CBAM – Upcoming Changes from 2026. What Importers Need to Know
As of 1 January 2026, the Carbon Border Adjustment Mechanism (CBAM), commonly referred to as the “carbon border tax,” will enter into full application.
CBAM is one of the key elements of the European Union’s climate policy, designed to equalize carbon emission costs between EU producers and importers from non-EU countries.
In practice, companies importing certain goods into the EU will be required to account for the CO₂ emissions generated during their production.
When Will CBAM Apply?
The full implementation of CBAM begins on 1 January 2026. However, the purchase of CBAM certificates for emissions related to goods imported in 2026 will only be possible starting from 1 February 2027.
The first annual CBAM declarations must be submitted by 30 September 2027 (covering emissions embedded in goods imported in 2026).
The transitional period lasts until the end of 2025. During this time, importers are required to report emissions data but are not yet obligated to purchase certificates.
How Does the CBAM Mechanism Work?
The core principle of CBAM is the obligation to purchase CBAM certificates reflecting the CO₂ emissions embedded in imported goods.
Importers will be required to surrender a number of certificates corresponding to the emissions associated with the goods they place on the EU market.
Importantly, importers may deduct carbon costs already paid in the country of production, provided they can properly document such payments. In such cases, the number of required CBAM certificates will be reduced accordingly.
Who Is Affected by CBAM?
The mechanism applies to imports of carbon-intensive goods, in particular:
- Iron and steel
- Aluminum
- Cement
- Fertilizers
- Electricity
- Hydrogen
Any importer established in the EU must obtain the status of an authorized CBAM declarant before importing goods covered by the mechanism. Only authorized declarants are permitted to submit CBAM declarations and purchase certificates.
Key Obligations for Importers
From 2026 onwards, importers will be required to:
- Apply for authorized CBAM declarant status (by 31 March 2026),
- Report actual or estimated embedded emissions for imported goods,
- Purchase the required number of CBAM certificates,
- Submit annual CBAM declarations by 30 September each year,
- Maintain records and retain documentation supporting emissions data.
While importers may appoint representatives to submit declarations on their behalf, full responsibility remains with the authorized declarant.
Who Is Exempt?
Importers bringing in CBAM goods with a total annual net mass not exceeding 50 tonnes are exempt from the obligations under Regulation (EU) 2023/956.
This exemption is intended to reduce the administrative burden for smaller importers.
From 2027 – Ongoing Certificate Balancing Obligation
Starting in 2027, authorized declarants will be required to maintain a sufficient number of CBAM certificates in their registry accounts.
At the end of each quarter, the number of certificates held must correspond to at least 50% of the embedded emissions in goods imported since the beginning of the calendar year.
What Should Be Done Now?
The transitional period runs until the end of 2025 – this is the final opportunity to prepare for the new obligations.
Companies should now:
- Analyze their import structure,
- Verify which goods fall within the CBAM scope,
- Develop a system for collecting emissions data,
- Establish reporting procedures,
- Plan a budget for the purchase of CBAM certificates.
CBAM represents not only new compliance obligations but also an important step toward a more sustainable economy.
Although the mechanism requires increased transparency and organizational readiness, it may also serve as an incentive to optimize processes and invest in low-carbon technologies.
With full implementation approaching in 2026, now is the time to ensure your company is fully prepared for the upcoming changes.