CBAM and Thailand: What Thai Aluminium, Steel and Petrochemical Exporters Must Do
Thailand faces full CBAM exposure with no domestic carbon pricing currently eligible for CBAM deduction. Thai aluminium, steel, and petrochemical exporters into the EU face CBAM certificate liability from Q1 2026. The Thailand Greenhouse Gas Management Organisation (TGO) is developing a carbon pricing instrument but it is not yet operational and not yet recognised under Article 9 of Regulation 2023/956.
Thailand CBAM Exposure by Sector
| Sector | Key companies / installations | EU export volume | Estimated annual CBAM liability at default |
|---|---|---|---|
| Aluminium | Indorama Ventures (downstream), regional smelter imports for re-export | 50,000–150,000 t/year (re-export significant) | EUR 40–122M |
| Steel (rebar, sections) | Sahaviriya Steel, G Steel, Tata Steel Thailand | 100,000–250,000 t/year | EUR 14–36M |
| Fertilisers (urea, ammonium phosphate) | Thai Central Chemical, NFC, IRPC | 200,000–500,000 t/year | EUR 30–76M |
| Cement clinker | Siam Cement Group (SCG), TPI Polene | 300,000–800,000 t/year | EUR 16–43M |
Thailand's Grid Emission Factor
Thailand's national grid emission factor is approximately 0.42 tCO2/MWh — significantly lower than India (0.82) or Indonesia (0.85). This favours electricity-intensive sectors like aluminium downstream processing and EAF steel where actual values are documented. Renewable share of the grid is rising as Thailand pursues its 2050 net-zero target — actual values calculated today should be re-verified annually as the grid factor falls.
The Re-Export Question
Thailand is a major aluminium re-export hub: aluminium imported from Bahrain, Malaysia, and the Middle East is processed in Thailand and re-exported as fabricated products to the EU. CBAM applies to the embedded carbon of the original primary smelter, not the Thai processor. This means Thai re-exporters need verified embedded carbon data from their upstream smelter source — and the smelter's data needs to follow the supply chain into the Thai exporter's declaration. See the aluminium sector page for the primary vs secondary distinction.
Frequently Asked Questions
Does Thailand have a carbon price eligible for CBAM deduction?
No. Thailand does not currently have a national carbon tax or operational ETS eligible for CBAM Article 9 deduction. The TGO is developing a carbon pricing instrument but it is not yet recognised by the EU Commission as eligible for deduction.
What is Thailand's total annual CBAM exposure?
Estimated at EUR 100–280M annually across aluminium, steel, fertilisers, and cement clinker — based on current export volumes and EU default values.
Which Thai companies face the highest CBAM exposure?
SCG (cement and chemicals), Indorama Ventures (downstream aluminium and PET), Sahaviriya Steel, and the major fertiliser producers (Thai Central Chemical, NFC). Re-export operators handling primary aluminium for fabrication also face significant exposure.
Does CBAM apply to Thai aluminium re-exports?
Yes. CBAM applies to the embedded carbon of the original primary smelter, not to the Thai processor. Thai re-exporters need verified embedded carbon data from their upstream smelter source.
Where can Thai manufacturers find ISO 14065 accredited CBAM verifiers?
Thai manufacturers typically use NABCB (India), TÜRKAK (Türkiye), or international ISO 14065 accredited firms. See the verifier directory for the global list.
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