CBAM: What Are the Obligations for Importers in the European Union in 2026?

The CBAM (Carbon Border Adjustment Mechanism), also known as the MACF (Carbon Border Adjustment Mechanism) or “carbon tax”, is a major reform of international trade introduced by the European Union.

It aims to put a carbon price on imports of certain products to ensure a level playing field between European producers subject to the EU Emissions Trading System (EU ETS) and importers of goods from third countries.

In the context of the ecological transition and the fight against climate change, this mechanism represents a major change for importing companies. It introduces new administrative, reporting and operational obligations, requiring adaptation of internal processes and supplier relationships.

This article provides a comprehensive and detailed guide to CBAM obligations for importers in Europe, covering regulatory, practical and strategic aspects.

What is the CBAM and why was it introduced?

The CBAM is a mechanism introduced by the European Union to apply a carbon price to imports of certain products based on their CO₂ emissions. It was designed to prevent European companies from relocating production to countries with less stringent environmental standards.

This measure is part of the European Green Deal, led by the European Commission, and was adopted as an extension of the European Emissions Trading System (EU ETS).

According to Ursula von der Leyen, President of the European Commission:

“ I welcome the political agreement reached this morning on the Commission’s proposal for a carbon border adjustment mechanism. This is a central element of our European Green Deal, aimed at preventing the risk of carbon leakage. It is a major step forward as we raise our climate ambitions. ”

Source: European Commission press release (Press Corner)

The objectives are therefore twofold:

• Reduce global CO₂ emissions
• Protect European industries from unfair competition

Which products are covered by the CBAM?

The CBAM initially covers a limited number of so-called “high-carbon-intensity” sectors.

Products currently covered:

• Cement
• Iron and steel
• Aluminium
• Fertilisers
• Electricity
• Hydrogen

Key takeaway:

Sector	Carbon exposure level	CBAM Impact
Steel	Very high	High
Aluminium	High	High
Cement	Very high	High
Fertilisers	High	Medium to high
Electricity	Variable	Specific
Hydrogen	Emerging	In development

Who is subject to CBAM obligations?

CBAM obligations apply to:

• Importers established in the European Union;
• Indirect customs representatives;
• CBAM declarants.

Any company importing goods covered by the CBAM (steel, aluminium, cement, fertilisers, electricity, hydrogen, etc.) must comply with the mechanism’s requirements, including emission reporting and, ultimately, the purchase and surrender of CBAM certificates.

In practice, this concerns:

• Manufacturers importing raw materials or components for their production;
• Distributors incorporating imported products into their supply chain;
• Traders carrying out international purchase-resale operations;
• International trading companies handling imported flows subject to the CBAM.

These actors must implement an appropriate organisation to collect supplier data, calculate emissions associated with imported products and ensure compliance with the reporting obligations set out in European Union regulations.

What are the main obligations for importers?

CBAM obligations break down into several key steps:

1. Register as a CBAM declarant

Importers must register with the competent authorities and obtain the status of authorised CBAM declarant.

2. Collect carbon emission data

Importers must obtain the necessary information from their suppliers to calculate emissions linked to imported products, in particular:

• Direct emissions (scope 1);
• Indirect emissions (scope 2, where applicable);
• Production data for the imported goods.

3. Submit CBAM emissions reports

Each year, importers must submit a CBAM declaration including:

• Quantities of goods imported;
• Carbon emissions associated with these imports;
• Country of origin of the products;
• The methodology used to calculate the emissions.

This declaration enables authorities to verify that imports comply with the requirements of the CBAM mechanism defined by the European Union.

4. Purchase and surrender CBAM certificates

From the definitive phase onwards, importers will have to:

• Purchase CBAM certificates linked to the imported emissions;
• Surrender CBAM certificates each year according to the declared emissions.

5. Retain and archive data

Companies must retain all supporting evidence:

• Supplier data: emissions, methods and volumes;
• Emission calculations: methods and results used;
• Customs documents: import declarations;
• CBAM declarations: reports submitted to the authorities.

