The EU Carbon Border Adjustment Mechanism entered its definitive phase on 1 January 2026. Every tonne of steel, aluminium, cement, fertiliser or hydrogen imported into the EU now carries a carbon price.
Importers using default emission values pay 10–30% more than those with verified actual data. The first CBAM certificates must be purchased and surrendered by 30 September 2027.
| Date | Milestone |
|---|---|
| 1 Jan 2026 | Definitive phase started – financial obligations apply to all imports |
| 31 Mar 2026 | Deadline to apply for Authorised CBAM Declarant status |
| Throughout 2026 | Collect and monitor emissions data from your supply chain |
| 1 Feb 2027 | CBAM certificates go on sale via the EU central platform |
| 30 Sep 2027 | First annual declaration + certificate surrender for 2026 imports |
| 2028 | Proposed scope expansion to 180+ downstream products |
| 2035 | CBAM fully phased in – EU ETS free allocation fully phased out |
We have spent over 15 years building a global emissions verification practice. We understand both sides of the CBAM equation – the EU regulatory framework and the operational reality of producers worldwide.
Since 1 January 2026, every CBAM import generates a carbon cost. You will purchase certificates in 2027 to cover your 2026 imports. The cost depends on one critical factor: the embedded emissions value you declare.
You have two options:
Option 1: Actual verified emissions
Based on real monitoring data from your supplier’s installation, independently verified by an accredited verifier.
Reflects the true carbon footprint of the goods you import.
Requires monitoring systems, data collection, and on-site verification – but results in lower, accurate CBAM costs.
Option 2: Default values
Country-specific averages set by the EU Commission (published 31 December 2025), with a punitive markup on top.
The markup is 10% in 2026, 20% in 2027, and 30% from 2028 onwards.
No verification needed – but you pay significantly more.
The incentive structure is deliberate. The EU wants you to collect real data. If you do not, you pay a premium.
Cost impact example: Steel imports under CBAM
For a steel importer bringing in 10,000 tonnes of hot rolled coil from India, the difference between default values and verified actual emissions can exceed €200 per tonne in CBAM costs. At current EU ETS carbon prices, that represents over €2 million in unnecessary costs per year. For Chinese steel, verified data can reduce CBAM costs by up to 62% compared to defaults. The math is simple: verified data saves money.
On 17 December 2025, the European Commission published a comprehensive package of implementing acts – just two weeks before the definitive phase began. Here is what matters:
| Topic | What it means for you |
|---|---|
| Omnibus simplification | 50-tonne de minimis threshold exempts small importers. Simplified authorization. Declaration deadline moved to 30 September. |
| Default values + markup | Country-specific default values published 31 December 2025. Punitive markup: +10% (2026), +20% (2027), +30% (2028+). Using actual data avoids the markup entirely. |
| Calculation methodology | Detailed rules for embedded emissions calculation per CN code. Product-based functional units. Weighted averages for multi-route installations. |
| Verification & accreditation | Accredited verifiers must conduct on-site inspections at producing installations in the first reporting year (2026). Rules for verifier accreditation and mutual recognition published. |
| Precursor cascade | Complex goods require reporting of embedded emissions from all precursors. If any link in the supply chain cannot provide data, default values apply for that precursor. |
| Scope expansion (proposed) | 180+ downstream products (car parts, appliances, construction materials, transformers) proposed for inclusion from 2028. Subject to legislative process. |
| Anti-circumvention | New measures to prevent emissions misdeclaration and evasion, including pre-aluminium and steel scrap as CBAM precursors. |
| Certificate pricing | Quarterly average EU ETS price in 2026. Weekly average from 2027. Quarterly holding requirement reduced to 50% of cumulative liability. |
CBAM does not just measure emissions at the final production step. For complex goods, it requires cascade reporting: the embedded emissions of every precursor must be tracked and aggregated through the supply chain.
Take steel as an example. A single steel product may involve iron ore, coke, pig iron, slab, and hot-rolled coil – each produced at different installations, potentially in different countries. Each step has its own emissions profile. CBAM requires all of them to be captured, documented, and ultimately verified.
