EU CBAM Definitive Regime 2026

Compliance Readiness, Authorised Declarant Requirements, Certificate Obligations and Reporting Framework for Importers

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1. Executive Summary

From 1 January 2026, every EU importer of CBAM-covered goods must hold Authorised CBAM Declarant status, purchase and surrender certificates linked to verified embedded emissions, and file an annual declaration through the CBAM Definitive Registry — obligations that carry direct financial and legal consequences with no transitional grace period.

The first certificate surrender and declaration deadline is 30 September 2027, covering all 2026 imports; the Q1 2026 certificate price, set at approximately €75.36 per tonne CO₂e, establishes the initial cost benchmark, with three further quarterly prices to follow before year end. Certificate obligations for sectors such as steel — where draft Commission benchmarks suggest costs potentially exceeding €600 per tonne — create material financial exposure that most compliance teams have not yet fully modelled.

Three compliance risks dominate the 2026 preparation agenda. Importers operating without authorised declarant status cannot lawfully bring CBAM-covered goods into EU customs territory. Certificate cost exposure varies by sector and supply chain emissions intensity and requires active quarterly management, not a year-end adjustment. Verified embedded emissions data must come from non-EU producers, and the supplier engagement programme required to obtain it cannot be built close to the declaration deadline.

This report equips Compliance Managers with a structured implementation framework covering declarant authorisation, declaration architecture, certificate management, supplier data governance, registry administration, sector-specific exposure analysis, internal governance structure, and a sequenced preparation roadmap to the 30 September 2027 deadline.

Table 1 — EU CBAM at a Glance

Item	Detail
Regulation	Regulation (EU) 2023/956
Definitive regime launch	1 January 2026
Covered sectors	Steel and iron, aluminium, cement, fertilisers, hydrogen, electricity
Importer obligation	Authorised CBAM Declarant status required to import
Certificate basis	Verified embedded emissions in imported goods
Certificate price mechanism (2026)	Quarterly average of EU ETS allowance auction prices
Certificate price mechanism (2027+)	Weekly average of EU ETS allowance auction prices
First reported certificate price	~€75.36/tonne CO₂e (Q1 2026, published 7 April 2026)
First declaration deadline	30 September 2027 (covering 2026 imports)
Registry	CBAM Definitive Registry (European Commission)
Administering body	European Commission DG TAXUD / national competent authorities

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2. Regulatory Context

2.1 What Is EU CBAM?

The Carbon Border Adjustment Mechanism was established under Regulation (EU) 2023/956, published in the Official Journal of the European Union on 10 May 2023, as a carbon pricing instrument applied to imports of specific goods from countries without equivalent carbon costs. Its primary regulatory purpose is to prevent carbon leakage — the relocation of production from the EU to jurisdictions with less stringent emissions regulation — by ensuring that imported goods bear a carbon cost equivalent to that applied to EU domestic production under the EU Emissions Trading System (EU ETS).

The mechanism does not impose a tariff. It requires importers to surrender certificates representing the embedded carbon emissions of the goods they bring into EU customs territory, with certificate prices directly linked to the EU ETS allowance auction price.

The sectors covered under the definitive regime are steel and iron, aluminium, cement, fertilisers, hydrogen, and electricity. These sectors were selected on the basis of their emissions intensity and their exposure to carbon leakage risk under the EU ETS. The mechanism applies to imports from all third countries, with exemptions for countries whose carbon pricing systems are fully linked with the EU ETS — currently including EEA members (Iceland, Liechtenstein, Norway) and Switzerland — as specified in Article 2 of Regulation (EU) 2023/956.

CBAM certificate prices track the EU ETS allowance auction price over a reference averaging period, meaning carbon market volatility translates directly into CBAM cost uncertainty. For 2026 imports, the Commission calculates and publishes one quarterly price per calendar quarter; from 2027 onwards, pricing moves to a weekly basis. Compliance teams cannot treat certificate costs as a fixed budget line; they must model a range and plan for price movement throughout the compliance year.

Table 2 — EU ETS and CBAM Relationship Framework

Element	EU ETS	EU CBAM
Applies to	EU-based producers	Non-EU importers of covered goods
Compliance obligation	Surrender allowances for emissions	Surrender certificates for embedded emissions
Price mechanism (2026)	Auction / secondary market	Quarterly average of EU ETS auction prices
Price mechanism (2027+)	Auction / secondary market	Weekly average of EU ETS auction prices
Covered entities	EU installations	Authorised CBAM Declarants
Purpose	Reduce EU production emissions	Prevent carbon leakage at the border
Interaction	CBAM price tracks ETS price	ETS price drives CBAM certificate cost

2.2 What Changed on 1 January 2026?

Four substantive compliance changes took effect on 1 January 2026, each creating operational obligations that did not exist under the reporting-only framework in force from 1 October 2023 to 31 December 2025.

Authorised CBAM Declarant status. Under the transitional phase, EU importers were required to report embedded emissions quarterly but were not subject to an authorisation requirement as a precondition to importing. From 1 January 2026, only entities holding Authorised CBAM Declarant status — granted by the competent national authority in the member state of establishment — may import CBAM-covered goods into EU customs territory. An importer without authorisation cannot lawfully proceed with imports of covered goods.

Certificate purchase and surrender obligations. The transitional phase imposed no financial obligation tied to carbon content. The definitive regime requires importers to purchase CBAM certificates and surrender a number corresponding to the verified embedded emissions in their imported goods. This obligation applies to all authorised declarants for all imports of covered goods from 1 January 2026 onward, with the first surrender deadline on 30 September 2027.

Annual declaration filing requirements. Quarterly transitional reports have been replaced by annual CBAM declarations. Each declaration must cover all CBAM-covered imports made during the preceding calendar year, include verified embedded emissions data structured by CN code, country of origin, and production installation, and be accompanied by the corresponding certificate surrender. The declaration must be submitted through the CBAM Definitive Registry.

CBAM Definitive Registry administration. The transitional CBAM Registry has been replaced by the CBAM Definitive Registry, which serves as the central platform for declarant authorisation, certificate management, declaration submission, and ongoing compliance administration. Importers who managed transitional reporting through a separate system must migrate to and operate within the Definitive Registry framework.

