by Jenny Mae Vansteenlandt
What is CBAM? And what is the impact on your business?
Since Jan. 1, 2026, the Carbon Border Adjustment Mechanism (CBAM) is finally in force. Do you import (carbon-intensive) goods from outside the EU? Then you may face new obligations as well as additional costs. CBAM is thus more than an administrative formality. It has a direct financial and operational impact, especially for manufacturing companies, construction companies and internationally active SMEs.
What is CBAM?
CBAM is a European mechanism that ensures that imported goods bear a similarCO2 cost as goods produced within the EU.
The system ties in with the existing EU Emissions Trading System (EU ETS). Within the EU, large industrial players must purchase allowances for their carbon emissions. As the number of available allowances decreases annually, their price increases. To avoid shifting production to countries with less strict climate rules (so-called carbon leakage), until now certain sectors received free allowances.
With the introduction of CBAM, that system is gradually changing. The free allowances will be phased out. At the same time, a comparable carbon price will be applied to imported carbon-intensive goods.
Importers must henceforth:
report emissions from imported CBAM goods,
and from 2027, purchase and surrender CBAM certificates to hedge emissions.
In this way, the EU wants to create a level playing field and accelerate the transition to a cleaner industry.
Are you subject to CBAM? Do the check in 4 steps
| Check | Examples | Note |
|---|---|---|
Do you import goods from outside the EU customs territory? | Turkey, China, India, ... | |
Do your goods fall under CBAM? | Cement, iron & steel, aluminum, fertilizers, hydrogen, electricity | Assess this based on the CN codes - see Annex I of Regulation (EU) 2023/956. |
Are you releasing these goods into free circulation in the EU? (i.e. are you the official importer making the customs declaration?) | Do you purchase CBAM goods but are not the official importer yourself? Then the obligation lies with your supplier or distributor. | |
Do you import more than 50 tons of these goods per calendar year (cumulative for all goods combined)? | For hydrogen and electricity there is no threshold, these are always covered by CBAM. |
Important:
Up to and including 2025, a threshold of €150 per shipment still applied - this will expire.
From when does CBAM apply?
2023 - 2025: Transition period
You had to report volume and emissions quarterly, but with no financial obligation or certificates.
2026: Final start
You need CBAM authorization to import.
2027: First annual declaration.
You submit certificates for 2026 imports.
Main obligations
Authorization and license
You must apply for the status of 'Authorized CBAM Declarant' (at EORI level). This is best done through the customs authorities. Without (current) authorization you are no longer allowed to import CBAM goods.
Data collection and reporting
You must report per commodity and per production facility on:
Volume (tons)
Country and production facility of origin
Direct emissions - related to the production process (e.g. gas combustion)*
Indirect emissions (electricity consumption)*
Any carbon price already paid in country of origin (deductible subject to proof)
*Emission data are ideally provided by suppliers. Where these are not available, default values may be used. Note that default values are deliberately high and often lead to higher costs. Timely agreements with suppliers are therefore strongly recommended.
Purchasing and submitting CBAM certificates (from 2027)
From 2027, importers must effectively purchase and turn in CBAM certificates.
One certificate is equivalent to 1 ton ofCO2.
The price follows the EU ETS auction price.
Common pitfalls (and how to avoid them)
Requesting emission data from suppliers too late => Establish contractually now who is responsible for correct CO₂ data.
Working with default values due to faulty data flows => This leads to structurally higher certificate costs.
No timely authorization requests => Your input can stall at the border, resulting in operational damage. So plan your CBAM application on time.
How Vandelanotte can support you
CBAM has an impact on different branches of your company: purchasing, logistics, finance, ... By making carbon emissions and costs explicit, CBAM influences supplier choice (lower emissions have financial advantages), contract conditions, data sharing and budgeting, among other things.
We help you address CBAM not only compliantly, but also strategically smartly using:
a CBAM impact analysis (does CBAM apply and to what extent?);
support in registration and authorization;
design and improvement of processes to correctly collect, verify and report data;
guidance in reporting emissions and use of default versus actual values;
budgeting of CBAM certificates;
strategic advice around suppliers, contracts and sourcing.
Don't wait until you need to purchase your first certificates; prepare now. Contact our experts for an exploratory discussion. That way you will avoid surprises and be ready for the next phase of European climate regulation.
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Jenny Mae Vansteenlandt
Senior Advisor Sustainability jennymae.vansteenlandt@vdl.be
Disclaimer
In our opinions, we rely on current legislation, interpretations and legal doctrine. This does not prevent the administration from disputing them or from changing existing interpretations.
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