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Industry Mind · Briefing

CBAM: the first bill arrives in 2027

The definitive period of the EU's carbon border adjustment mechanism began in January 2026. The first certificates are paid for in 2027, and exporters' emissions data is now part of the price.

October 20264 min readWolf x group

CBAM puts a carbon price on certain goods entering the EU, so that imports carry the same cost of emissions as goods made inside it. After a transition of reporting only, 2026 is the first year that will be paid for, starting with a small share of the cost while free allocation under the EU emissions trading system is phased out.

Who it covers

CBAM applies to imports of iron and steel, aluminium, cement, fertilisers, hydrogen and electricity, including certain products made from them. Since 1 January 2026, importers above the threshold must be authorised CBAM declarants, approved by the competent authority of their Member State. Those who applied by 31 March 2026 could continue importing while their application was assessed.

What the 2025 simplification changed

  • A 50-tonne threshold. Regulation (EU) 2025/2083 exempts importers whose combined imports of iron and steel, aluminium, cement and fertilisers do not exceed 50 tonnes net mass per calendar year. The threshold does not apply to electricity or hydrogen, which remain covered whatever the volume.
  • Later payment. Certificates can be bought from February 2027, covering the emissions embedded in goods imported during 2026.
  • Later declaration. The first annual declaration and surrender of certificates is due by 30 September 2027 instead of 31 May.

Why exporters should care

The legal obligation sits with the EU importer, but the cost depends on the emissions embedded in the goods. That makes the exporter's emissions data commercially relevant: two offers at the same price can carry a different carbon bill for the buyer.

For a supplier from Asia, reliable emissions data is no longer a sustainability report. It is part of the sales offer.

Our view

What to do now

  1. Check which of your products fall under CBAM and how much your EU customers import each year.
  2. Ask your EU importers what emissions data they need from you, in what format and by when.
  3. Collect installation-level emissions data and have it checked by a qualified verifier where required.
  4. Build the carbon cost into price discussions for 2026 and 2027 deliveries.

Sources

  1. EY Global Tax News: EU adopts CBAM omnibus regulation
  2. Greentryst: EU CBAM 2026, the definitive regime
  3. Manglai: CBAM timeline 2026 and 2027
  4. European Commission: Carbon Border Adjustment Mechanism

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