope follow EU announcements; prepare contracts before the next export cycle.
Official fee: CBAM financial obligations fall on EU importers — check current rules with official EU sources.
Timing is not a promise of an outcome or hearing date. Check the notice, limitation period and current authority rules for your matter.
What to send for the first review
Send every relevant page, a dated sequence of events, any hearing or filing deadline, and the outcome you need. This lets counsel identify urgent steps, missing evidence and a precise scope of work.
- Product carbon footprint (PCF) per ISO 14067 or EU CBAM methodology
- Energy consumption + emission factor per production line
- Monthly production volume per CN code (8-digit)
Legal Basis
EU Regulation 2023/956 (CBAM) — transitional 1 Oct 2023 – 31 Dec 2025 (report only) · definitive 1 Jan 2026 (buy CBAM certificates) · covers steel, aluminium, cement, fertiliser, electricity, hydrogen · Thai Climate Change Act (draft) — expected Q1/2026 · ETS + carbon tax the official rate/tCO₂e from 2026 · US CCA (pending).
📚 Official sources — check the current law and procedure before acting
- กรมสรรพากร— The Revenue Department
- กรมที่ดิน— Department of Lands
- องค์การบริหารจัดการก๊าซเรือนกระจก (อบก.)— Thailand Greenhouse Gas Management Organization
- สำนักงานคณะกรรมการกฤษฎีกา — ตัวบทกฎหมายฉบับทางการ— Office of the Council of State
Who Needs This
Thai exporters of steel/aluminium/cement/fertiliser/hydrogen to EU · smelters · cement plants on SET (SCG, TPI) · downstream users of carbon-intensive EU inputs · SME suppliers of EU importers.
Required Documents
- Product carbon footprint (PCF) per ISO 14067 or EU CBAM methodology
- Energy consumption + emission factor per production line
- Monthly production volume per CN code (8-digit)
- Invoice + BL to EU + EU importer EORI number
- Carbon price paid in Thailand (retired T-VERs) — 1:1 deductible.
Common Pitfalls
- Sharing production data without confidentiality terms
- Accepting all carbon cost in contracts without assessing impact
- Relying on default values that overstate cost
Typical Use-cases
- SCG cement to Netherlands · 20,000 t/mo · CBAM cost €1.4M/mo from 2026
- Sahaviriya steel billet to EU · verified PCF cuts CBAM 40%
- Aluminium wheel OEM to Germany · Scope 3 for BMW ESG report
- Thai Central Chemical fertiliser to Poland · CBAM report Q1/2026.
FAQ
- Do small exporters need to comply?
- Depends on EU thresholds in each phase; importers usually request data anyway.
- Does Thailand have a carbon tax yet?
- It is being developed — check current status with the Excise Department and relevant agencies.
- Do documents need English translation?
- Importers usually want English; our certified translators can help.
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Official sources — accounting, tax, social security
The information on this page follows the official sources below. Always check the latest version before you file.
- Revenue Department — Revenue Code, income tax, VAT— Revenue Department
- Social Security Office— Social Security Office
- Department of Business Development — company registration— Department of Business Development
- Office of the Council of State — Thai law database— Office of the Council of State
- Board of Investment (BOI) / LTR Visa— Thailand Board of Investment
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Frequently asked questions
- Can a foreigner own 100% of a Thai company?
- Generally no for activities listed in the Foreign Business Act, where majority foreign ownership requires a Foreign Business Licence, a BOI promotion, or treaty rights such as the US–Thailand Treaty of Amity. Manufacturing and certain export activities are largely open, and BOI-promoted activities can permit full foreign ownership together with land-holding and visa privileges, so the right structure depends on the specific activity.
- What is the minimum registered capital for a Thai company?
- There is no general statutory minimum for a Thai-majority company, but practical thresholds apply: a fee quoted after review million of paid-up registered capital per foreign work permit, or a fee quoted after review million if the foreigner is married to a Thai national, and a fee quoted after review million per foreign shareholder for a Foreign Business Licence. Capital should therefore be planned around the visa and work-permit outcome you need, not the incorporation minimum.
- How long does company registration take?
- Registration at the Department of Business Development can be completed within one to three working days once the name reservation, shareholder documents and company objectives are ready, and the VAT registration and social security registration follow afterwards. The realistic end-to-end timeline including bank account opening is two to six weeks, with the bank account usually being the slowest step for foreign directors.
- What ongoing accounting obligations does a Thai company have?
- Every Thai company must keep statutory accounts, file monthly withholding tax (PND 1, 3, 53) and VAT (PP 30) returns by the middle of the following month, file the half-year corporate income tax return (PND 51) and the annual return (PND 50), and have its financial statements audited by a Thai CPA and filed with the DBD each year. Dormant companies are not exempt — nil returns and an audited statement are still required.