Poland and Romania together accounted for 10.3% of the EU’s 2025 extra-EU imports under current Carbon Border Adjustment Mechanism (CBAM) codes, equivalent to roughly 11.5 billion euros based on rounded Eurostat-derived country shares. Poland represented 6.1% of those imports and Romania 4.2%.
The countries sit at the intersection of European industrial production, eastern supply routes and cross-border electricity trade. Both combine direct demand for imported materials with supply to wider European value chains. Steel and aluminium serve construction, machinery, household appliances, automotive components and metal fabrication; fertilisers serve agricultural markets, while electricity imports have a distinct commercial and regulatory profile.
Customs data and supply-chain exposure
Customs figures do not necessarily reflect final industrial consumption. Goods can enter through neighbouring EU member states before reaching Polish or Romanian factories, while shipments cleared locally may be distributed onward. Import routes therefore matter when assessing where CBAM-related exposure sits across supply chains.
A contractor buying steel from a regional warehouse could face a carbon-related cost indirectly without having a CBAM certificate obligation. Importers serving multiple customers need an auditable method to assign imported quantities and associated emissions evidence. Buyers comparing lower-priced material from a higher-emissions plant with costlier material backed by credible verified data need to assess landed cost and contracting risk.
For investors, the question is whether Poland and Romania can use CBAM to encourage better supply quality and environmental data without undermining manufacturing competitiveness. The analytical objective is to distinguish direct customs liability from wider supply-chain exposure across eastern Europe’s industrial markets.
Country-level routes and proposed scope
Country-level investigation should identify leading CN8 items and origins, then examine importers, processors, distributors and buyers in manufacturing clusters. Poland warrants close attention to high-volume metal processing and fertiliser distribution.
Romania is an EU neighbour to Serbia and other Energy Community markets. Its position makes electricity-import evidence and carbon-price exposure particularly relevant, with separate scrutiny warranted for electricity and industrial feedstock routes from the Western Balkans.
The EU has proposed expanding CBAM’s downstream scope to selected manufactured products. Their treatment could change from 2028 if the proposal is adopted.