The EU Carbon Border Adjustment Mechanism (CBAM) officially entered into force on 1 January 2026, marking a decisive shift from policy design to real-time customs enforcement. Three weeks into go-live, it is clear that CBAM is no longer a theoretical climate instrument. It is now an integral part of EU import procedures, with immediate operational consequences for importers and exporters of carbon-intensive goods.
The CBAM Registry is now part of national customs systems via TARIC and the EU Customs Single Window. In practice, this means that customs authorities now verify CBAM authorisation before releasing goods for free circulation. Early figures confirm the scale of implementation: during the first week of January alone, more than 12,000 authorization applications were filed, over 4,100 authorized CBAM declarants were approved, and 10,000+ import declarations were validated in real time.
While the transitional phase has formally ended, one final obligation remains. Importers must submit the last quarterly report for Q4 2025 by 31 January 2026. This closes the reporting-only phase and marks the full transition to the definitive CBAM regime.
A critical compliance trigger in 2026 is the 50-tonne annual mass threshold. Importers exceeding this threshold for CBAM-covered goods (such as steel, aluminium, cement, fertilisers, electricity, and hydrogen) must hold Authorised CBAM Declarant status. The Commission’s simplification package exempts importers below this level – primarily SMEs – while still capturing the vast majority of embedded emissions.
For companies that missed the 1 January deadline, there is a limited safety valve: if an authorisation application is submitted by 31 March 2026, imports may continue provisionally until the competent authority issues a decision. This is not a grace period, but a conditional bridge – and stakeholders should use it carefully.
Although are no certificates to purchase in 2026, this year is far from “quiet.” CBAM liabilities begin accruing with every covered import. Member States will start selling CBAM certificates in 2027, reflecting emissions embedded in 2026 imports.
The first annual CBAM declaration – together with the surrender of certificates – will be due by 30 September 2027. Certificate prices will track the EU Emissions Trading System (ETS), subject to transitional rules, and verified carbon prices already paid in third countries may be deducted where properly documented.
CBAM currently applies to basic materials, but the Commission has already proposed a significant expansion. From 1 January 2028, the scope may extend to approximately 180 downstream steel- and aluminium-intensive products, including machinery and appliances, alongside stricter anti-circumvention rules.
At the same time, political volatility remains. Recent calls by France and Italy for a temporary fertiliser carve-out show that CBAM’s design can still evolve—even after go-live.
For exporters to the EU, CBAM’s entry into the definitive regime fundamentally changes the commercial landscape. Although the legal obligation to declare and surrender CBAM certificates rests with EU importers, enforcement now takes place at customs clearance. Any failure on the buyer’s side directly affects the exporter. Shipments may be delayed or blocked if CBAM authorisation checks fail, shifting commercial pressure upstream. This means longer lead times, demurrage costs, Incoterms risk allocation, and potential renegotiation of contracts. As CBAM liabilities begin accruing with 2026 shipments, EU buyers are rapidly standardizing their data demands. Exporters should therefore expect emissions transparency to become a baseline commercial requirement. The ability to provide credible, product-specific and auditable embedded emissions data will increasingly determine supplier preference, pricing discussions, and access to the EU market. In parallel, exporters should anticipate new contractual clauses addressing data warranties, audit rights, and CBAM-related price adjustments, particularly in light of the expected downstream scope expansion from 2028.
2026 is not a dormant year. It is a critical preparation window. Businesses should use this time to secure reliable supplier emissions data, establish verification pathways, and account for CBAM costs. They should do this well before the first real cash outflows begin in 2027.
CBAM is now part of EU customs law. Treat it accordingly.
