The start of 2026 This marks a point of no return in the European Union's climate policy. After several years of trials and reports at no direct cost, the Carbon Border Adjustment Mechanism It enters its final phase and begins to have a real economic impact on imports of certain products.
For companies that sell to the European market, especially those steel, iron, aluminum, fertilizers, cement, hydrogen and electricityCBAM ceases to be a theoretical issue and becomes a key variable when setting prices, negotiating contracts and organizing its logistics and emissions traceability.
Is your company ready for the new final CBAM period?
The European Commission has published Key regulatory updates These changes refine both the reporting requirements and the calculation of the costs associated with emissions embodied in imported goods. For many companies, knowing about these changes in advance can make the difference between a smooth transition and an unexpected increase in costs.
If you work in import, customs, logistics, foreign trade, compliance, finance or sustainability And if you manage the flow of goods in the affected sectors, the new scheme not only implies more paperwork: it affects the margin structure, the choice of suppliers, and the very trade strategy with the EU.
What is CBAM and how will it change in 2026?
El CBAM The Carbon Border Adjustment Mechanism (CBRM) is the well-known European "carbon tariff." Its central objective is prevent carbon leakageThat is, to prevent companies from moving their production to countries with laxer environmental regulations and then selling their products in the EU without internalizing the climate cost.
On transitional period 2023-2025Importers were only required to declare emissions associated with the covered assets, without having to pay for them. That phase served to collect data, test methodologies and adjust the reporting systems of companies and authorities.
Beginning January 1, 2026, the mechanism enters definitive regimeIn addition to reporting, importers will need to acquire CBAM certificates that reflect the volume of CO₂ emissions incorporated into their products, at a price aligned with the European Emissions Trading System (EU ETS).
In practice, this means that imports of certain goods will be subject to a additional cost linked to its carbon footprint. This cost will be calculated in €/tonne of CO₂, with a quarterly average value in 2026 and a weekly value from 2027 onwards, following the auction price of emissions in the EU ETS.
Sectors and products affected in the final regime
The CBAM focuses on sectors with a high emissions intensity and relevant to European industry. At its core are:
- Cement
- Aluminum
- Fertilizers
- Ferrous metals (iron and steel)
- Hydrogen
- Electricity
These products were already under scrutiny during the transitional phase, but with the full implementation of the mechanism they are now directly associated with the Purchase and delivery of CBAM certificates by importers in the EU.
Furthermore, December 2025 the European Union decided expand the scope of CBAM adding a wide range of industrial goods for further processing in the value chain. These are, above all, products with a high steel and aluminum content, with an average of 79% of these materials.
In total, around 180 new items, among them numerous iron and steel products (such as pipes, structures, railway materials, or screws), a defined list of industrial machinery and equipment and determined home appliancesThis expansion strengthens the coherence of the system and reduces the risk of diverting emissions to semi-finished or processed goods.
Simplification measures and reduction of administrative burden
Aware of the potential impact on the business sector, the EU has introduced a series of simplified rules to limit the regulatory burden, especially on SMEs and small operators.
The key measure is the fixing of a minimum threshold of 50 tons for CBAM imports. Transactions below this weight will be exempt from the mechanism, which, according to EU calculations, will release the 90% of importersespecially small and medium-sized enterprises and individuals.
The procedures have also been adjusted authorization of declarants, the method of calculating emissions, the reporting formats and compliance with financial obligations, with the aim of making the system more manageable for companies that actually concentrate the volume of emissions.
At the same time, Brussels has designed a reinforced strategy against tax evasion to close potential escape routes, such as trade diversions to non-covered products, triangulated operations, or underreporting of emissions in the supply chain.
Calculation of emissions and new methodology for electricity
One of the most delicate elements of the CBAM is the methodology for calculating implicit emissions of imported products. The European Commission has been refining these rules to ensure the system is both robust and workable for businesses and verifiers.
In the specific case of the electricityThe method for determining the predetermined valuesUntil now, an emission factor based primarily on the fossil fuels of the exporting country was used. With the reform, the calculation will reflect the carbon intensity of all generation sources of that country, including the thermal energy, which will foreseeably reduce CBAM obligations in many cases.
This modification is accompanied by a simplification of conditions in order to be able to declare the actual electricity emissions, making it easier for operators with reliable and verified data to benefit from accounting that is more in line with their production reality.
For the remaining products, specific calculation rules are maintained that will allow importers to choose between default values and verified real dataprovided they meet the technical and audit requirements set out in the CBAM regulation.
Authorized declarants, certificates and key deadlines
The new framework establishes that only the CBAM authorized declarants will be able to manage imports subject to the mechanism. EU importers, or their customs representatives, exceeding the threshold of 50 tonnes CBAM goods must request this status.
The deadline to request recognition as authorized declarant has been fixed on March 31th 2026Companies that are not properly registered and authorized in a timely manner may encounter serious obstacles in continuing to introduce the covered products into the Community market.
Los CBAM certificates will be acquired before the competent national authorities in each Member State. Its price will be directly linked to the auction value of the rights of EU ETS, Expressed in €/ton of CO₂: quarterly average in 2026 and weekly average from 2027 onwards.
Each year, importers must declare emissions associated with their imports and deliver the corresponding number of certificates to the national authority. The volume of certificates to be returned will depend on the implicit emissions per imported productwhether calculated with real data or with accepted default values.
Reference parameters and relationship with the EU ETS
One element that is still under development is the benchmarks for CBAMThey are expected to be available in 2026, once the reference parameters of the EU ETS, with whom they will maintain a close relationship.
