CBAM in 2026: what changes for EU importers of steel, cement, fertilisers and aluminium

From 1 January 2026, the EU’s Carbon Border Adjustment Mechanism (CBAM) moves from a “reporting-only” trial into the definitive regime, which is designed to mirror the carbon cost EU producers face under the EU Emissions Trading System. For importers of steel, cement, fertilisers and aluminium, 2026 is the year when CBAM stops being a quarterly compliance exercise and becomes a supply-chain, contracting and data-verification project with direct financial exposure.

What 2026 changes in practice: scope stays, obligations tighten

CBAM still targets a limited group of carbon-intensive products and certain precursors, with iron and steel, aluminium, cement and fertilisers at the core of what most industrial importers deal with day to day. The key difference in 2026 is not “what goods exist”, but what the EU expects you to prove about them: embedded emissions must be calculated using the EU’s methodology, supported by evidence from non-EU producers, and prepared for verification under the definitive regime.

If you have been treating CBAM as a customs-side reporting task, 2026 forces a broader operational view. Purchase orders, Incoterms, supplier declarations, plant-level emissions data, and the ability to link each customs entry to the correct installation and product category become the spine of compliance. When something does not reconcile, the risk is no longer only an inaccurate report — it can become a compliance breach that delays imports or triggers penalties.

Another practical shift is that the transition period flexibility ends. During the trial phase (1 October 2023 to 31 December 2025), many companies relied on simplified approaches and interim defaults; by 2026, the expectation is that your numbers are based on the EU method and grounded in auditable source data. That changes the type of conversations you need with suppliers: it is less about “can you send something?” and more about “can you send the right thing, in the right format, reliably, every shipment?”

Authorised CBAM declarant status and the 50-tonne relief for small volumes

A central 2026 requirement is authorisation: imports of CBAM goods into the EU customs territory are meant to be handled by an authorised CBAM declarant, obtained through the CBAM register process. In real terms, that means you need a named legal entity, a compliance owner, and a documented internal control framework that a competent authority can accept before you keep importing without disruption.

At the same time, the EU introduced a mass-based exemption aimed at removing very small importers from the burden. The political agreement and related materials describe a 50-tonne per importer per year threshold for CBAM goods, intended to exempt the majority of importers while still capturing most embedded emissions. This matters for businesses that only import small, irregular volumes of steel products, aluminium components, cement-based items or fertiliser batches: you may fall outside CBAM’s day-to-day obligations, but you still need a monitoring view so you do not accidentally exceed the threshold mid-year.

Be careful with the edge cases. Even when the exemption applies, your procurement team still benefits from understanding CBAM exposure in supplier pricing and lead times, because many upstream sellers will embed carbon-cost expectations into contracts. And if your volumes fluctuate, build a simple “CBAM volume tracker” aligned to customs declarations so you can see, month by month, whether you are drifting towards the threshold.

Money and timing: certificates, ETS linkage, and why 2026 still matters financially

CBAM is designed to align the carbon price of imports with the EU ETS carbon price, to reduce incentives for moving production outside the EU. Conceptually, the cost follows embedded emissions: the higher the verified emissions in the imported good, the higher the CBAM exposure. Practically, that means your commercial teams need to understand that “cheaper material” can become “more expensive landed cost” once carbon is priced in.

Recent EU simplifications have also affected timing. Several compliance briefings and policy summaries describe that the start of CBAM certificate sales was postponed, with the expectation that certificates for 2026 imports will be purchased later (starting in 2027), priced using EU ETS-linked reference values. The operational implication is straightforward: 2026 is still the year you must capture and validate emissions data shipment by shipment, because those 2026 imports create the obligation that later turns into certificate surrender.

For budgeting, treat CBAM as a two-part problem: (1) data completeness and verification readiness in 2026, and (2) cash planning for certificate purchasing once the deferred payment window opens. If you wait until “the year of payment” to fix data, you will discover you cannot reconstruct robust emissions evidence retrospectively across hundreds or thousands of consignments.

How CBAM cost is reduced: carbon prices paid abroad and contract design

CBAM is not meant to “double charge” if a genuine carbon price has already been paid in the country of production, but proving that is a documentary challenge. The only workable approach is to agree, upfront, what evidence the supplier will provide: the scope of carbon pricing, the period covered, how it applies to the installation, and how it maps to the goods you import. Without that, you risk paying the EU-equivalent carbon cost because you cannot demonstrate a valid reduction.

This is where contract design becomes a compliance tool. Add clauses that require the producer to provide installation-level emissions data, support verification, and notify you of material methodology changes. For higher-risk supply chains (for example, carbon-intensive steel routes or fertiliser production with high process emissions), it can be worth adding audit rights or third-party verification obligations, because the downstream importer is the party facing EU enforcement.

Commercially, you may also see a “carbon transparency premium”. Suppliers who can provide stable, verified embedded-emissions data will be easier to import from and may win tenders even if their headline price is slightly higher. Over time, this reshapes sourcing: the ability to document emissions becomes part of supplier performance, alongside quality, delivery and price.

Operational checklist for importers in 2026: data, verification, and customs alignment

Start with mapping: list the CN codes and product categories you import that fall within CBAM coverage, then map each one to the supplier installation(s) and production routes. For steel and aluminium, the complexity often comes from semi-finished and finished products and from recycled content claims that need evidence. For cement, the embedded emissions can be heavily driven by clinker and fuel mix. For fertilisers, process emissions and energy inputs can swing results materially.

Next, set up a single internal dataset that links purchase orders, invoices, transport documents and customs declarations to CBAM reporting fields. This is where many companies fail: finance has one view, customs brokers have another, sustainability teams have a third, and none of them join cleanly. In 2026, the goal is a line-of-sight from “this consignment crossed the border” to “these embedded emissions are supported by these documents, for this installation, for this reporting year”.

Finally, test your process before it is audited under pressure. Run sample shipments end-to-end: collect supplier data, calculate embedded emissions using the EU method, store evidence, and produce an internal “audit pack”. If you cannot do that on ten shipments, you will not be able to do it on ten thousand — and CBAM is unforgiving to organisations that treat compliance as a once-a-year scramble.

What typically breaks first: suppliers, verification readiness, and internal controls

The first failure point is supplier readiness. Many non-EU producers are not set up to deliver consistent, installation-level emissions data that matches EU methodology expectations. In 2026, importers who succeed will be the ones who standardise templates, train suppliers, and build a routine: data submission deadlines, validation checks, and escalation paths when data is missing or inconsistent.

The second failure point is verification readiness. Even if the EU’s phased approach and timing changes soften the immediate cash impact, verified numbers still matter, and verification is only possible if evidence is complete and traceable. Build document retention rules now: what you store, where you store it, who signs off, and how changes are controlled. A lightweight internal controls framework beats a “heroic effort” every time.

The third failure point is accountability. CBAM sits between customs, sustainability and finance, which makes it easy for everyone to assume someone else owns it. In 2026, a clear owner and a simple governance model are worth more than another spreadsheet: one accountable lead, one agreed data model, one set of controls, and routine reporting to management on coverage, gaps and exposure.