CSRD and CBAM: what Brazilian exporters need to know
Selling to Europe means reporting emissions and paying a carbon tax at the border. A practical summary of what applies to each profile, with the calendar, sector coverage and the real traps.
CSRD in one sentence
The *Corporate Sustainability Reporting Directive* (CSRD) requires roughly 50,000 companies with European operations to publish sustainability reports under the ESRS standards, with external audit, XBRL format and the principle of double materiality. Brazilian companies with a branch, a subsidiary or relevant EU revenue fall in scope.
CBAM in one sentence
The *Carbon Border Adjustment Mechanism* is a carbon charge on European imports of cement, iron and steel, aluminium, fertilisers, hydrogen and electricity. It ran in a transition phase (reporting only) between October 2023 and December 2025; effective payment from January 2026.
Who is affected in Brazil
CSRD
- Brazilian subsidiaries of European multinationals that meet the size thresholds.
- Exporters with more than €150M in net EU revenue in two consecutive years.
- Direct suppliers of companies covered by CSRD: they are part of their European clients' Scope 3 and will be pushed to provide primary data.
- Brazilian SMEs listed on a European exchange, from 2027.
CBAM
- Brazilian exporters in the six listed sectors, regardless of size.
- The direct obligation sits with the European importer, but the primary data has to come from the exporter; whoever does not provide it is penalised with default values.
What to report
CSRD: 12 ESRS standards
- ESRS 2 (general): governance, strategy, management of impacts, risks and opportunities.
- ESRS E1 (climate): Scope 1, 2 and 3 emissions, transition plan, targets, physical and transition risks.
- ESRS E2-E5: pollution, water, biodiversity, circular resources.
- ESRS S1-S4: own workforce, workers in the value chain, communities, consumers.
- ESRS G1: business conduct, anti-corruption, political lobbying.
CBAM: embedded emissions per product
- Direct emissions from the production process (Scope 1).
- Indirect emissions from the electricity consumed (Scope 2).
- For some sectors: emissions from precursors (input materials).
- All verified by an accredited third party from 2026.
Calendar 2025-2027
| Year | CSRD | CBAM |
|---|---|---|
| 2024 | Wave 1 (large EU companies) starts reporting financial year 2024 | Quarterly reporting, no payment |
| 2025 | Wave 1 report published; Wave 2 preparation | Last year with no payment |
| 2026 | Wave 2: foreign subsidiaries and large non-EU companies enter | Effective payment begins |
| 2027 | Wave 3: listed SMEs | Coverage widened (review expected) |
| 2028+ | Full coverage | Possible extension to chemicals, plastics and other sectors |
CBAM: how the calculation works in practice
- The Brazilian exporter measures direct process emissions per tonne of product, using a traceable methodology (preferably aligned with the GHG Protocol and ISO 14067).
- It adds indirect emissions from the electricity consumed (grid mix or a traceable green contract).
- It submits the data to an accredited verifier.
- It shares the verified report with the European importer (the CBAM declarant).
- The importer calculates embedded emissions, buys proportional CBAM certificates and settles with the European authority.
If the primary data does not arrive in time, the declarant uses default values, which are deliberately conservative and penalise the product.
CSRD: double materiality in practice
Unlike IFRS S2 (which asks "how does climate affect my business?"), CSRD requires the double question: how climate affects my business AND how my business affects climate and society. For each material topic:
- Financial impact: how the topic affects revenue, cost, assets, liabilities and cash flow.
- Impact on people and the environment: the positive and negative effects of the company's operations on the topic.
That multiplies the materiality assessment work and requires structured stakeholder engagement.
Operational recommendation
For a Brazilian company that finds itself under one of the two obligations (or both):
- Start with a complete, auditable GHG inventory (Scopes 1, 2 and 3). It is the common base for CSRD, CBAM, IFRS S2 and CDP.
- Set up primary data collection with priority suppliers. Without primary data, CBAM penalises you and CSRD becomes a fragile estimate.
- Run a formal double materiality assessment. It is not optional under CSRD.