Table 3 — Transitional Phase vs Definitive Regime Comparison

Compliance Element	Transitional Phase (Oct 2023–Dec 2025)	Definitive Regime (Jan 2026 onward)
Authorisation requirement	Not required	Authorised CBAM Declarant status mandatory
Financial obligation	None	Certificate purchase and surrender required
Reporting frequency	Quarterly emissions reports	Annual CBAM declaration
Reporting deadline	One month after quarter end (31 Jan / 30 Apr / 31 Jul / 31 Oct)	30 September following the reporting year
Certificate obligation	None	Surrender certificates equal to verified embedded emissions
Registry	Transitional CBAM Registry	CBAM Definitive Registry
Consequence of non-compliance	Penalties for late/inaccurate reporting	Penalties plus inability to import without authorisation

2.3 Key Regulatory Developments Since Launch

The European Commission formally confirmed that EU CBAM entered into force on 1 January 2026, with the CBAM Definitive Registry operational and authorisation processes open through national competent authorities across EU member states. Published on 14 January 2026, this confirmation marked the official end of the transitional phase and the start of certificate-related compliance obligations across all covered sectors.

In February 2026, the Commission advanced Omnibus simplification proposals addressing administrative burden under the definitive regime. Analysis published by Accountancy Europe in February 2026 identifies the proposed changes as covering certificate purchase mechanics, reporting burden, thresholds, and administrative complexity. These proposals are under active discussion and have not been adopted into the operative regulatory framework. Compliance teams should not adjust current obligations on the basis of proposed simplifications — the requirements of Regulation (EU) 2023/956 remain in full force until any amendment is formally enacted.

The Commission continued development and rollout of the CBAM Definitive Registry through to May 2026, with updated guidance on registry operation, reporting workflows, and authorisation processes published as recently as 26 May 2026. This guidance is the current authoritative operational reference for compliance administration and supersedes all transitional-phase documentation.

On scope expansion, Reuters reported in December 2025 that Commission drafts were examining extension of the CBAM framework to downstream manufactured goods and additional anti-circumvention measures, with further discussions anticipated from 2028 onward. These are proposals under examination, not adopted regulation. Compliance teams with exposure to downstream steel-intensive or aluminium-intensive products should monitor Commission consultation activity but need take no current compliance action.

Table 4 — Regulatory Development Timeline (2026)

Date	Development	Status	Operational Impact
1 January 2026	Definitive regime enters into force	Confirmed	All certificate and declarant obligations active
14 January 2026	Commission confirms successful launch	Confirmed	Registry and authorisation processes operational
February 2026	Omnibus simplification proposals advanced	Under discussion	No change to current obligations
26 May 2026	Updated CBAM guidance published by DG TAXUD	Confirmed	Current authoritative operational reference
Dec 2025–ongoing	Scope expansion to downstream products under examination	Proposed only	No current compliance action required
2028 onward	Scope expansion discussions expected to progress	Proposed only	Monitor Commission consultation activity

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3. Compliance Obligations

3.1 Authorised CBAM Declarant Requirements

Any legal entity established in an EU member state that imports CBAM-covered goods into EU customs territory from 1 January 2026 must hold Authorised CBAM Declarant status granted by the competent national authority in the member state of establishment. Importing CBAM-covered goods without this authorisation is not a reportable breach with a subsequent penalty — it is an immediate bar to lawful importation. The authorisation requirement is the foundational compliance obligation from which all other EU CBAM obligations follow.

Authorisation applications are submitted through the CBAM Registry. The European Commission DG TAXUD administers the central registry framework, while national competent authorities in each member state process applications, grant authorisation, and manage ongoing declarant compliance. Importers with operations across multiple member states must identify the correct competent authority in each relevant jurisdiction.

The eligibility criteria for authorised declarant status are specified in Article 17(2) of Regulation (EU) 2023/956 and further detailed in Commission Implementing Regulation (EU) 2025/486. They include: establishment in an EU member state with a valid EORI number; absence of serious or repeated infringements of customs, taxation, or market abuse rules in the five years preceding application; and financial and organisational capacity sufficient to meet certificate obligations, including demonstrated solvency and internal controls capable of managing CBAM certificate obligations. The financial solvency and internal controls criteria are conditions of continued authorisation, not one-time assessments at application — compliance teams must treat them as ongoing governance requirements.

Once authorised, declarants carry ongoing compliance responsibilities extending beyond declaration filing: maintaining the CBAM Registry account, purchasing and holding sufficient certificates throughout the compliance year, submitting verified annual declarations, surrendering certificates by the deadline, and cooperating with any audit or verification activity initiated by the competent authority. Authorised declarant status is not an administrative formality — it constitutes a continuous compliance commitment.

Table 5 — Authorised CBAM Declarant Eligibility Framework

Criterion	Requirement	Regulatory Basis	Compliance Action
Establishment	Legal entity in an EU member state with valid EORI	Article 5, Reg. (EU) 2023/956	Confirm legal entity registration and EORI in relevant member state
Application channel	CBAM Registry via competent national authority	Article 17(1), Reg. (EU) 2023/956	Identify competent authority in member state of establishment
Infringement record	No serious or repeated customs, tax, or market abuse infringements in prior 5 years	Article 17(2)(a); Implementing Reg. 2025/486	Review compliance history; resolve any open matters before applying
Financial solvency	Demonstrated solvency and internal controls for certificate management	Article 17(2)(b); Implementing Reg. 2025/486	Document financial standing; prepare evidence for authority review
Ongoing conditions	Criteria must continue to be met after authorisation granted	Article 17, Reg. (EU) 2023/956	Build internal process for continuous compliance management

3.2 Annual Declaration Obligations

The annual CBAM declaration must be submitted through the CBAM Definitive Registry by 30 September of the year following the import year, covering all CBAM-covered goods imported during the preceding calendar year. For 2026 imports, the declaration deadline is 30 September 2027. The declaration must include verified embedded emissions data structured by CN code, country of origin, and production installation — per Article 6 of Regulation (EU) 2023/956 — and must be accompanied by the surrender of CBAM certificates in a quantity corresponding to those verified emissions.

Working backward from the 30 September 2027 deadline, the data preparation timeline is demanding. Verified embedded emissions data must be collected from non-EU producers, validated against the applicable verification standard, and reconciled against import records before the declaration can be completed accurately. This process cannot be compressed into the weeks before the deadline — it requires systematic data collection throughout 2026 and formal verification activity in early 2027. Compliance teams that have not initiated supplier emissions data collection processes by mid-2026 will face significant preparation risk.

The declaration architecture requires reporting by CN code, country of origin, and production installation — not as a single aggregate annual figure. Data quality weaknesses at the point of import will compound over the compliance year and cannot be corrected retrospectively without risk of inaccuracy in the final declaration.

