CBAM transitional phase begins. EU importers of covered goods must submit quarterly reports on embedded greenhouse gas emissions. No certificate purchases required during this phase.
Carbon Border Adjustment Mechanism (CBAM)
The EU Carbon Border Adjustment Mechanism (CBAM) requires any company importing over 50 tonnes of cement, iron and steel, aluminum, fertilizers, electricity, or hydrogen into the EU per year to register as an authorized CBAM declarant, annually report verified embedded greenhouse gas emissions, and surrender CBAM certificates priced against EU Emissions Trading System (EU ETS) allowances, with a penalty of €100 per tonne of CO₂e for authorized declarants who fail to surrender certificates on time.
Next Deadline
September 30, 2027: authorized CBAM declarants must file the first annual CBAM declaration and surrender certificates for all covered goods imported during 2026.
The 2026 reporting year is already in progress. Authorized CBAM declarants must verify and declare embedded emissions for all goods imported between January 1 and December 31, 2026 by September 30, 2027. CBAM certificate prices for 2026 imports are set as quarterly averages of EU ETS allowance auction prices. Certificates go on sale in February 2027. Companies that have not yet obtained authorized CBAM declarant status cannot import covered goods above the 50-tonne annual threshold until the National Competent Authority (NCA) grants authorization.
Regulation timeline
What the regulation requires
The Carbon Border Adjustment Mechanism (Regulation EU 2023/956, amended by Regulation EU 2025/2083) entered its definitive phase on January 1, 2026, following a transitional reporting period from October 2023 to December 2025. It applies to EU importers and indirect customs representatives acting on their behalf, importing covered goods into the EU: cement, iron and steel, aluminum, fertilizers, electricity, and hydrogen.
Importers below 50 tonnes per year across all in-scope goods combined are exempt from CBAM obligations. Electricity and hydrogen are assessed separately and are not subject to the same threshold.
The regulation requires importers to hold authorized CBAM declarant status, report verified greenhouse gas emissions (direct and, for some sectors, indirect) embedded in imported goods, purchase CBAM certificates equivalent to those emissions, and annually surrender them. If a carbon price has already been paid in the country of origin, the declarant can deduct the corresponding amount.
The mechanism prevents carbon leakage by ensuring that the carbon cost of imports matches the cost borne by EU producers under the EU ETS, with free allowances for EU producers phasing out between 2026 and 2034.
Common CBAM implementation challenges
Non-EU suppliers rarely hold emissions data in the format CBAM requires
CBAM compliance depends on access to reliable emissions data from non-EU suppliers. Importers must calculate embedded emissions for each imported good and production site and support those calculations with verified production-level data.
Non-EU suppliers operate outside CBAM's regulatory scope and carry no obligation to provide emissions data in the format the regulation requires. Emissions reporting processes and methodological standards are not uniform across production regions, and verification readiness cannot be assumed.
Authorization, declaration, and certificate surrender each require a separate workflow
The definitive phase establishes three connected obligations: authorization, annual declaration, and certificate surrender. Each carries its own workflow, registry interaction, and timing requirements.
The quarterly certificate holding requirement is 50% of embedded emissions accrued since the start of the calendar year. Preparing and submitting the annual declaration and certificate surrender requires coordinated input from procurement, trade compliance, and finance.
Certificate cost exposure moves with EU ETS allowance prices
CBAM certificate prices move with EU ETS allowance prices. For 2026 imports, certificate prices reflect a quarterly average of EU ETS auction prices.
From 2027, certificate prices reflect weekly EU ETS averages. Importers must forecast certificate cost exposure, account for carbon costs already paid in the country of origin, and plan purchases before the September 30 annual surrender deadline.
CBAM may extend to selected downstream products from 2028
In December 2025, the European Commission submitted a legislative proposal to extend CBAM coverage to selected downstream products. The proposal is subject to legislative negotiation and has not yet been adopted.
If adopted, the extension would bring additional product categories into CBAM scope. The scope of those categories and the 2028 implementation date remain subject to change as legislative negotiation continues.
Manage every CBAM obligation in one platform
The osapiens HUB for CBAM covers compliance workflow, embedded emissions calculation, annual declaration preparation, and CBAM report generation for submission to the EU CBAM declarant portal. The platform gives procurement and finance teams visibility into carbon cost exposure and enables supplier benchmarking across product categories.
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