Poland and Romania 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% and Romania 4.2% of the imports.
The two countries link European industrial production with eastern supply routes and cross-border electricity trade. Both import materials directly and supply wider European value chains. Steel and aluminium serve construction, machinery, household appliances, automotive components and metal fabrication. Fertilisers supply agricultural markets, while electricity imports have a distinct commercial and regulatory profile.
Customs figures do not necessarily indicate where goods are ultimately consumed. Imports may enter through neighbouring EU member states before reaching Polish or Romanian factories; goods cleared in either country may also be distributed elsewhere. The figures therefore need to be distinguished from final industrial consumption.
Supply-chain exposure and country-level scrutiny
A contractor buying steel from a regional warehouse may face an indirect carbon-related cost without having a CBAM certificate obligation. Importers serving multiple customers need an auditable way to allocate imported quantities and associated emissions evidence. Buyers weighing lower-priced material from a higher-emissions plant against costlier material with credible verified data must assess landed cost and contracting risk.
For investors, the issue is whether CBAM can encourage better supply quality and environmental data without undermining manufacturing competitiveness. Country-level analysis should identify leading CN8 items and origins, then examine importers, processors, distributors and buyers in manufacturing clusters. Poland warrants attention for high-volume metal processing and fertiliser distribution.
Romania, an EU neighbour to Serbia and other Energy Community markets, merits separate scrutiny of electricity and industrial feedstock routes from the Western Balkans. Those routes are relevant to electricity-import evidence and carbon-price exposure. The Energy Community includes neighbouring markets such as Serbia that are relevant to that evidence and exposure.
The EU has proposed expanding CBAM downstream to selected manufactured products. Their treatment could change from 2028 if the proposal is adopted. Analysis across eastern Europe’s industrial markets needs to distinguish direct customs liability from wider supply-chain exposure.