Table 6 — Annual Declaration Preparation Checklist

Preparation Step	Owner	Output Required	Timing
Confirm all CBAM-covered goods in import scope	Compliance / Customs	Confirmed goods classification list by CN code	By Q1 2026
Establish supplier emissions data collection process	Procurement / Compliance	Supplier data request templates and process	By Q1 2026
Collect embedded emissions data from non-EU producers	Procurement	Emissions data records per supplier / CN code	Throughout 2026
Commission third-party verification of emissions data	Compliance	Verified emissions data report	Q1–Q2 2027
Reconcile verified data against import records	Compliance / Finance	Reconciliation report by CN code and origin	Q2 2027
Calculate total CBAM certificate obligation	Finance / Compliance	Certificate obligation calculation	Q2 2027
Confirm certificate holdings sufficient for surrender	Finance	Certificate position confirmed	Q3 2027
Submit annual declaration via CBAM Registry	Compliance	Submitted declaration record	By 30 September 2027
Surrender certificates	Compliance / Finance	Certificate surrender confirmation	By 30 September 2027

3.3 CBAM Certificate Management Requirements

CBAM certificates must be surrendered by 30 September 2027 for all embedded emissions associated with CBAM-covered goods imported during 2026. The surrender obligation is not a year-end event — it is the culmination of a certificate management process that must operate continuously throughout the compliance year. Certificates are purchased through the CBAM Definitive Registry.

For 2026 imports, the Commission calculates and publishes one certificate price per calendar quarter, based on the quarterly average of EU ETS allowance auction clearing prices. From 2027 onwards, prices are published weekly. The first reported CBAM certificate price — covering Q1 2026 imports and published on 7 April 2026 — was approximately €75.36 per tonne CO₂e. This figure provides an indicative benchmark for financial planning purposes but does not represent a fixed price for the full compliance year. Each quarter of 2026 carries its own certificate price, and compliance teams must update their cost modelling as each quarterly price is published.

The operative regulation requires authorised declarants to maintain sufficient certificates in the registry corresponding to accumulated embedded emissions on a quarterly basis — per Article 22(2) of Regulation (EU) 2023/956. Compliance teams should consult current DG TAXUD guidance to confirm the operative quarterly holding threshold and build their certificate purchasing schedule accordingly.

A certificate shortfall at surrender triggers regulatory penalty exposure. Importers who underestimate their embedded emissions — through poor supplier data, calculation errors, or failure to account for all covered imports — will face a gap between their certificate holdings and their verified declaration, triggering enforcement action by the competent national authority.

Table 7 — Certificate Management Workflow

Stage	Action	Responsibility	Timing
1. Baseline estimation	Estimate full-year certificate obligation based on import volumes and available emissions data	Finance / Compliance	Q1 2026
2. Initial certificate purchase	Purchase certificates based on estimated Q1 2026 exposure at Q1 price	Finance	After Q1 2026 price published (April 2026)
3. Quarterly price monitoring	Obtain Commission-published quarterly price; update cost model	Finance / Compliance	Each quarter
4. Quarterly holding review	Review certificate holdings against accumulated embedded emissions	Finance / Compliance	Quarterly throughout 2026
5. Top-up purchases	Purchase additional certificates as import volumes or emissions data are updated	Finance	As required
6. Pre-declaration reconciliation	Reconcile certificate holdings against verified declaration figure	Finance / Compliance	Q2–Q3 2027
7. Final purchase (if required)	Purchase additional certificates to cover any shortfall before surrender	Finance	By September 2027
8. Certificate surrender	Surrender certificates via CBAM Registry	Compliance	By 30 September 2027

3.4 Supplier Emissions Data Governance

CBAM certificate obligations are calculated on verified embedded emissions data that must come from non-EU producers — entities outside EU jurisdiction, outside EU compliance culture, and in many cases without existing carbon reporting infrastructure. Compliance teams cannot calculate accurate CBAM obligations without this data. Where it is absent, incomplete, or unverifiable, the importer faces a direct trade-off between delayed declaration preparation and reliance on default values that increase certificate cost.

The embedded emissions data required for each declaration must cover the direct emissions associated with production of the imported goods and, where applicable, indirect emissions from electricity consumption during production. The data must be collected in the format and to the standard specified in the Commission's implementing guidance and must be capable of independent third-party verification. Verbal or approximate figures from suppliers do not satisfy the verification standard.

Where a non-EU producer cannot or will not provide verified emissions data, the operative regulation provides a fallback mechanism: default values set by CN code and country of origin in Commission Implementing Regulation (EU) 2025/2621. Where country-specific data is unavailable, default values are based on the average emission intensity of the ten highest-emission exporting countries for that good. Default values are not a cost-neutral fallback — they carry a 10% markup in 2026, rising to 30% by 2028, applied to incentivise use of actual verified data rather than defaults.

An importer sourcing from an efficient producer who relies on default values due to an absent supplier data programme will pay materially more in certificates than actual emissions warrant. The financial case for investing in supplier data governance is direct and quantifiable.

Compliance teams should establish a formal supplier engagement programme as a matter of priority. This requires identifying every non-EU producer in the supply chain for covered goods, issuing data requests in the correct format, establishing a verification process for received data, and maintaining records sufficient to support audit review. Suppliers unable to engage should be flagged for commercial risk review — the cost of default values plus markup may affect the viability of continued sourcing from that supplier.

Table 8 — Supplier Emissions Data Workflow

Step	Action	Output	Risk if Not Completed
1	Map all non-EU suppliers of CBAM-covered goods	Supplier register with goods classification by CN code	Incomplete declaration data
2	Issue emissions data requests in Commission-approved format	Data request documentation	Non-compliant data received
3	Receive and review supplier emissions data	Emissions data records	Data gaps requiring default values + markup
4	Commission third-party verification of supplier data	Verified emissions report	Declaration based on unverified data
5	Apply default values where supplier data unavailable	Default value calculation including applicable markup	Higher certificate cost than actual emissions warrant
6	Maintain complete data records for audit	Audit-ready data file	Inability to substantiate declaration

Table 9 — Verification Readiness Framework

Emissions Data Type	Verification Requirement	Default Value Risk
Direct production emissions	Third-party verification required	High — default values carry 10% markup in 2026
Indirect electricity emissions (cement, fertilisers)	Verification required where applicable	Medium — depends on electricity source in country of origin
Supplier-provided unverified estimates	Not acceptable for declaration	Default values apply automatically with markup
Data without CN code / origin / installation breakdown	Insufficient for Article 6 declaration structure	Declaration inaccuracy risk

3.5 CBAM Registry Administration and Controls

The CBAM Definitive Registry is the single operational platform through which every substantive compliance obligation under the definitive regime is administered — declarant authorisation, certificate purchasing, certificate holding management, annual declaration submission, and certificate surrender. Its administration must be treated with the governance discipline applied to any regulated financial or compliance system.

