Carbon Border Adjustment Mechanism (CBAM)

The definitive period has started. The paperwork is now money.

Since 1 January 2026, CBAM is no longer a reporting exercise. Every tonne of CO₂ embedded in the cement, iron and steel, aluminium, fertiliser, hydrogen and electricity you bring into the EU now carries a price — and the number you declare is the number you pay for.

The first annual CBAM declaration, covering all 2026 imports, is due by 30 September 2027. It must be backed by either conservative default values or by actual emissions verified by an accredited CBAM verifier. There is no third option, and the gap between the two is where the money sits.

What is actually in scope

CBAM covers goods listed in Annex I of Regulation (EU) 2023/956 by CN code: cement, iron and steel, aluminium, fertilisers, hydrogen and electricity, together with a range of precursors and downstream products. Check your CN codes against Annex I — the surprises are almost always in the precursors and the derivative products, not the obvious ones.

The gases covered are carbon dioxide, nitrous oxide and perfluorocarbons, depending on the good.

  • Direct emissions only: iron and steel, aluminium, hydrogen, electricity

  • Direct and indirect emissions: cement and fertilisers

Are you a producer outside the EU? CBAM reaches you even if you do not export to the EU yourself. If your product is bought by a manufacturer who uses it as a precursor for a CBAM good, or by a trader who resells into the EU, your emissions data will be requested.

What changed under Regulation (EU) 2025/2083

The simplification package was adopted on 8 October 2025 and is now law. The headline changes:

A single 50-tonne mass threshold. An importer whose cumulative net mass of iron and steel, aluminium, cement and fertiliser goods stays below 50 tonnes in a calendar year is exempt and declares this in the customs declaration. Cross the threshold at any point in the year and you owe CBAM on everything imported in that year — including the obligation to be authorised, to declare and to surrender. The exemption does not apply to electricity or hydrogen, and the Commission reviews the threshold every year by 30 April.

Deadlines moved. Declaration and surrender both shifted from 31 May to 30 September.

Certificate sales deferred to 1 February 2027, with the 2026 certificate price calculated as a quarterly ETS auction average (weekly from 2027 onwards).

Quarterly holding reduced from 80% to 50%, and only from 2027.

Default values now carry a mark-up. Country- and good-specific default values are published in Implementing Regulation (EU) 2025/2621 and must be increased by 10% in 2026, 20% in 2027 and 30% from 2028 (1% for fertilisers). Where no reliable country data exists, the fallback is the average of the ten exporting countries with the highest emission intensities.

Non-calcined kaolinic clays are out of scope.

How we help

For installation operators outside the EU — consultancy

Your monitoring plan is the foundation of everything downstream. Under Implementing Regulation (EU) 2025/2547 it must define installation boundaries, production processes and routes, the reporting period, every parameter to be monitored, and the method chosen for each. We build it with you:

  • Scoping against Annex I: which of your goods are CBAM goods, and which of your inputs are precursors

  • Installation boundaries, production processes and production routes

  • Selection of monitoring methods per source stream — calculation-based, mass balance or measurement-based — and justification of the data sources chosen

  • Attribution of emissions to goods, including heat, electricity, waste gases and purchased precursors

  • Documentation of any carbon price due in your jurisdiction, so your EU customer can deduct it

  • Written procedures, data flows and control activities that will survive a verifier's scrutiny

  • Registration in the CBAM Registry and structured communication of data to your EU customers

Why us

We have been doing MRV under the EU ETS since it began. CBAM borrows the EU ETS architecture almost wholesale — monitoring plans, benchmarks, accredited verification, reasonable assurance — and that is the language we already speak. The same team supports clients on EU ETS, ETS2, product carbon footprint and CSRD, so your CBAM numbers stay consistent with everything else you report.

Independent verification

Verification of an operator's emissions report may only be carried out by a verifier accredited under Regulation (EU) 2023/956 and Delegated Regulation (EU) 2025/2551. We are working together with ETS accredited verifiers, currently the CBAM scope extension progress is ongoing.

A note on independence. The verification rules prohibit a verifier, or any part of the same legal entity, from having provided consulting on the monitoring plan, the monitoring methodology or the emissions report it verifies. We therefore keep the two tracks strictly separate: where we act as your verifier, we have not built your monitoring system, and vice versa. If you engage us for consultancy, we will help you find an independent verifier — and prepare you so the verification runs short and clean.

Importer or producer of CBAM goods? We can help you meet compliance

  • We can help you to determine the embedded emissions within CBAM goods produced / imported.

  • Through our team of experts, during the transitional period we can conduct an independent (voluntary) verification of the calculation methodologies used for calculation of the embedded emissions

Where you are in the timeline

  • 1 January 2026 — Definitive period starts. Only authorised CBAM declarants may import CBAM goods. The financial obligation begins to accrue.

  • Throughout 2026 — Non-EU operators monitor emissions under a compliant monitoring plan. Data that was not captured during the year cannot be reconstructed afterwards.

  • 1 February 2027 — Sale of CBAM certificates opens on the common central platform.

  • From 2027 — At the end of each quarter, at least 50% of the certificates corresponding to your imports so far that year must sit in your registry account.

  • 30 September 2027 — First annual CBAM declaration submitted and certificates surrendered, for calendar year 2026.

The commercial case for actual data

The mark-up on default values is deliberate. It is designed so that declaring real, verified emissions is, in almost every case, cheaper than declaring defaults — and the discount widens every year as the mark-up climbs from 10% to 30%.

Your CBAM bill is not simply emissions × certificate price. It is reduced by two things, and both need to be actively claimed:

  • The free allocation adjustment, calculated on CBAM benchmarks under Implementing Regulation (EU) 2025/2620, mirroring what an EU producer would have received free. It shrinks each year as free allocation is phased out between 2026 and 2034.

  • A carbon price effectively paid in the country of production, net of any rebates or free allocation in that scheme — but only if your supplier documents it. If they don't, it is assumed to be zero.

Neither of these arrives automatically. Both depend on the quality of what your supplier monitored during the year.