Executive summary:
On 1 January 2026, the EU’s Carbon Border Adjustment Mechanism (CBAM) entered its Definitive phase.
After two years of transitional reporting, CBAM has shifted from a monitoring obligation to a fully enforceable customs and financial mechanism. For EU importers, this means new costs, stricter controls, and clear compliance deadlines.
CBAM is no longer a future consideration. It must now be embedded into customs processes, supplier management, and cost planning.
We break down the key changes importers need to understand:
- What changed on the 1st of January 2026
- Which goods and companies are affected
- What importers must do now to remain compliant
From Reporting to Enforcement: What Changed in 2026
During the transitional phase (October 2023-December 2025), importers were only required to submit quarterly CBAM reports. These reports covered embedded greenhouse gas emissions for certain carbon‑intensive goods, but no financial adjustment applied.
From the 1st of January 2026, CBAM entered its definitive phase. Three changes are especially important for importers:
1. CBAM Certificates Are Now Mandatory
Importers must now purchase and surrender CBAM certificates to cover the embedded emissions of CBAM‑covered goods imported into the EU during 2026. The price of CBAM certificates for 2026 is linked to the quarterly average price of EU Emissions Trading System (EU ETS) allowances, as made public by the EU commission in the first week of April 2026.
This means CBAM is no longer just an administrative task, it is a direct cost that must be forecast, budgeted, and managed.
2. Only Authorised CBAM Declarants Can Import
As of 2026, companies who are importing more than 50 tonnes yearly must act as Authorised CBAM declarants. If an Importer is importing less than 50 tonnes per year, then they are not required to report. Where the importer is a non-EU entity, an indirect representative must be appointed to act on their behalf for CBAM purposes.
Authorisation for EU companies importing more than 50 tonnes of CBAM-covered goods per year requires:
- Access to the CBAM trader portal, including the necessary system setup (H3 for the Netherlands, Elster for Germany, etc.)
- Registration with the national competent authority
- Demonstration of sufficient financial and operational capacity to meet CBAM obligations
- Systems in place to collect emissions data from suppliers, manage the purchase of certificates and associated costs.
Importers without an approved Authorised CBAM Declarant application number may find their goods blocked at customs.
3. Annual CBAM Declarations Replace Quarterly Reports
Quarterly transitional reports have been replaced by an annual CBAM declaration. This declaration must be submitted by 31 May of the following year. For the 2026 reporting year, the declaration must be submitted before September 2027.
The annual declaration must include:
- Total quantities of imported CBAM goods (including net weight, HS-code and country of origin)
- Verified embedded emissions or, where applicable, default values
- The Number of CBAM certificates surrendered
Errors, missing data, or incorrectly customs-cleared entries may lead to penalites and corrective actions.
Which Goods Are Covered by CBAM?
CBAM applies at product level, not at company level. Even occasional imports of covered goods can trigger obligations once the 50-tonne threshold is exceeded.
CBAM currently applies to a defined list of carbon‑intensive products, including:
- Cement
- Iron and steel
- Aluminium
- Fertilisers
- Electricity
- Hydrogen
For many businesses, CBAM affects raw materials and semi‑finished goods that sit upstream in the supply chain, often outside traditional compliance focus areas.
The scope is expected to expand over time, making early compliance maturity a competitive advantage.
What Companies Must Do Now
With CBAM live, preparation is no longer enough. Importers must move to operational compliance.
Key actions include:
1. Secure CBAM Authorisation
If not already completed, importers must obtain CBAM declarant authorisation as a priority. Without it, imports of covered goods may be refused or blocked at customs.
2. Strengthen Supplier Data Collection
Accurate emissions data is the foundation of CBAM compliance. Importers must:
- Engage non‑EU suppliers to provide verified emissions data
- Understand calculation methodologies
- Establish contractual obligations where necessary
Where actual data is unavailable, default values are applicable. These typically result in higher CBAM costs.
3. Integrate CBAM into Customs Processes
CBAM data must align with customs declarations, product classifications, and origin data. Discrepancies increase the risk of audits, corrections and penalties related to underreported or missing emissions.
Integrating CBAM into customs workflows helps ensure:
- Consistent data submission
- Reduced manual errors
- Faster clearance processes
4. Plan for Financial Impact
CBAM introduces a variable cost linked to carbon pricing. Companies should:
- Model CBAM exposure across products and suppliers
- Factor CBAM costs into pricing and sourcing decisions
- Assess whether supplier changes or process improvements can reduce emissions intensity
Why CBAM Is Also a Strategic Issue
CBAM is designed to align trade with the EU’s climate objectives, but its impact goes far beyond environmental policy.
While CBAM is a regulatory requirement, it is also a strategic signal. The mechanism is designed to encourage cleaner production globally and prevent carbon leakage.
Businesses that proactively manage CBAM can:
- Improve supply chain transparency
- Reduce long‑term carbon costs
- Strengthen ESG reporting and sustainability credentials
Those that treat CBAM as a last‑minute compliance task may face higher costs and operational disruption.
How ALS Can Help
CBAM compliance sits at the intersection of customs, carbon data, and financial planning. Managing it in silos increases risk.
At ALS Customs Services, we support businesses through every stage of CBAM compliance.
Our experts help companies:
- Obtain CBAM declarant authorisation
- Collect supplier emissions data
- Align CBAM requirements with customs declarations
- Manage ongoing reporting and certificate obligations
With deep customs expertise and technology‑driven solutions, ALS helps businesses stay compliant while keeping supply chains moving.
With ALS, customs are simplified, and trade is amplified.
TL;DR
- CBAM is live from 1 January 2026: the mechanism has entered its definitive phase, shifting from transitional reporting to enforceable financial obligations.
- CBAM certificates are now required: EU importers must purchase in 2027 and surrender certificates based on the embedded emissions of CBAM-covered goods, priced in line with EU ETS allowances.
- Authorisation is mandatory: only authorised CBAM declarants are permitted to import more than 50 ton of CBAM goods into the EU.
- Annual declarations replace quarterly reports: importers must submit a verified annual CBAM declaration by 31 May each year.
- Supplier emissions data is critical: missing or inaccurate data can trigger default values and significantly higher CBAM costs.
- CBAM directly impacts landed cost and sourcing decisions, not just regulatory compliance.
- Early action reduces risk: companies that integrate CBAM into customs, procurement, and ESG processes gain cost control and supply chain resilience.