The registry operates under the administration of the European Commission DG TAXUD, with updated operational guidance published as recently as 26 May 2026. This guidance is the current authoritative reference for registry workflows and supersedes any earlier transitional-phase documentation.

For the compliance manager responsible for registry administration, the immediate priorities are account structure and access controls.

The registry must be configured with appropriate user permissions — the number of individuals with declaration submission and certificate surrender authority should be limited to those with defined responsibility and sign-off authority within the governance structure. Unrestricted registry access creates audit trail risk: if certificate purchases or declaration submissions cannot be attributed to a named authorised individual, the organisation's ability to demonstrate governance over its CBAM obligations is materially weakened.

Declaration submission within the registry must follow the architecture of the annual declaration — embedded emissions data by CN code, country of origin, and production installation, linked to specific import records, with certificates allocated to each element. The audit trail generated by registry activity will be the primary evidence base in any competent authority review or enforcement inquiry. Registry records should be treated as regulatory documents and archived accordingly.

Table 10 — Registry Governance Model

Governance Element	Requirement	Recommended Control
Account access	Restricted to authorised personnel	Named user accounts with defined permissions
Declaration submission authority	Limited to compliance sign-off holders	Dual authorisation for final declaration submission
Certificate purchase authority	Finance and compliance sign-off required	Segregation of purchase and surrender functions
Audit trail	All registry actions attributed to named users	Registry access log reviewed quarterly
Documentation retention	Records maintained for competent authority review	Archive policy aligned with national authority requirements
Registry guidance version	Use current DG TAXUD guidance (updated May 2026)	Review guidance updates quarterly

4. Key Dates and Deadlines

Every milestone from 1 January 2026 onward in the EU CBAM implementation timeline carries a direct compliance obligation. The timeline below covers the full regulatory arc from the initial transitional phase through to the first annual declaration and certificate surrender under the definitive regime.

Table 11 — EU CBAM Full Implementation Timeline (2023–2027)

Date	Milestone	Regulatory Basis	Action Required
1 October 2023	Transitional reporting phase begins	Regulation (EU) 2023/956	Quarterly emissions reporting commenced
10 May 2023	Regulation (EU) 2023/956 published in Official Journal	EUR-Lex	Operative legal basis established
31 December 2025	Transitional reporting-only phase ends	Regulation (EU) 2023/956	Final quarterly report submitted
1 January 2026	Definitive regime enters into force	European Commission / DG TAXUD	Declarant authorisation mandatory; certificate obligations active
14 January 2026	Commission confirms successful launch	DG TAXUD announcement	Registry and national authority processes operational
Throughout 2026	Certificate purchasing obligations active; quarterly prices published	Regulation (EU) 2023/956; Implementing Reg. 2025/2548	Purchase and hold certificates per quarterly price
30 September 2027	First annual declaration and certificate surrender deadline	ICAP Carbon Action / Regulation (EU) 2023/956	Submit declaration; surrender certificates for 2026 imports

Three milestones carry the greatest operational preparation lead time.

• First, the 1 January 2026 authorisation requirement — any importer that did not obtain Authorised CBAM Declarant status before this date has been operating outside the lawful framework and must resolve this immediately.

• Second, the certificate purchase obligation active throughout 2026, which requires financial planning, quarterly EU ETS price monitoring, and procurement of certificates on a continuous basis rather than as a year-end activity.

• Third, the 30 September 2027 declaration deadline, which requires verified embedded emissions data from all non-EU producers covering the full 2026 import year — data that must be collected systematically throughout 2026 and verified in early 2027.

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5. Financial Exposure and Risk

5.1 Certificate Cost Exposure

CBAM certificate prices for 2026 imports are calculated by the European Commission on a quarterly basis, as the weighted average of EU ETS allowance auction clearing prices for each calendar quarter, per Commission Implementing Regulation (EU) 2025/2548. The first quarterly certificate price — covering Q1 2026 imports — was approximately €75.36 per tonne CO₂e, published on 7 April 2026. Subsequent quarterly prices are published within the first week following each quarter end. From 2027 onwards, certificate pricing moves to a weekly basis. Each quarter of 2026 carries its own price, and EU ETS market movements will determine the cost of certificates for Q2, Q3, and Q4 imports — compliance teams cannot treat the Q1 figure as representative of the full year.

Certificate cost exposure is calculated against verified embedded emissions: the total tonnes of CO₂ equivalent attributable to the production of imported CBAM-covered goods, multiplied by the applicable quarterly certificate price. For high-emission import profiles, this exposure is material. Draft Commission benchmark data reported by Reuters in December 2025 indicated that aluminium imports from certain origins could face CBAM costs around €168 per tonne, while certain steel imports may face costs exceeding €600 per tonne depending on emissions intensity. These are sector-level estimates based on draft Commission data, not confirmed final figures, but they indicate the order of magnitude of financial exposure in the most emissions-intensive supply chains.

Finance teams should model certificate cost exposure across three scenarios: a base case using the current EU ETS price, a downside case using a lower price assumption, and an upside case using a higher price to stress-test budget impact. Modelling should be updated each quarter as the Commission publishes new certificate prices and as verified emissions data from suppliers is received and confirmed.

Table 12 — Certificate Exposure Model Framework

Input	Data Source	Planning Consideration
Annual import volume by CBAM sector	Customs and procurement records	Confirm all covered goods and CN codes are included
Embedded emissions per tonne (verified)	Supplier verified data / default values	Distinguish verified from default — default carries 10% markup in 2026
Quarterly CBAM certificate price	Commission publication (DG TAXUD)	Update each quarter; model a price range across full year
Base cost estimate	Volume × emissions intensity × quarterly certificate price	Use for budget planning per quarter
High-cost scenario	Apply higher EU ETS price assumption to remaining quarters	Stress-test full-year financial exposure
Default value premium	Compare verified emissions to applicable default + markup	Quantify cost of absence of supplier data programme

5.2 Enforcement and Non-Compliance Risk

Regulation (EU) 2023/956 establishes that importers who fail to surrender sufficient certificates to cover verified embedded emissions are liable for penalties under the definitive regime. The operative regulation confirms penalty exposure for certificate shortfalls, but a precise per-tonne penalty figure is not available in the current research data — compliance teams should verify the operative penalty rate directly in the regulation and current DG TAXUD guidance. The absence of a confirmed figure does not reduce enforcement risk; the financial consequence of a shortfall must be assessed against the regulation itself.

