28 May 2026
CBAM 2026 marks the definitive phase. After the transitional period, the mechanism becomes a direct part of import costs for companies bringing into the European Union products such as steel, aluminium, cement, fertilisers, hydrogen or electricity.
For importers, CBAM should no longer be treated as a separate administrative obligation. From 2026, data on embedded emissions, CN codes, actual producers and any carbon price paid in the country of origin will directly influence the number of CBAM certificates required.
CBAM 2026: What it is and why does it become important?
CBAM, the Carbon Border Adjustment Mechanism, is the EU mechanism for adjusting imports at the border based on their carbon content. Its purpose is to align the carbon cost of certain goods imported into the EU with the cost borne by European producers under the EU ETS.
The mechanism aims to reduce the risk of carbon leakage, meaning the relocation of production to countries where carbon costs are lower or non-existent.
CBAM currently mainly covers the following product categories:
- cement;
- iron and steel;
- aluminium;
- fertilisers;
- hydrogen;
- electricity.
These sectors are significantly exposed to carbon emissions and are relevant for the competitiveness of European industry.
CBAM certificate price for Q1 2026: EUR 75.36/tCO₂e
A key element for importers is the emergence of the first concrete financial benchmark. For Q1 2026, the CBAM certificate price is EUR 75.36/tCO₂e, applicable to embedded emissions in CBAM goods imported between 1 January and 31 March 2026.
This price clearly shows that CBAM is no longer just technical reporting. It becomes an obligation with direct financial impact.
For companies importing large volumes of steel, aluminium, cement or fertilisers, the CBAM cost must be included in commercial analysis, supplier contracts and procurement planning.
CBAM 2026 – obligations for importers
Under the definitive regime, importers must build a complete and verifiable CBAM file. This should not be prepared at the end of the year, but organised as imports take place.
The most important CBAM obligations for importers are:
- obtaining or verifying the status of authorised CBAM declarant;
- correctly identifying the CN codes covered by CBAM;
- collecting actual data on embedded emissions;
- separating direct and indirect emissions, where required by law;
- having data verified by accredited verifiers;
- calculating the required CBAM certificates;
- documenting any carbon price paid in the country of origin.
These elements are essential for the correct calculation of the CBAM obligation. An error in the CN code, actual producer or embedded emissions can directly affect the final cost.
CBAM embedded emissions: why actual data matters
The calculation of embedded emissions is one of the most important components of the CBAM mechanism. Importers must obtain data from the actual producers outside the EU, not only from commercial suppliers.
In practice, the data must answer several basic questions:
- where the imported goods were produced;
- who the actual producer is;
- what methodology was used to calculate emissions;
- what the direct emissions are;
- where relevant, what the indirect emissions are;
- whether the data can be verified.
The European Commission aims for actual data to remain the primary basis for CBAM declarations. Default values should only be used when actual data is not available.
CBAM default values may increase costs
A major risk for importers is the use of CBAM default values. If an importer cannot obtain actual, verifiable data compatible with the CBAM methodology, it will have to use the default values established by the Commission.
These values are generally conservative. This means they may reflect a higher emissions level than the actual emissions of an efficient producer.
The consequence is direct: a higher number of CBAM certificates to purchase and, implicitly, a higher cost for the importer.
For this reason, preparing CBAM data is not only a compliance issue. It is a cost control issue.
The European Commission is working on dedicated rules for deducting the carbon price paid in a third country. This initiative is relevant for CBAM importers because, under certain conditions, a carbon price already paid in the country of origin may reduce the number of CBAM certificates to be surrendered. However, the reduction will not be automatic. The importer will have to clearly demonstrate what price was paid, for which emissions, under which carbon pricing system, and whether any rebates, refunds or compensations existed. Without verifiable documents, this deduction cannot be credibly applied.
Deadline for the 2026 CBAM declaration
The first CBAM declaration for the 2026 calendar year must be submitted by 30 September 2027.
However, this deadline does not mean that preparation can be postponed until 2027. Data must be collected from 2026, for each relevant import.
Importers should organise information by:
- product;
- CN code;
- supplier;
- actual producer;
- country of origin;
- imported quantity;
- embedded emissions;
- verification documents;
- evidence of any carbon price paid outside the EU.
If this information is not collected in time, the company may have to reconstruct data retroactively. This is a risky approach and may lead to errors, missing documentation or mandatory use of default values.
Carbon price paid in the country of origin
Another important element in the definitive CBAM regime is the possibility of taking into account the carbon price paid in a third country.
Under certain conditions, the importer may request the deduction of this price from the CBAM obligation. However, the deduction cannot be based on general statements. Clear evidence will be required regarding:
- the applicable tax or emissions trading system;
- the emissions for which the carbon price was paid;
- the amount effectively paid;
- any rebates, compensations or refunds;
- conversion into euro, if the payment was made in another currency.
This documentation will become particularly important for imports from jurisdictions that already apply carbon pricing instruments.
CBAM and EU ETS: the link between imports and the carbon market
CBAM is directly connected to the EU ETS. The mechanism aims to ensure that imported goods bear a carbon cost comparable to that applied to European production.
This link is important for importers because the price of CBAM certificates reflects the evolution of EUA prices under the EU ETS.
As free allocation under the EU ETS is gradually reduced for sectors covered by CBAM, the CBAM obligation will become increasingly relevant for importers. This transition must be understood early, especially by companies with supply chains dependent on carbon-intensive products.
What importers should do in 2026
For affected companies, 2026 should be treated as the year for complete CBAM data organisation.
Importers should start by reviewing their imports and identifying all products that fall within the CBAM scope. They should then contact suppliers and actual producers to obtain data on embedded emissions.
The practical steps are:
- checking CN codes for all imported products;
- identifying actual producers, not only commercial intermediaries;
- requesting actual data on embedded emissions;
- checking the availability of supporting documents;
- assigning internal responsibilities for CBAM;
- including CBAM requirements in supplier contracts;
- estimating the potential cost of CBAM certificates;
- assessing the risk of using default values.
These steps must be taken before the declaration deadline. CBAM cannot be managed effectively through last-minute data collection.
CBAM becomes an import cost, not just reporting
CBAM 2026 marks the transition from reporting to a real financial obligation. For importers, technical data becomes directly relevant for the final cost of imported goods.
At a price of EUR 75.36/tCO₂e for Q1 2026, the lack of verified data may become more expensive than properly preparing the CBAM file.
Companies importing steel, aluminium, cement, fertilisers, hydrogen or electricity must treat CBAM as part of the procurement process. End-of-period reporting is not enough. Data, verification, traceability and cost control are required.
In 2026, CBAM compliance is no longer optional as an internal priority. It is a condition for properly managed imports in an economy where the cost of carbon becomes part of product pricing.
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