These elements must be reliably archived and easily accessible in the event of an audit by the competent authorities in order to demonstrate compliance of the CBAM declarations.

What are the steps to achieve CBAM compliance?

The Carbon Border Adjustment Mechanism (CBAM), also referred to as the carbon tax, is being rolled out in two distinct phases:

Transitional phase (2023–2025)

During this period, companies must prepare for the new obligations without any direct financial impact:

• No obligation to purchase CBAM certificates;
• Quarterly reporting obligation for the relevant imports;
• Collection and transmission of CO₂ emissions data.

Definitive phase (from 2026)

From 2026, the mechanism becomes fully operational:

• Obligatory purchase of CBAM certificates corresponding to imported emissions;
• Submission of complete annual declarations;
• Financial compliance with the requirements of the mechanism.

What data must be collected?

Under the CBAM, importers must implement a reliable and structured data collection system.

Mandatory data to collect

• Product identification (CN code) which allows precise classification of the goods according to the customs nomenclature and determines eligibility for the Carbon Border Adjustment Mechanism (CBAM);
• Imported quantities of the product, expressed in the appropriate units (tonnes, kilograms, MWh, etc.), in order to measure the volumes concerned;
• Direct emissions of the product, corresponding to greenhouse gases generated during its manufacturing process;
• Indirect emissions (depending on the product), mainly linked to the energy consumed to produce the good, such as electricity;
• Calculation methodology, specifying the methods, data sources and assumptions used to estimate emissions;
• Country of production, indicating the geographical origin of the goods and identifying the applicable regulatory framework;
• Installation data of production sites, compiling information on manufacturing sites (location, industrial processes, technologies used) to ensure traceability and reliability of the declared data.

Example data collection table

Data	Description	Source
Product code	CN customs code	Customs declaration
Direct emissions	CO₂ generated during production	Supplier
Indirect emissions	Electricity consumed	Supplier / energy mix
Imported quantity	Volume or mass	Commercial documents

How are emissions calculated under the CBAM?

Emission calculations under the CBAM are based on standardised methodologies defined by the European Union, to ensure data harmonisation and comparability between different operators and third countries.

Simplified formula

Criteria affecting emission factors

• Product type: each product has its own carbon intensity, linked to the raw materials used and the manufacturing steps required.
• Country of production: differences in energy mix and regulation influence the level of emissions.
• Technologies used: more modern and efficient industrial processes generally reduce emissions.

What are the CBAM reporting obligations?

Reporting obligations under the CBAM are based on the regular collection and transmission of information on emissions associated with imported goods:

• Quarterly declarations (transitional phase): operators must regularly transmit data on emissions associated with imported goods to ensure progressive monitoring during the transition period.
• Annual declaration (definitive phase): a complete declaration must be submitted each year, containing all information relating to emissions and imported volumes.
• Emission justification: declared emissions must be supported by reliable and documented data to attest to their accuracy and compliance.
• Transmission via a dedicated CBAM register: all information must be centralised and transmitted through a specific register, guaranteeing traceability and monitoring of declarations.

Principles to follow for declarations

• Accurate: declared information must faithfully reflect the reality of emissions and production data, without significant errors or approximations.
• Verifiable: data must be verifiable and justifiable at any time using reliable documents and traceable sources
• Traceable: each piece of data must be traceable from its origin to its declaration to ensure full transparency.

What are the risks of non-compliance?

Failure to comply with obligations related to the carbon tax (CBAM) can result in significant consequences for importing companies, both financially, operationally and regulatorily, such as:

• Financial fines;
• Import refusal;
• Administrative sanctions;
• Customs blockage.

How to prepare effectively for the CBAM?

To effectively anticipate CBAM requirements, it is essential to structure your approach in advance and adopt best practices that secure compliance while optimising internal processes.

