A Packaging Printing Factory’s Three Real-World Carbon Tariff Integration Pathways: CBAM / EU ETS / Domestic Carbon Market

In November 2025, a cosmetics customer exporting to the EU contacted me after receiving a letter from an EU buyer requiring all packaging suppliers to provide a carbon footprint report for each packaging type by June 2026, or their orders would be canceled. The letter alarmed the customer, who came to ask me: "I am the brand owner. Do I also need to provide this from my printing factory? What kind of report must the printing factory provide?"

I told him: this is a spillover effect from the EU CBAM (Carbon Border Adjustment Mechanism) entering into full effect in 2026. On the surface, CBAM is a carbon tariff covering 6 product categories: steel, aluminum, cement, fertilizers, electricity, and hydrogen. However, packaging, as an "accessory" to these products, has also been brought within the carbon data disclosure requirements.

This is actually one of the biggest shifts in the packaging and printing industry in 2026—carbon data has changed from a “bonus” to an “entry requirement”. However, printing company owners still have a vague understanding of the boundaries among these three types of carbon mechanisms and often confuse them.

Category 1: CBAM (Carbon Border Adjustment Mechanism)—a hard constraint for exports to the EU

CBAM is the EU carbon tariff adopted in 2023 and fully effective in 2026. The core logic is to impose a "carbon cost differential" on carbon-intensive products imported from outside the EU, ensuring that producers inside and outside the EU bear the same carbon costs.

The 6 product categories initially covered by CBAM (steel, aluminum, cement, fertilizers, electricity, and hydrogen) do not currently directly involve packaging, but from 2026, the EU will require importers of these products to declare the “carbon emissions generated during upstream production processes.” As packaging is one of the “upstream materials,” it must provide carbon footprint data.

Implications for printing plants in practice: ① Packaging orders exported directly to the EU, such as food bags, cosmetic boxes, and luxury gift boxes, will require buyers to obtain a carbon footprint report; ② Even if the packaging orders themselves are not subject to CBAM tariffs, buyers may still require printing plants to provide data; ③ The report format will generally be required to comply with ISO 14067 or the GHG Protocol standards.

Three specific CBAM requirements for printing plants: ① provide data for Scope 1 (direct emissions from boilers and generators), Scope 2 (indirect emissions from purchased electricity), and Scope 3 (upstream raw material procurement and downstream logistics); ② data granularity at the "per product" or "per process" level; ③ the report must be issued by a third-party certification body (not self-reported by the printing plant).

Type 2: EU ETS (EU Emissions Trading System) — Indirect Transmission Through the Packaging Supply Chain

EU ETS is the European Union's carbon emissions trading system, established in 2005, covering power plants, factories, airlines, and other facilities within the EU. Beginning in 2024, the EU began discussing expanding the EU ETS to upstream material supply chains, including the packaging industry.

Difference between EU ETS and CBAM: CBAM is a “border adjustment” that imposes a carbon tariff on imported products; EU ETS is an “internal trading” system that enables the market-based trading of emission allowances among businesses within the EU. However, their impact on printing plants is similar—both require the provision of carbon data.

Implications for printing plants: If EU buyers are registered under the EU ETS, their carbon costs will be passed down to their upstream supply chains. The more detailed the data provided by printing plants, the lower the buyers' carbon costs. This is why EU buyers are increasingly "picky" in demanding carbon footprints from printing plants.

The most direct impact of the EU ETS on printing plants is their inclusion in the scope of "supply chain carbon accounting". Specifically, under the 2026 implementation framework: ① EU buyers must report Scope 3 emissions data to the EU ETS regulatory authority each year; ② Scope 3 includes "purchased goods and services," namely the packaging products supplied by printing plants; ③ Once a printing plant's carbon data are included in its buyer's Scope 3, the buyer's compliance costs will change.

Type Three: The National Carbon Market in China — the Printing Company's Own "Carbon Account"

The national carbon market was launched in 2021 and expanded in 2024 to cover eight industries: steel, cement, aluminum smelting, papermaking, printing and dyeing, chemicals, power generation, and aviation. The packaging and printing industry is currently not among the eight mandatory sectors, but some printing companies have voluntarily joined the "voluntary emissions reduction market" (CCER) in exchange for carbon credits.

The impact of the domestic carbon market on printing plants falls into two categories: ① printing plants with annual comprehensive energy consumption of ≥ 1 × 10,000 metric tons of standard coal will be mandatorily included (currently, no packaging printing plant nationwide has reached this threshold); ② printing plants may voluntarily join CCER and earn carbon credits through emission-reduction projects, such as upgrading VOC treatment equipment or replacing motors with energy-efficient models. These carbon credits can be sold on the carbon market.

The real benefits of a printing plant joining CCER: ①The market price of carbon credits is 30-80 yuan per tonne (2025 data); ②A printing plant reduces 500-2,000 tonnes of carbon emissions annually, corresponding to revenue of 15,000-160,000 yuan; ③Beyond the direct revenue, CCER certification can also help printing plants secure export orders (EU buyers prefer suppliers with CCER certification).

However, the threshold for printing plants to join CCER is also high: ① baseline carbon emissions accounting is required (typically requiring 3 months of continuous monitoring data); ② emission reduction projects must be measurable, reportable, and verifiable (MRV); ③ third-party verification costs 5-10 ten-thousand yuan per verification, once a year.

Comparison of the Three Types of Mechanisms and Selection of Printing Suppliers

机制Scope of ApplicationPrinting Factory Data RequirementsPrinting plant costPrinting plant revenueCBAMEU export ordersComplete Scope 1/2/3 dataThird-party certification: RMB 30,000–80,000/productRetain EU ordersEU ETSEU buyer supply chainsScope 3 upstream dataSame as aboveBuyers are more willing to cooperateDomestic CCERPrinting plants voluntarily participateBaseline + emission reduction MRVVerification 50,000-100,000 yuan/yearCarbon credits 15,000-160,000 yuan/year

3 Practical Suggestions from Print Shop Experience

First, when a customer requests a "carbon report," first confirm whether it refers to CBAM, EU ETS, or CCER. These three requirements differ in data granularity, reporting format, and third-party certification body.

Second, prioritize third-party organizations with ISO 14064 certification qualifications. ISO 14064 is an internationally recognized quantification standard under the GHG Protocol, recognized by both the European Union and China. The fee for a single certification is RMB 30,000–80,000, covering 5–10 products.

Third, do not complete all the data at once. Start with Scope 1/2 data for "orders exported to the EU" (the easiest and least costly), then proceed to Scope 3, and finally consider CCER voluntary emission reductions. A phased approach can keep first-year expenditure within 50,000 yuan.

Trends and Changes in 2026

Starting in the second half of 2026, the EU may extend CBAM to products directly related to packaging (such as paper, plastic pellets, and aluminum foil). This means that the carbon data for printers’ core raw materials (paper, ink, and plastic pellets) will also be included.

Preparations the printing plant should make in advance: ① Communicate with paper suppliers and request ISO 14067 reports; ② Communicate with ink suppliers and request carbon footprint data; ③ Communicate with plastic pellet suppliers and request PCR (post-consumer recycled) content and carbon footprint data. The carbon transparency of these upstream data will increasingly become a competitive advantage for printing plants.

Further Reading

Carbon Emission Accounting for Packaging Companies: 3 Methods — ISO 14064 / GHG Protocol / National Standard GB/T 51316

Three Practical Forms of the "Carbon Label" in Packaging and Printing: CFP / EPD / China Environmental Label

Packaging and Printing Carbon Footprint: 3 Types of Real Data Boundaries: Scope 1/2/3