CBAM in 2026: what exporters and EU importers must do
The EU Carbon Border Adjustment Mechanism (CBAM) moved from its transitional phase into the definitive period on 1 January 2026. For exporters of steel, aluminium, cement, fertilisers, hydrogen and electricity, and for the EU companies that import these goods, CBAM in 2026 is no longer a reporting exercise. Embedded emissions now carry a cost, and the quality of your data decides how large it is.
Transitional period vs definitive period
From October 2023 to the end of 2025, CBAM ran in a transitional phase. EU importers filed quarterly reports on the embedded emissions of the goods they imported, but paid nothing. Default values could be used widely while installations got their data in order.
From 2026, the definitive period applies. Importers must be authorised CBAM declarants, and they will surrender CBAM certificates that reflect the embedded emissions of their imports, adjusted for any carbon price already paid in the country of production and for free allocation phasing out under the EU Emissions Trading System. The first annual CBAM declaration, covering goods imported in 2026, is due in 2027.
Dates, thresholds and procedures have been adjusted by EU simplification measures. Always check the latest European Commission guidance for the rules that apply to your shipments.
Which goods are covered
- Iron and steel, including many downstream products
- Aluminium
- Cement and clinker
- Fertilisers
- Hydrogen
- Electricity
Coverage is defined by customs (CN) codes. The list of goods may be extended over time, so exporters of related products should keep watch.
Embedded emissions: direct and indirect
Embedded emissions are the greenhouse gases released in producing a good, expressed per tonne. They include:
- Direct emissions from fuels and processes at the installation.
- Indirect emissions from the electricity consumed, for the goods where these count.
- Emissions from precursors — relevant inputs such as clinker in cement or pig iron in steel.
Emissions are attributed to production processes and then to products, giving specific embedded emissions (SEE) per tonne for each good.
Actual values vs default values
Where actual installation data is not available, default values can be used. Defaults are set conservatively and, in the definitive period, are expected to include mark-ups. For an efficient producer, actual values will usually mean lower embedded emissions — and fewer certificates for the importer. Actual values must be determined under the CBAM monitoring rules and verified by an accredited verifier.
Verification and the data trail
In the definitive period, actual embedded emissions used in a declaration need to be verified by an accredited verifier. Verifiers look for the same things in every case: a clear monitoring approach, complete activity data, correct emission factors, a sound allocation of emissions to products and evidence for each figure. Installations that already keep a disciplined GHG inventory are at an advantage, because most of the work is the same. Gaps found late — missing fuel records, unclear precursor sources, electricity data that cannot be traced to a meter — are expensive to fix under deadline pressure.
It also helps to keep CBAM data and your corporate inventory in one system. When the same approved fuel and electricity entries feed both, the numbers reconcile and a verifier has one trail to follow instead of two spreadsheets that disagree.
What exporters and installation operators should do now
- Map installations and production routes for every CBAM good you sell into the EU.
- Set up monitoring of fuels, process inputs, electricity and precursors by installation.
- Calculate specific embedded emissions per product and CN code.
- Prepare for verification — keep evidence and a clear calculation trail.
- Share data with customers using the standard communication template, so importers can use actual values.
- Record any carbon price paid locally, which may reduce the importer's obligation.
What EU importers should do now
- Make sure you are, or will be, an authorised CBAM declarant.
- Identify every supplier and installation behind your CBAM imports.
- Request actual, verified embedded emissions data from them.
- Compare actual against default values to understand your exposure.
- Build the data trail you will need for the annual declaration in 2027.
How EKOTRACE supports CBAM
EKOTRACE handles CBAM for producers and importers in the same platform as your GHG inventory. Producers model installations, processes and precursors, calculate direct and indirect embedded emissions per product and share them with customers. Importers collect installation data from suppliers through the supplier portal and see actual against default values. The same evidence, approvals and versioned emission factors apply, ready for verification. Learn more on our CBAM Compliance page, or see how CBAM fits alongside ESG reporting.
Frequently asked questions
Does CBAM apply to exporters outside the EU?
The legal obligation sits with the EU importer, but importers depend on exporters' data. In practice, exporters that can supply verified actual values are better placed with EU customers.
Can we keep using default values?
Defaults remain available but are designed to be conservative. Actual verified data is usually more favourable for efficient producers.