- Implement a platform with a field-level audit trail. The auditor will ask for source, factor, version and owner.
- Plan independent verification (limited assurance at minimum). Without verification, none of the four frameworks accepts the data.
How Mangue helps
We deliver auditable GHG inventories with the trail verifiers require. We support the CSRD double materiality assessment and structure the CBAM calculation with a verified methodology.
For exporters in the CBAM sectors we offer an integrated package: embedded emissions calculation, independent verification, and support to the European importer in filing the declaration.
- Map which CSRD wave applies to you: Wave 1 (large EU companies) still in 2025, Wave 2 (foreign subsidiaries) from 2026, Wave 3 (listed SMEs) from 2027.
- For CBAM, build an embedded emissions calculation per tonne of exported product; it requires a traceable methodology, verified by a third party from 2026.
- Negotiate with the European importer how the CBAM cost is passed through in the price: whoever absorbs it loses margin, whoever passes it on has to document the calculation record.
- Use the CSRD work to cover IFRS S2 voluntarily as well; the overlap between the standards cuts the marginal effort.
- Start with primary supplier data; without it, CBAM default values penalise your product with the worst case in the sector.
Perguntas frequentes
My company has no EU branch. Do I need to worry about CSRD?+
Possibly. CSRD applies to foreign companies with net revenue above €150 million in the EU in two consecutive years, or to a European subsidiary that crosses the thresholds. Even without direct CSRD exposure, your European client will probably ask you for Scope 3 data for their own report.
Who pays CBAM, the exporter or the importer?+
Legally, the European importer (the CBAM declarant) pays when buying CBAM certificates. Commercially, the pass-through depends on the contract negotiation. The market has already seen both absorption into the price (the exporter loses margin) and full pass-through (the importer loses competitiveness). A company prepared for CBAM negotiates better.
Can I use CBAM default values instead of calculating my emissions?+
You can, but you will pay the worst case in the sector, often 2 to 4 times more than the real figure for an efficient operation. Default values are designed to penalise whoever does not bring verified primary data.
Does CSRD accept a report prepared under IFRS S2?+
There is interoperability work between EFRAG (CSRD) and the ISSB (IFRS), but it is not automatic. CSRD requires double materiality and covers topics beyond climate (E2-E5, S1-S4, G1). IFRS S2 is climate only. A company under both shares much of the data but needs separate narratives.
What is the penalty for not reporting under CSRD?+
Each member state sets the local penalty when transposing the directive. It usually combines a monetary fine (proportional to revenue), publication of the non-compliance, and personal liability for directors. In serious cases, restricted access to European public contracts.
- CSRD
- Corporate Sustainability Reporting Directive. The EU directive requiring around 50,000 companies to publish ESG reports under the ESRS standards.
- ESRS
- European Sustainability Reporting Standards. The thematic CSRD standards: ESRS 2 (general), E1-E5 (environmental), S1-S4 (social), G1 (governance).
- Double materiality
- The CSRD principle: a company reports both the impact of a topic on the business and the impact of the business on that topic and on society.
- CBAM
- Carbon Border Adjustment Mechanism. A carbon tax charged on European imports to level the cost with European producers under the ETS.
- ETS
- Emissions Trading System. The regulated European carbon market, with an average price between €60 and €90/tCO₂e (2024-2026).
- CBAM declarant
- The European importer authorised to buy CBAM certificates and declare the embedded emissions of imported products.
- Default values
- Standard emission values per tonne of product, set by the EU for each CBAM sector. Used when the exporter does not provide primary data.
- XBRL
- eXtensible Business Reporting Language. The format CSRD requires for electronic tagging of the report.
- Diretiva (UE) 2022/2464 · Corporate Sustainability Reporting Directive · Jornal Oficial da União Europeia
- Regulamento (UE) 2023/956 · Mecanismo de Ajustamento Carbónico Fronteiriço · Jornal Oficial da União Europeia
- Carbon Border Adjustment Mechanism · Comissão Europeia · Taxation and Customs Union
Frameworks mencionados neste artigo
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