This is where most companies get stuck:
This is not a problem you can solve in the last month before your declaration is due. It requires engagement with your suppliers now, clear data requirements, and a structured path to verification readiness.
We are currently in the process of obtaining CBAM verifier accreditation. While that is underway, our team is fully operational to help you prepare. When accreditation is granted, we will transition seamlessly from preparation to formal verification.
Here is what we do today:
All of this is done within the strict boundaries of auditor impartiality. We prepare you for verification – we do not tell you what your numbers should be.
Act now. The 2026 clock is running.
Every tonne imported in 2026 will need to be declared and paid for by September 2027. The sooner your supply chain data is verification-ready, the less you pay. Start with a free CBAM compliance gap analysis.
Gain exclusive access to our recorded CBAM webinar session held on 21st April 2026, where Normec Verifavia experts discuss the impact of actual vs default emissions on CBAM costs and what it takes to be verification-ready.
Complete the form below to receive temporary access to the webinar recording for a period of one week.
You request a quote or gap analysis through this page. We respond within 48 hours.
We collect information on your CBAM-relevant imports, CN codes, supplier locations, and current data practices.
We define scope, timeline, and deliverables in a clear contract.
Our team reviews your data, methodology, and supply chain readiness against CBAM requirements.
Where needed, we work directly with your third-country producers to evaluate their monitoring and documentation.
You receive a prioritised action plan with clear recommendations, timelines, and cost implications.
As we obtain accreditation, we transition to formal verification of your CBAM data.
The Carbon Border Adjustment Mechanism (CBAM) is an EU regulation that puts a carbon price on imports of carbon-intensive goods (cement, iron & steel, aluminium, fertilisers, hydrogen, and electricity). It mirrors the EU Emissions Trading System (ETS) to prevent carbon leakage – the risk that EU production moves to countries with weaker climate policies. The definitive phase started on 1 January 2026.
CBAM applies if you import more than 50 tonnes per year of covered goods into the EU. Check whether your products fall under the CN codes listed in Annex I of Regulation (EU) 2023/956. The EU Commission provides a self-assessment tool on its CBAM page. Imports below the 50-tonne threshold are exempt (except for hydrogen and electricity).
Default values are country-specific emission intensity averages set by the EU Commission. They include a punitive markup: +10% in 2026, +20% in 2027, and +30% from 2028 onwards. This markup is designed to incentivise importers to obtain verified actual emissions data from their suppliers. If you rely on default values, you pay more for CBAM certificates than if you use real, verified data.
CBAM certificates will be available for purchase from 1 February 2027 via the EU central platform. The first annual CBAM declaration and certificate surrender deadline is 30 September 2027, covering all imports made during calendar year 2026. In 2026, certificates are priced at the quarterly average EU ETS allowance price; from 2027, at the weekly average.
For complex goods (goods made from other CBAM goods), the embedded emissions of all precursors must be reported. For example, if you import steel coils made from pig iron, you need the emissions data from both the pig iron and the steel production. If any precursor in the chain lacks verified data, default values with markups apply for that precursor.
Non-EU producers of CBAM goods need to monitor their emissions at installation level, following the CBAM calculation methodology published in December 2025. This data must be independently verified by an accredited verifier, who must conduct an on-site inspection in the first reporting year. Producers who provide verified data help their EU customers reduce CBAM costs – making them more competitive.
Non-compliance penalties include €100 per tonne of CO₂ for undeclared or under-declared emissions, with no cap. Additionally, from 1 January 2026, imports of CBAM goods above 50 tonnes require Authorised CBAM Declarant status – without it, goods cannot be released for free circulation.
We are currently in the process of obtaining CBAM verifier accreditation. In the meantime, we offer pre-verification services: compliance gap analysis, data review, supplier readiness assessment, and precursor cascade mapping. These services prepare you for formal verification as soon as our accreditation is confirmed.