Enforcement triggers under the definitive regime include: failure to hold Authorised CBAM Declarant status while importing covered goods; failure to submit the annual declaration by 30 September of the relevant year; failure to surrender sufficient certificates to match the verified declaration; submission of a declaration containing inaccurate embedded emissions data; and failure to maintain the registry records required for competent authority review.

The audit exposure is significant and underappreciated. The CBAM Definitive Registry creates a complete and auditable record of every import, every certificate purchase, every declaration, and every surrender. Competent national authorities have full visibility of this record. Discrepancies between import records and declared emissions, certificate positions that do not align with accumulated imports, or declarations that cannot be supported by verified supplier data are visible in the registry record and subject to enforcement inquiry without any additional investigation being required by the authority.

Table 13 — Compliance Risk Matrix

Risk	Trigger	Consequence	Mitigation
Importing without authorisation	No Authorised CBAM Declarant status	Inability to import lawfully; regulatory penalty	Apply for authorisation immediately if not yet held
Late declaration	Declaration submitted after 30 September 2027	Penalty exposure	Build declaration preparation timeline from now
Certificate shortfall	Certificates surrendered < verified emissions	Penalty exposure; competent authority inquiry	Maintain quarterly certificate holding review
Inaccurate declaration	Emissions data errors or omissions	Declaration correction required; potential penalty	Commission third-party verification of all data
Default value reliance	Supplier data unavailable	Overpayment vs verified data; 10% markup applied in 2026	Invest in supplier emissions data programme
Registry documentation failure	Audit trail insufficient for competent authority review	Enforcement inquiry; inability to substantiate declaration	Implement registry governance controls

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6. Sector-Specific Impact Analysis

6.1 Steel and Iron

Steel and iron imports carry the broadest EU CBAM compliance burden in the definitive regime, reflecting the sector's emissions complexity and the diversity of production routes covered. Under Annex II of Regulation (EU) 2023/956, only direct emissions apply to iron and steel. The primary compliance challenge is the granularity required — direct process emissions must be reported by CN code, country of origin, and production installation, and steel and iron production generates direct process emissions from both blast furnace operations and electric arc furnace operations, which have materially different emissions intensities. Supply chains spanning multiple origins and production routes compound the data collection burden.

The supplier data challenge for steel importers is acute. Many non-EU steel producers, particularly in high-emission jurisdictions, have limited carbon reporting infrastructure and may have no established process for producing the structured emissions data required for an EU CBAM declaration. Importers with diversified steel supply chains should map their top suppliers by volume, identify those in jurisdictions without equivalent carbon pricing, and prioritise data engagement with those suppliers before the end of 2026.

Draft Commission benchmarks referenced in Reuters reporting from December 2025 indicated that certain steel imports may face CBAM costs exceeding €600 per tonne depending on emissions intensity. This figure represents a sector-specific cost exposure at the upper end of current benchmark estimates and underlines that certificate cost management is a material procurement consideration for steel importers operating at scale.

6.2 Aluminium

Aluminium imports are subject to EU CBAM on the basis of direct process emissions only, as specified in Annex II of Regulation (EU) 2023/956. Indirect electricity emissions are not included in the embedded emissions calculation for aluminium under the current regulation. The compliance focus for aluminium importers is therefore on obtaining and verifying direct process emissions data from smelters — specifically, the direct emissions generated during the electrolytic reduction process.

The supplier data challenge for aluminium importers centres on the concentration of production in a relatively small number of large smelting operations, many of which are located in jurisdictions with limited carbon reporting culture. Data requests must be structured around direct process emissions per tonne of aluminium produced, consistent with the CN code classification and production installation framework required under Article 6. Where verified direct emissions data cannot be obtained, default values will apply — with the associated markup — and importers should model the cost differential as part of their supplier engagement commercial case.

Reuters reporting from December 2025 referenced draft Commission benchmark data suggesting aluminium imports from certain origins could face CBAM costs around €168 per tonne. This sector-level estimate should inform financial planning exercises but is drawn from draft benchmarks and must be treated as indicative.

6.3 Cement

Cement imports carry a high direct emissions burden tied to the chemical process of clinker production, which releases CO₂ as a by-product of limestone calcination. This process emission is inherent to conventional cement production and cannot be materially reduced without fundamental changes to production technology. Unlike steel and aluminium, cement and fertiliser imports are subject to both direct and indirect emissions under the CBAM framework — indirect emissions from electricity consumption during production are included in the embedded emissions calculation.

The compliance challenge for cement importers is primarily one of data precision rather than data availability. Cement producers in major exporting countries are more likely than some other sectors to have engaged with EU CBAM reporting during the transitional phase, meaning data relationships may already exist. Compliance teams should review transitional-phase data quality, confirm that both direct and indirect emissions data meets the verification standard required under the definitive regime, and update supplier agreements to ensure ongoing data provision.

6.4 Fertilisers

Fertiliser imports under EU CBAM are primarily covered in relation to nitrogen-based products, where the production process generates significant direct emissions from the use of natural gas as a feedstock and energy source in ammonia production. Like cement, fertilisers are subject to both direct and indirect emissions in the embedded emissions calculation under the CBAM framework.

The supplier data challenge in fertilisers is compounded by the concentration of production in a small number of major exporting countries where carbon reporting is not embedded in standard commercial practice. Importers should not assume that the fertiliser sector's relative familiarity with EU regulatory requirements translates into emissions data readiness at the level required for CBAM declarations. Formal data requests covering both direct and indirect emissions, with third-party verification arrangements, should be established with all major fertiliser suppliers.

6.5 Hydrogen

Hydrogen is included in the EU CBAM scope under the definitive regime, with embedded emissions varying significantly by production method. Grey hydrogen — produced from natural gas without carbon capture — carries high embedded emissions. Green hydrogen, produced by renewable electrolysis and certified as an RFNBO, carries near-zero embedded emissions for CBAM certificate calculation purposes. The first task for compliance teams managing hydrogen imports is to confirm the production method and certification status for each supplier and ensure the embedded emissions data reflects the actual production route.

