CBAM: What companies should know now

The EU is one step closer to climate neutrality: in December 2022, a political agreement was reached on the carbon border adjustment mechanism as part of the European Green Deal. As a result, a reporting obligation for importers of certain energy-intensive goods came into force on 1 October 2023. We have summarised for you what you need to know about the border adjustment mechanism. For example, to whom the reporting obligation applies and how certificate trading works.

The Carbon Border Adjustment Mechanism (CBAM for short) is intended to counteract the risk of carbon leakage to countries with no or lower ambitions to combat CO2 emissions. The European Union recognises the risk of companies either importing goods from other EU countries with lower emission reduction requirements or relocating production to these countries. This could save costs that are inevitably incurred when switching to more environmentally friendly production.

This is why the EU Emissions Trading Scheme is being supplemented by the border adjustment mechanism and extended to imported goods. Companies will be obliged to purchase emission certificates for every tonne of CO2 they import. The harmonised EU regulation on CBAM is also intended to create incentives for non-EU countries to increase their climate ambitions.

The CBAM is part of the Fit for 55 package. It is one of the measures that the EU has launched as part of the European Green Deal to reduce greenhouse gas emissions by 55 per cent by 2030 compared to 1990 levels. By 2050, it wants to be the first confederation of states to achieve complete CO2 neutrality.

The new regulations will initially affect goods imported from non-EU countries that are particularly CO2-intensive, including cement, electricity, fertilisers, aluminium, iron, steel, hydrogen and some upstream and downstream products. By 2030, the scope of the CO2 border adjustment is to be extended to all industrial goods.

Non-EU countries that are integrated into emissions trading in the EU or whose EU emissions trading systems (ETS) are recognised as equivalent can be excluded from the scope of application.

As set out in the European Commission’s proposed amendment from December 2025, the scope is to be expanded to include 180 additional product categories from 2028 onwards. The products affected include, amongst others, engines, pumps, oven burners, fridge-freezer combinations, oil and fuel filters, cranes, lifts, conveyor belts, industrial robots, washing machines, cables, wires, commercial vehicles, vehicle bodies, furniture made of aluminium or steel, and many more. 

Even though the purchase of CBAM allowances will not begin until February 2027, companies will already be under considerable pressure in 2026. From the reporting phase starting in October 2023 and the transition to the emissions trading phase in early 2026, importers must fully record CBAM-relevant goods, determine their embedded emissions in accordance with the strict CBAM system boundaries, and at the same time ensure that they are registered as authorised CBAM declarants. As emissions calculations must, in principle, be based on certified real-world data, companies are now absolutely reliant on the support of their non-European suppliers. However, the necessary transparency regarding production steps, precursor materials and energy use is often lacking – a problem that will become even more acute in view of the planned expansion of the CBAM scope to numerous additional product groups from 2028 onwards.

For companies, this means one thing above all else in 2026: establishing reliable data interfaces, digital processes and close cooperation with global suppliers is no longer optional, but a prerequisite for fulfilling CBAM obligations efficiently and in compliance with the law.