CBAM and Vietnam: What Vietnamese Steel, Aluminium and Fertiliser Exporters Must Do
Vietnam is a fast-growing exporter into the EU across CBAM-covered sectors — particularly steel from Hoa Phat and Formosa Ha Tinh, aluminium from emerging downstream processors, and fertilisers from PVFCCo, PVCFC, and DAP-Vinachem. Vietnam does not have a national carbon price currently eligible for CBAM Article 9 deduction. The Vietnamese ETS is in pilot phase but is not yet operational at scale.
Vietnam CBAM Exposure by Sector
| Sector | Key companies / installations | EU export volume | Estimated annual CBAM liability at default |
|---|---|---|---|
| Steel (BF-BOF integrated) | Hoa Phat (Dung Quat, Hai Duong), Formosa Ha Tinh, Pomina | 500,000–1,500,000 t/year (rising) | EUR 71–214M |
| Steel (rebar, sections, EAF) | Vinakyoei, VAS, Pomina, Tung Ho | 300,000–600,000 t/year | EUR 14–28M |
| Aluminium (downstream) | Hoa Phat Aluminium, Tan A Dai Thanh | 50,000–150,000 t/year | EUR 40–122M |
| Fertilisers (urea, NPK) | PVFCCo (Phu My), PVCFC (Ca Mau), Vinachem subsidiaries | 300,000–700,000 t/year | EUR 46–106M |
Hoa Phat Dung Quat — Vietnam's CBAM Centre of Gravity
Hoa Phat's Dung Quat integrated steel complex is Vietnam's largest single CBAM-exposed installation. As an integrated BF-BOF site, the actual embedded carbon is close to global BF-BOF averages (1.85–2.20 tCO2/t) — meaning the saving from documenting actual versus default is small per-tonne but very large in absolute terms given the volume. For Hoa Phat, the more important play is investment in DRI-EAF and grid decarbonisation that will lower actual values over time. The vault record needs to be re-verified annually as those investments come online.
Vietnam's Grid Emission Factor
Vietnam's national grid emission factor is approximately 0.62 tCO2/MWh — heavily coal-dependent but with rapidly growing solar and wind shares. EAF steel producers in solar-heavy southern provinces have an actual-value advantage that doesn't exist for northern producers on coal-heavy grids. This regional split matters for CBAM documentation and should be reflected in installation-specific actual values rather than a national average.
The Pellet and Coke Supply Chain
Vietnam imports the majority of iron ore pellets (Brazil, Australia) and coking coal (Australia) for its integrated steel production. The embedded carbon of these inputs flows into the embedded carbon of Vietnamese steel exports. Vietnamese producers documenting actual values need to maintain traceability to their pellet and coke suppliers — this is increasingly the bottleneck in CBAM verification, not the Vietnamese installation's own emissions data.
Frequently Asked Questions
Does Vietnam have a carbon price eligible for CBAM deduction?
No. Vietnam does not currently have a national carbon tax or operational ETS eligible for CBAM Article 9 deduction. The pilot ETS is scheduled for mandatory operation from 2028 but is not yet recognised by the EU Commission for CBAM deduction.
What is Vietnam's total annual CBAM exposure?
Estimated at EUR 170–470M annually across steel, aluminium, and fertilisers — based on current export volumes and EU default values. Hoa Phat alone accounts for the majority of the steel exposure.
Which Vietnamese companies face the highest CBAM exposure?
Hoa Phat (Dung Quat and Hai Duong steel complexes), Formosa Ha Tinh, PVFCCo and PVCFC (urea), and the downstream aluminium fabricators. Hoa Phat's Dung Quat alone is Vietnam's largest single CBAM-exposed installation.
Does CBAM apply to Vietnamese rebar exports?
Yes. Steel rebar (HS code 7214) is covered under CBAM Annex I. Vietnamese EAF rebar producers can document significantly lower actual values than the 2.18 default, especially those operating on solar-heavy southern grids.
Where can Vietnamese manufacturers find ISO 14065 accredited CBAM verifiers?
Vietnamese producers typically work with regional ISO 14065 accredited firms based in Singapore, Malaysia, or Thailand, or with European firms with Asian offices. See the verifier directory for the global list.
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