Production method claims from non-EU producers must be substantiated with verifiable evidence. A supplier claiming to produce green or low-carbon hydrogen but unable to provide certification evidence cannot support a near-zero emissions declaration. Where production method cannot be verified, default values will apply — and for hydrogen, default values reflect the most emissions-intensive production pathway. The Authorised CBAM Declarant obligation and annual declaration requirement apply regardless of production method; certificate surrender obligations approach zero only for genuinely certified near-zero-emissions hydrogen.

6.6 Electricity

Electricity imports into the EU are subject to EU CBAM where they are directly imported through interconnectors. Unlike commodity sectors, the embedded emissions calculation is based on the carbon intensity of electricity generation in the exporting country rather than a manufacturing process. Compliance obligations for electricity importers are therefore directly tied to the carbon intensity of the exporting country's generation mix, which can change year on year as the generation portfolio evolves.

Table 14 — Sector Exposure Comparison

Sector	Emissions Scope (per Reg. 2023/956)	Data Collection Complexity	Certificate Cost Exposure	Key Implementation Risk
Steel and iron	Direct only (Annex II)	High — multiple production routes; blast furnace vs EAF	High — up to ~€600/t on draft benchmarks	Supply chain breadth; multi-origin data gaps
Aluminium	Direct only (Annex II)	Moderate — direct process emissions per smelter	Moderate to high — ~€168/t on draft benchmarks	Direct process data from smelters; default value markup
Cement	Direct + indirect electricity	Moderate	High — inherently emissions-intensive	Ensure both direct and indirect data verified
Fertilisers	Direct + indirect electricity	Moderate to high	Moderate to high	Supplier data gaps in major exporting countries
Hydrogen	Direct only; varies by production method	High — production method verification required	Near-zero if certified green; high if grey	Production method claims without substantiating evidence
Electricity	Generation carbon intensity	Moderate	Depends on exporting country grid	Exporting country grid carbon intensity changes year on year

Table 15 — Sector Readiness Assessment Matrix

Sector	Transitional Data Likely Available	Verification Upgrade Required	Default Value Risk	Priority Action
Steel and iron	Partial	Yes — structured by CN code / installation required	High	Map suppliers; commission data requests now
Aluminium	Partial	Yes — direct process data only; confirm Annex II scope	Moderate	Clarify direct-only scope with suppliers; structure data requests accordingly
Cement	Likely	Yes — confirm direct + indirect both verified	Moderate	Review transitional data quality; update agreements
Fertilisers	Partial	Yes — direct + indirect required	High	Formal supplier engagement programme required
Hydrogen	Limited	Yes — production method certification required	Very high	Confirm RFNBO or other certification evidence for each supplier
Electricity	Variable	Review against current guidance	Moderate	Confirm exporting country carbon intensity data

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7. Practical Action Framework

7.1 Compliance Manager Readiness Checklist

The following 15-step process constitutes the minimum compliance implementation roadmap for an EU importer of CBAM-covered goods under the definitive regime. Each step identifies the responsible function, the output required, and the applicable regulatory reference.

1. Confirm Authorised CBAM Declarant status. Owner: Compliance. Verify that the organisation holds valid authorised declarant status from the competent national authority. If not yet obtained, initiate the application through the CBAM Registry immediately. Regulatory reference: Article 17, Regulation (EU) 2023/956; Implementing Regulation (EU) 2025/486.

2. Map all CBAM-covered goods in the import portfolio. Owner: Compliance / Customs. Produce a complete register of all goods imported that fall within EU CBAM covered sectors — steel and iron, aluminium, cement, fertilisers, hydrogen, electricity — confirmed by eight-digit CN code and country of origin against Annex I of Regulation (EU) 2023/956. Output: Confirmed covered-goods register.

3. Identify all non-EU suppliers for covered goods. Owner: Procurement / Compliance. For every CBAM-covered good identified in step 2, identify the non-EU producer. Where goods are sourced through intermediaries, trace back to the original production entity. Output: Non-EU supplier register for CBAM purposes.

4. Confirm CBAM Registry account structure and access controls. Owner: Compliance. Review the CBAM Definitive Registry account, confirm user permissions are appropriately restricted, and establish dual authorisation for declaration submission and certificate surrender. Output: Registry governance documentation.

5. Establish a supplier emissions data request programme. Owner: Procurement. Issue formal embedded emissions data requests to all non-EU producers, using the Commission-approved format. Specify the correct emissions scope per sector (direct only for steel, aluminium, hydrogen; direct plus indirect for cement, fertilisers). Set a data return deadline that allows time for verification before declaration preparation. Output: Data request documentation with response tracking.

6. Assess initial certificate cost exposure. Owner: Finance / Compliance. Using available import volume data and indicative embedded emissions estimates, produce a baseline certificate cost range for 2026 imports. Model three scenarios: base, low, and high EU ETS price assumptions. Use the Q1 2026 benchmark price of €75.36/tonne CO₂e as a starting reference; update as subsequent quarterly prices are published. Output: Certificate exposure model — Q1 2026.

7. Initiate certificate purchasing. Owner: Finance. Begin purchasing CBAM certificates through the CBAM Registry on a schedule aligned with the quarterly holding obligation. Do not defer all purchases to the period immediately before surrender. Output: Certificate purchasing schedule; registry holdings record.

8. Establish a quarterly certificate holding review. Owner: Finance / Compliance. Implement a quarterly review process comparing certificate holdings against accumulated estimated embedded emissions for the year to date. Update purchasing schedule each quarter as new certificate prices are published and as import volume data is updated. Output: Quarterly certificate position review record.

9. Receive and review supplier emissions data. Owner: Procurement / Compliance. As supplier data responses are received, review for completeness and format compliance. Identify gaps, apply default values where necessary, and flag commercial risk where continued default value reliance — including the 10% markup in 2026 — will materially increase certificate costs. Output: Supplier data review log.

10. Commission third-party verification of emissions data. Owner: Compliance. Appoint a qualified verifier to verify embedded emissions data received from non-EU producers, in accordance with the verification standard required under the definitive regime. Output: Verified emissions data report.

11. Reconcile verified emissions data against import records. Owner: Compliance / Finance / Customs. Cross-reference verified emissions data against the full import record for 2026, structured by CN code, country of origin, and production installation, to confirm that all covered imports are accounted for in the declaration. Output: Reconciliation report.

