CBAM 2026: How to design factories to reduce carbon emissions from the start?

From January 1, 2026, the European Union's Carbon Border Adjustment Mechanism, or CBAM, will officially enter its full implementation phase.

For manufacturing businesses in Vietnam, CBAM is not simply a new export procedure. This mechanism places increasingly high demands on the ability to identify, verify, and provide emission data associated with goods.

A practical question arises: if a business is preparing to build or expand a factory, how should the structure be designed to reduce carbon emissions from the outset?

The answer lies not simply in installing solar panels. A carbon-ready plant requires a comprehensive approach encompassing production processes, architecture, structure, energy systems, and the ability to measure and store operational data.

What changes does CBAM 2026 bring?

According to the European Commission, CBAM was developed to limit "carbon leak," that is, the shifting of high-emission production to countries with less stringent climate policies.

From January 1, 2026, CBAM will officially apply to certain goods in six industry groups:

• Cement.
• Iron and steel.
• Aluminum.
• Fertilizer.
• Electricity.
• Hydrogen.

Importers in the EU or their indirect customs representatives importing goods exceeding 50 tonnes of CBAM must meet the requirements for licensed declarant status. They declare the implied emissions and submit the corresponding CBAM certificate number as required. The certificate price is linked to the quota auction price of the EU Emissions Trading System (ETS). (See reference) The European Commission's CBAM definitive regime..

Non-EU businesses are typically not the direct buyers of certificates. However, manufacturers may be required by customers or importers to provide data on the processes, raw materials, fuel, electricity, and emissions of their goods.

The method of calculation and emission limits depend on the product type, product code, and sectoral guidance. In August 2026, the European Commission published a set of guidance for operators outside the EU, which included guidance on calculating implied emissions and separate documents for each sector. See European Commission sectoral guidance.

Does a low-emission plant mean it meets CBAM requirements?

Not entirely. Businesses need to differentiate between the two classes of carbon.

Carbon from factory construction

This includes emissions related to construction materials, construction, transportation, equipment replacement, and operation of the facility throughout its lifecycle.

Carbon content in the product

This refers to emissions determined by the method applied to goods subject to CBAM. The scope may relate to the production process, input materials, fuel, electricity, and specified stages.

Using low-carbon building materials helps reduce the environmental impact of a building, but it does not automatically reduce the product's CBAM (Cost, Area, and Amity, Amity, and Amity) rating.

Conversely, a factory designed for energy efficiency, with metering systems for each production line and good control over the production process, will be better positioned to reduce and demonstrate emissions associated with the product.

Therefore, a reasonable goal is not to build a "CBAM-certified plant," because CBAM is not a building certification. The goal should be to build a plant with low energy consumption, transparent data, and sufficient adaptability to meet the requirements of export customers.

7 design decisions that help reduce emissions from the start.

1. Start with the production flowchart and data boundaries.

Factory design shouldn't begin with dividing room space or choosing an architectural style. Input data should start with the product, capacity, and production process.

The investor should determine:

• Raw materials and semi-finished products as inputs.
• Processes that generate heat, steam, gas, or waste.
• The device uses electricity and fuel directly.
• The designed output of each production line.
• The point of exchange between stages.
• Output products, by-products, and waste.
• Data needs to be collected for each batch or production cycle.

This diagram helps the design team identify areas with high energy consumption and locations where separate meters should be installed.

This approach can be combined with Checklist for designing a factory ready for production. To simultaneously control functionality, logistics, MEP, and scalability.

2. Optimizing the overall site plan and building envelope.

The building's orientation, the distance between blocks, the location of air vents, the roof, and the cladding all affect the lighting, ventilation, and cooling requirements.

During the conceptual design phase, businesses can consider:

• Limit direct sunlight exposure to the facades of buildings that receive a lot of sun.
• Choose roofing and wall materials with appropriate thermal insulation properties.
• Utilize natural light but control glare and heat.
• Provide natural ventilation for eligible areas.
• Separate the heat-generating area from the space that needs to be conditioned.
• Arrange warehouses and production lines to reduce internal transportation distances.
• Reserve the land for expansion without requiring major demolition.

Each manufacturing industry has different requirements regarding temperature, humidity, cleanliness, and room pressure. Therefore, passive solutions need to be tested in conjunction with technological conditions, fire safety, and the working environment.

3. Design MEP based on actual load

Electrical, air conditioning, ventilation, compressed air, steam, and process water systems typically account for a large proportion of a factory's energy needs.

If the equipment selected is too large, the system may frequently operate at low load and be inefficient. If insufficient capacity is selected, the plant will require renovation after commissioning.

MEP design should be based on:

• Load distribution graphs by shift and by season.
• Current capacity and expansion plans.
• Simultaneous operation mode of the device.
• The ability to control according to actual needs.
• Device performance at various load levels.
• Losses in the distribution network.
• The ability to perform maintenance without shutting down the entire plant.

For compressed air systems, it's necessary to consider the operating pressure, pipe diameter and structure, equipment placement, and flow measurement points. For HVAC systems, it's better to zone areas according to demand rather than uniformly conditioning areas with varying operating conditions.

4. Prioritize energy efficiency before adding renewable energy.

Rooftop solar power can help reduce the amount of electricity purchased from the grid and make use of factory roof space. However, energy efficiency should still be addressed first.