Key steps for CBAM compliance

• Identify covered products by determining which goods are subject to the CBAM in order to focus efforts on the flows actually affected;
• Map suppliers by analysing the supply chain to identify actors capable of providing reliable emissions data;
• Implement a data collection system by structuring and centralising the flow of information needed for emission calculations;
• Train internal teams by raising awareness among staff of CBAM obligations to ensure proper ownership;
• Automate processes by using digital tools to make calculations more reliable, reduce errors and increase efficiency;
• Implement carbon tracking tools to monitor emissions continuously in order to anticipate reporting obligations and regulatory developments.

Strategic CBAM best practices

• Integrate CBAM into the supply chain strategy;
• Work with suppliers capable of providing reliable data;
• Anticipate costs related to certificates;
• Implement internal audits.

Step	Action	Description	Period / Timing
1	Identify eligibility	Check whether imported products are subject to the CBAM (cement, steel, aluminium, fertilisers, electricity, hydrogen, etc.)	Upstream
2	Register	Registration as an importer in the EU CBAM register	Transitional then mandatory phase
3	Collect data	Obtain emissions data and imported volumes from non-EU suppliers	Ongoing
4	Calculate emissions	Calculation of direct and indirect emissions according to European Commission methodologies	Ongoing
5	Report emissions	Submission of quarterly CBAM declarations	Transitional phase (2023–2025)
6	Purchase certificates	Purchase of CBAM certificates corresponding to imported emissions	Definitive phase (from 2026)
7	Surrender certificates	Annual surrender of certificates based on declared emissions	From 2026
8	Verify and audit	Data control, verification by accredited bodies	Ongoing
9	Set up an internal organisation	Structure processes (ERP, customs, purchasing, compliance) and train teams	Ongoing

What are the impacts of the CBAM on importing companies?

The CBAM has several significant impacts on importing companies:

1. Financial impact

The mechanism can lead to an increase in import costs, particularly due to the obligation to purchase CBAM certificates (CBAM), the price of which is linked to the carbon emissions associated with the imported products.

2. Operational impact

Compliance involves a complexification of customs processes, with additional reporting obligations and a greater need for data monitoring and management, which may require the implementation of new internal tools and procedures.

3. Strategic impact

In the longer term, the CBAM may lead to a reconfiguration of supply chains, with companies encouraged to favour more environmentally virtuous suppliers in order to reduce their exposure to emission-related costs.

According to Paolo Gentiloni, Commissioner for Economy:

“The agreement reached this morning is a decisive step towards launching the world’s first carbon border adjustment mechanism and I warmly congratulate the negotiators of the EU institutions on this historic achievement. The CBAM is at the heart of the EU’s efforts to achieve its ambitious climate objectives under the European Green Deal. It sends an important signal to producers around the world that the EU is determined to reduce emissions and expects the same level of commitment from industrial companies exporting to the EU, wherever they are located.”

Source: European Commission press release (Press Corner)

CBAM: Summary table of importer obligations

Obligation	Description	Frequency	Phase
Registration	Authorised declarant status	Once	Transitional & definitive
Data collection	Supplier emissions data	Ongoing	Transitional & definitive
CBAM declaration	Emission reporting	Quarterly then annual	Both phases
Purchase of certificates	Carbon compensation	Annual	Definitive phase
Archiving	Retention of evidence	Ongoing	Both phases

The CBAM: a major transformation for importers

The CBAM represents a structural evolution of international trade. It imposes new obligations on European importers in terms of transparency, reporting and environmental compliance.

Beyond a regulatory constraint, the CBAM also represents an opportunity:

• to optimise supply chains
• to strengthen traceability
• and to integrate carbon criteria into purchasing decisions

Companies that anticipate these obligations now will be better positioned to limit risks, control their costs and adapt sustainably to this new European regulatory framework.

CBAM FAQ: Frequently asked questions about the carbon border mechanism

Sources:

• European Commission – dedicated CBAM page (in English)
• CBAM Guidance & legislation – Taxation and Customs Union (EU) (in English)
• Guidance document on CBAM implementation (pdf in English)

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