12. Calculate final certificate obligation. Owner: Finance / Compliance. Based on verified emissions data and the reconciliation report, calculate the precise number of certificates required for surrender. Compare against current certificate holdings. Purchase additional certificates if a shortfall exists. Output: Final certificate obligation calculation; confirmation of sufficient holdings.

13. Prepare the annual declaration. Owner: Compliance. Using verified emissions data and the final certificate calculation, prepare the annual CBAM declaration for 2026 imports in the CBAM Definitive Registry, structured per Article 6 requirements. Output: Draft annual declaration in registry.

14. Complete internal governance sign-off. Owner: Compliance Director / CFO (as defined in governance structure). Subject the declaration to internal review and formal sign-off before submission. Output: Signed declaration authorisation record.

15. Submit declaration and surrender certificates by 30 September 2027. Owner: Compliance. Submit the completed annual declaration and surrender the corresponding certificates through the CBAM Definitive Registry by 30 September 2027. Output: Declaration submission confirmation; certificate surrender record. Regulatory reference: Article 6 and Article 22, Regulation (EU) 2023/956.

7.2 Internal Governance Structure

The most common EU CBAM governance failure is a single compliance manager carrying obligations that are operationally distributed across five or six business functions — procurement, finance, customs, legal, sustainability, and compliance — without formal ownership assignments, escalation paths, or budget authority. This structure fails not because the compliance manager lacks competence but because EU CBAM obligations cannot be discharged by compliance alone: certificate purchasing requires finance authority, supplier data collection requires procurement engagement, import classification requires customs expertise, and contractual supplier obligations require legal involvement.

The RACI matrix below defines the minimum ownership structure required for functional EU CBAM compliance governance.

Table 16 — CBAM Governance RACI Matrix

Obligation	Compliance	Finance	Procurement	Customs	Legal
Declarant authorisation	R/A	C	—	C	C
Registry administration	R/A	C	—	—	—
Covered goods classification	R	—	C	A	—
Supplier data requests	C	—	R/A	—	C
Emissions data verification	R/A	C	C	—	—
Certificate purchasing	C	R/A	—	—	—
Quarterly holding review	R	A	—	—	—
Declaration preparation	R/A	C	C	C	—
Declaration sign-off	C	C	—	—	A
Certificate surrender	R	A	—	—	—
Audit / competent authority response	R/A	C	C	C	C

R = Responsible; A = Accountable; C = Consulted

Finance must be engaged from the outset because certificate purchasing requires budget allocation, cash flow management aligned to quarterly purchase timing, and quarterly financial review of certificate position against accumulating emissions liability. Procurement's involvement is non-optional because the supplier data programme — the foundation of accurate declarations — cannot be managed by compliance in isolation from the commercial relationships that procurement owns.

Customs holds import classification expertise without which the covered-goods register cannot be confirmed with the CN code specificity required for accurate declarations. Legal involvement is required for supplier contractual arrangements that create data provision obligations and for any enforcement or audit response engagement.

7.3 Preparing for the First Declaration Deadline

Working backward from the 30 September 2027 declaration and certificate surrender deadline, the preparation roadmap has five sequenced phases that must be completed in order.

Table 17 — Declaration Readiness Timeline

Phase	Period	Actions Required	Output
Phase 1 — Foundation	Q1 2026	Confirm authorisation; map covered goods by CN code; identify suppliers; establish registry governance; initiate certificate purchasing at Q1 2026 price	Covered-goods register; supplier register; registry governance documentation; initial certificate holdings
Phase 2 — Data Collection	Q2–Q4 2026	Issue supplier data requests; receive and review responses; apply default values where required; maintain quarterly certificate holding review; update cost model each quarter as new prices published	Supplier emissions data file; quarterly certificate position records
Phase 3 — Verification	Q1–Q2 2027	Commission third-party verification of all supplier emissions data; reconcile verified data against import records by CN code, origin, and installation	Verified emissions data report; reconciliation report
Phase 4 — Declaration Preparation	Q2–Q3 2027	Calculate final certificate obligation; confirm certificate holdings; purchase additional certificates if required; prepare annual declaration in registry per Article 6	Final certificate obligation calculation; draft declaration
Phase 5 — Submission and Surrender	By 30 September 2027	Internal sign-off; declaration submission; certificate surrender	Submitted declaration record; certificate surrender confirmation

Phase 2 is the critical dependency. If the supplier data collection programme is not initiated in Q1 2026 and managed systematically throughout the year, Phase 3 verification cannot be completed with sufficient time for accurate declaration preparation in Phase 4.

Compliance teams that begin data collection late will face a forced choice between relying on default values — with the associated certificate cost markup — or submitting a late or inaccurate declaration.

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8. Strategic Outlook 2026–2027

Two categories of regulatory development are under active Commission examination and will materially affect compliance planning horizons beyond the immediate 2027 declaration cycle.

Downstream product expansion. Reuters reporting from December 2025 cited Commission draft documents examining the extension of EU CBAM to downstream manufactured goods — including steel-intensive and aluminium-intensive products — with further discussions anticipated from 2028 onward.

The rationale is to address circumvention risk: importers sourcing finished or semi-finished products incorporating covered commodities can currently avoid certificate obligations that would apply if they imported the raw commodity directly.

The Commission's examination of this expansion is confirmed through available reporting; formal adoption has not occurred. Organisations with downstream products incorporating CBAM-covered commodities in their import portfolios should monitor Commission consultation activity and assess potential exposure on a precautionary basis.

Anti-circumvention measures. The same Reuters reporting identified Commission drafts examining anti-circumvention measures designed to address import routing strategies that reduce CBAM exposure without genuinely reducing the carbon content of imported goods. Supply chain restructuring undertaken solely to minimise CBAM certificate obligations carries regulatory risk under forthcoming measures and should not be treated as a durable strategy.

Omnibus simplification reforms. The Commission advanced simplification proposals in February 2026, as analysed by Accountancy Europe. These proposals address certificate purchasing mechanics, threshold adjustments, and administrative burden reduction. They are under discussion and have not been adopted. Compliance programmes should be built around the operative requirements of Regulation (EU) 2023/956 as currently in force; any simplification subsequently adopted will reduce burden, and compliance teams can adjust accordingly.