The logical order is usually:

1. Eliminate unnecessary energy demands.
2. Reduce losses in the system.
3. Choose equipment with suitable performance.
4. Control the device based on the actual load.
5. Heat recovery or energy reuse if feasible.
6. Evaluating electrochemical options.
7. Supplementing with renewable energy sources.

Right from the structural design stage, the plant can prepare for roof loads, maintenance access, cable routes, electrical cabinet locations, and safety measures to facilitate the future installation of solar power.

Businesses can refer to this group. DATA Cons' Solar Systems project To visualize the practical implementation methods.

5. Selecting structures and materials according to the lifecycle.

Steel structures, concrete, cladding, and finishing materials all generate emissions during their production and construction processes.

The design can mitigate the impact by:

• Optimize the span, column spacing, and structural cross-section.
• Avoid designing for unnecessary overload.
• Prioritize solutions that are detachable or reusable.
• Request documentation regarding the origin and environmental information of the materials.
• Compare the options based on lifespan, maintenance, and replaceability.
• Control material losses at the construction site.
• Utilize prefabricated components where appropriate.

However, material selection should not be based solely on a single carbon number. The final choice must also consider durability, corrosive environments, load capacity, fire resistance, supply, and total lifecycle cost.

6. Design the metering system directly from the blueprint.

A factory that consumes less energy but fails to separate data along the production line may still face difficulties when customers require accountability for product emissions.

The metering system should be hierarchical:

• The main electricity meter for the entire factory.
• Meters are installed by workshop or area.
• Custom watches for high-volume production lines.
• Fuel, steam, compressed air, and process water metering points.
• Output data corresponds to the measurement period.
• Operating time and load conditions of the equipment.
• A system for storing, controlling, and retrieving data.

The data should include the measurement point code, unit, recording cycle, responsible person, and procedure for handling interruptions in the measuring device.

The GHG Protocol also distinguishes between direct emissions data, energy purchases, and value chain data. Designing the data architecture from the outset makes it easier for businesses to conduct emissions inventories or reporting. (See reference) GHG Protocol Standards and Guidance.

7. Commissioning and handover to maintain efficiency

A well-designed system may not function correctly without prior testing and calibration before handover.

A commissioning plan should include:

• Inspect the equipment against its design specifications.
• Calibrating important gauges.
• Test at various load levels.
• Test the control logic and alerts.
• Establishing energy baselines.
• Hand over the equipment inventory and maintenance schedule.
• Training the operating team.
• Monitoring and fine-tuning after the plant is operational.

The ultimate goal is to ensure the system operates in accordance with the design assumptions, while also creating an initial dataset to serve as a basis for comparison in subsequent phases.

The checklist is implemented in three stages.

Conceptual design phase

• Check if the product falls within the scope of CBAM.
• Identify the commodity code and export market.
• Create a flowchart for materials, energy, and products.
• Identify the main sources of emissions.
• Set measurable energy and carbon targets.
• Assessing infrastructure for electricity, water, fuel, and renewable energy.
• Allow for scalability.

Engineering design phase

• Develop load models by area and production line.
• Optimizing architecture, structure, and MEP.
• Design a hierarchical metering system.
• Regulations require data for equipment and materials.
• Integrate engineering data into BIM if the project applies it.
• Prepare the infrastructure for solar power and energy management systems.
• Establish a performance acceptance procedure.

Construction and handover phase

• Control the origin of materials and equipment.
• Update the changes in the completion report.
• Calibrate the measurement point and test data transmission.
• Test the system under various scenarios.
• Develop operating and maintenance instructions.
• Training personnel responsible for energy and data.
• Establish a baseline after the plant has stabilized its operation.

Mistakes businesses should avoid

Installing solar panels without optimizing the load: Renewable energy sources cannot address the problem of inefficient equipment or lossy systems.

Only save the main electricity bill: The bill shows how much electricity the entire factory used, but it doesn't explain which product or production line consumed that electricity.

Wait until the customer requests it before collecting data: Historical data may not be fully recoverable if the measurement system has not been installed.

Equating green building certification with CBAM: Green certifications and CBAMs can both support the common goal of reducing emissions, but they differ in scope and assessment methodology.

Separate the design team from the production team: If line parameters, energy consumption, and output are not shared from the outset, the project is likely to lack measurement points or have an inappropriate system layout.

Plant design should begin with the ability to measure.

In Vietnam, the 2024 updated list includes 2,166 facilities subject to greenhouse gas inventory, indicating that the requirement for emissions data management is increasingly reaching the grassroots level. (Information referenced from...) Ministry of Agriculture and Environment.

For export businesses, the value of factory design lies not only in the initial construction cost. The facility must also support efficient operation, data control, and adapt to the increasingly demanding requirements of the supply chain.

CBAM cannot be addressed by a single item. Businesses need to coordinate production, energy, construction, environment, finance, and data right from the project preparation phase.

DATA Cons provides comprehensive industrial development solutions, We provide comprehensive support from surveying, design, construction to infrastructure connection and handover. If your business is preparing to build or expand a factory, please contact us. Contact DATA Cons To jointly review the functional, energy, and metering infrastructure options right from the start.

This article is for informational purposes only and does not replace legal advice, greenhouse gas inventory advice, or the determination of CBAM obligations for a specific product.