The European Commission will define standard reference values that represent the typical production process for each product included in the mechanism. These values will act as a guide to determine what the quantity would have been. free broadcasting rights allocated if the production had taken place within the EU.
Importers will be able to use verified data from your suppliers to demonstrate production processes that differ from the standard, which would open the door to the application of alternative reference parameters more favorable when there is a lower carbon footprint.
Regarding the transition period, it is expected that the rules for the calculation of implicit emissions They will undergo some adjustments, precisely to align with these new benchmarks and with the logic of the EU ETS in its most recent phase.
Annual declarations, TARIC and customs control
The reporting obligation schedule is also strengthened by the definitive entry into force of the CBAM. Starting from May 31th 2027Authorized declarants must submit each year a CBAM statement relating to the previous year.
That declaration must be sent to the competent authority of the Member State before May 31 of each year and will collect, among other data, the volume of covered imports, implicit emissions and CBAM certificates acquired and delivered.
Additionally, declarants will be required to submit a certain number of certificates before July 1th of each year. The number of certificates to be issued will be directly linked to the declared level of incorporated emissions, so that there is a accounting consistency between imports, emissions data and bonds issued.
In parallel, the CBAM will be integrated into customs procedures through the inclusion of specific TARIC document codes in import declarations of affected goods from 1 January 2026.
Among these codes, the following stand out, for example: Y128, which identifies the CBAM account number, or the codes Y135 y Y136which include specific exceptions for goods linked to military activities or the production of electricity and hydrogen. The code Y137 It is used for the de minimis rule (minimum threshold that does not apply to electricity or hydrogen), while the Y238 It serves to indicate that the application for recognition as a CBAM declarant It was submitted before March 31, 2026.
Economic impact and role of emissions information
Beyond the strictly regulatory level, CBAM introduces a cost component which may alter the relative competitiveness of different international suppliers. The European importer will be legally responsible for the declaration and payment, but the allocation of the carbon cost will be decided in the trade negotiation.
In many cases, EU buyers will try to transfer to the supplier part or all of the cost associated with CBAM certificates, whether through price discounts, contract revisions, or changes in the supply base. This new scenario transforms the verifiable carbon footprint as one more element in the discussion about prices and conditions.
The main challenge for exporting companies is not only reducing their emissions, but also having access to solid, traceable and auditable dataThe system requires a clear measurement of direct emissions (scope 1), emissions derived from electricity consumed (scope 2) and, in some cases, part of scope 3 linked to relevant inputs.
This involves investing in measurement, verification and reporting systems, as well as in the standardization of internal processes, aligned with the innovation and sustainabilityCompanies that can offer their European customers a robust emissions information "package," with independent verification and a credible reduction plan, will be better positioned.
The practical consequence is that the CBAM functions as a market filterThose who demonstrate a smaller carbon footprint and good data control will have a competitive advantage, while those who cannot justify their emissions will face higher costs and possible loss of orders.
Deductions, compliance and penalty regime
The design of the mechanism acknowledges that, in some countries, a carbon price during the production of goods exported to the EU. To avoid double taxation, the system allows importers claim a deduction equivalent to the cost of carbon already paid in the country of origin.
To do this, it will be necessary to provide sufficient evidence that the carbon price has actually been paid, in what amount, and under what regulatory scheme. Inadequate or unverifiable documentation may result in the deduction not being accepted or being subsequently reviewed by the authorities.
In case of breach or inconsistencies in the declared data, the regulations provide for a set of sanctions. One of the clearest is a penalty of €100 per tonne of undeclared CO₂which can amount to significant sums in transactions of a certain volume.
National authorities also have the power to impose additional administrative fines and to demand the performance of external audits at the importer's own expense, when they detect serious or repeated irregularities in the CBAM declarations.
In situations of systematic or particularly serious non-compliance, even the following is considered: loss of authorized declarant statuswhich in practice may block the possibility of continuing to import products subject to the mechanism for the EU market.
CBAM and the European green agenda beyond 2026
The final deployment of CBAM does not come alone. It coincides with the entry into force of other key standards of the green agenda European, which, although they regulate different areas, point in the same direction of strengthening sustainability and the protection of the internal market.
Among the most notable measures is the implementation of a common data platform on chemical substances, intended to centralize information, improve transparency and facilitate coordination between national authorities, companies and citizens on chemical risks.
They are also updated periodically public procurement and concession thresholds which require the application of European procedures, in order to adapt these limits to economic developments and the international commitments assumed by the EU.
In parallel, a new toy safety regulations which formally comes into force in 2026, although its mandatory application is postponed until August de 2030This timeframe is intended to allow the sector to adapt to more demanding requirements, especially regarding dangerous chemicals present in children's products.
The set of these measures, with CBAM as one of the central pieces, reflects Brussels' desire to consolidate a a more sustainable economic model, in which environmental, safety and transparency rules reinforce each other, even if this entails tensions with certain industrial sectors concerned about their international competitiveness.
The definitive entry into force of the CBAM makes the carbon footprint This has become a tangible variable in the cost of importing to the European Union and is forcing companies in Europe and third countries to review their processes, contracts, and emissions data more rigorously. For those who trade cement, aluminum, fertilizers, ferrous metals, hydrogen, or electricity into the EU market, adapting is no longer optional: accurate measurement, verification, and reporting are becoming as important as the product's price itself, in a regulatory environment that will continue to evolve in the coming years.