Enforcement evolution. The CBAM Definitive Registry provides competent national authorities with a complete and auditable compliance record from the first day of the definitive regime. Enforcement is not dependent on proactive investigation — discrepancies are visible in registry data. As the 30 September 2027 deadline approaches, enforcement activity by national competent authorities can be expected to intensify as they identify declarants with incomplete data, certificate shortfalls, or delayed submissions.

Table 18 — Strategic Regulatory Outlook Framework

Development	Current Status	Anticipated Timeline	Compliance Action Required Now
Downstream product expansion	Under Commission examination	2028 onward	Monitor; assess downstream import exposure
Anti-circumvention measures	Under Commission examination	2028 onward	Avoid supply chain restructuring for CBAM avoidance
Omnibus simplification	Under discussion; not adopted	Uncertain	Continue compliance under current operative regulation
Enforcement intensification	Registry data active from January 2026	From 2027 declaration cycle	Ensure registry records are complete and audit-ready

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9. FAQ Section

Q: What internal departments should own EU CBAM compliance after January 2026?

A: Compliance owns declarant authorisation, registry administration, declaration preparation, and certificate surrender. Finance owns certificate purchasing, quarterly holding management, and cost modelling. Procurement owns the supplier emissions data programme. Customs owns covered-goods classification by CN code and country of origin. Legal owns supplier contractual arrangements and enforcement response. Each function must have defined responsibilities assigned before the compliance year is underway.

Q: What evidence will regulators expect during a CBAM audit?

A: Competent national authorities will expect complete registry records for the declaration year, verified embedded emissions data from non-EU producers with supporting verification documentation, evidence of certificate purchases and holdings throughout the year, and the reconciliation between verified emissions and certificates surrendered. Where default values have been used, evidence that verified supplier data was requested and could not be obtained will be required. Per Article 8(6) of Regulation (EU) 2023/956, records must be maintained in audit-ready condition for at least four years after the declaration year.

Q: How should we manage suppliers that cannot provide verified emissions data?

A: Commission Implementing Regulation (EU) 2025/2621 permits use of default values set by CN code and country of origin where verified data cannot be obtained. Default values carry a 10% markup in 2026, rising to 30% by 2028. Document that a data request was made and was not fulfilled, apply the applicable default value including markup to the relevant imports, and assess whether the resulting certificate cost premium affects the commercial case for continued sourcing from that supplier.

Q: What controls should be implemented around CBAM Registry access and reporting approvals?

A: Registry access should be restricted to named individuals with defined compliance or finance responsibilities. Declaration submission and certificate surrender should require dual authorisation — a preparer and an approver with distinct registry permissions. All registry actions should be logged and the access log reviewed quarterly. Registry governance documentation should form part of the organisation's compliance records.

Q: How should we estimate certificate purchasing costs before annual declarations are due?

A: Certificate costs for 2026 imports are calculated per quarter: import volume × verified embedded emissions intensity × the Commission-published quarterly price. The Q1 2026 price was approximately €75.36 per tonne CO₂e, published 7 April 2026; subsequent quarterly prices are published within the first week after each quarter closes. Where verified supplier data is not yet available, draft Commission benchmark figures for aluminium (~€168/t) and steel (potentially exceeding €600/t) from Reuters December 2025 reporting can inform planning estimates, but these should be treated as indicative.

Q: What practical steps should be completed before the first declaration deadline in 2027?

A: Compliance teams must confirm authorised declarant status, map all 2026 CBAM-covered imports by CN code and country of origin, collect and have verified all embedded emissions data from non-EU producers, purchase and hold sufficient certificates throughout 2026 on a quarterly basis, prepare the annual declaration in the CBAM Definitive Registry per Article 6, complete internal governance sign-off, and submit the declaration with corresponding certificate surrender by 30 September 2027. Supplier data collection must begin in Q1 2026 — it is the critical path item for the entire preparation timeline.

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10. References and Sources

EU Legislation

• Official Journal of the European Union │ Regulation (EU) 2023/956 Establishing a Carbon Border Adjustment Mechanism │ 10 May 2023 │ https://eur-lex.europa.eu/eli/reg/2023/956/oj/eng

• EUR-Lex │ Carbon Border Adjustment Mechanism Summary │ Updated 2026 │ https://eur-lex.europa.eu/EN/legal-content/summary/carbon-border-adjustment-mechanism.html

Commission Guidance and Announcements

• European Commission DG TAXUD │ Carbon Border Adjustment Mechanism │ Updated 2026 │ https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en

• European Commission DG TAXUD │ CBAM Legislation and Guidance │ 26 May 2026 │ https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-legislation-and-guidance_en

• European Commission DG TAXUD │ CBAM Registry and Reporting │ Updated May 2026 │ https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-registry-and-reporting_en

• European Commission DG TAXUD │ CBAM Successfully Entered Into Force on 1 January 2026 │ 14 January 2026 │ https://taxation-customs.ec.europa.eu/news/cbam-successfully-entered-force-1-january-2026-2026-01-14_en

Implementation and Market Intelligence

• ICAP Carbon Action │ EU CBAM Enters Compliance Phase and Outlines Path Ahead │ 19 January 2026 │ https://icapcarbonaction.com/en/news/eu-cbam-enters-compliance-phase-and-outlines-path-ahead

• Accountancy Europe │ CBAM Proposed Changes │ 17 February 2026 │ https://accountancyeurope.eu/publications/cbam-proposed-changes/

• Net0 │ EU CBAM in 2026: Definitive Regime, Omnibus Simplification and First Certificate Price │ 17 April 2026 │ https://net0.com/blog/the-eu-carbon-border-adjustment-mechanism-cbam

• Business.gov.uk │ EU Carbon Border Adjustment Mechanism (EU CBAM) │ 13 April 2026 │ https://www.business.gov.uk/campaign/europe/european-union-eu-regulations/eu-carbon-border-adjustment-mechanism-eu-cbam/

Sector and Scope Intelligence

• Reuters │ EU Aluminium and Cement Imports to Face Higher Emissions Costs, Draft Shows │ December 2025 │ https://www.reuters.com/sustainability/climate-energy/eu-aluminium-cement-imports-face-higher-emissions-costs-draft-shows-2025-12-12/

• Reuters │ EU to Widen Carbon Border Levy to Close Loopholes on Polluting Goods │ December 2025 │ https://www.reuters.com/sustainability/boards-policy-regulation/eu-extend-carbon-border-levy-new-products-drafts-show-2025-12-16/

CBAM Journal · Sekason Research Limited · London · cbamjournal.com

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