Six months into the definitive regime: what importers have learned

The EU CBAM's definitive regimeis six months old. Since 1 January 2026, importers of covered goods above the50-tonne threshold have needed authorised declarant status, and everyconsignment has added to a liability that falls due when certificate surrenderbegins in 2027. Enough time has passed to see where the real difficulties lie.

Supplier data is the bottleneck

The single most common problemis upstream. Importers can only report actual embedded emissions if theirsuppliers measure and share them, and many suppliers outside the EU are not yetequipped to do so. The fallback is default values, and the fallback gets moreexpensive: mark-ups on defaults are set to reach around 30 per cent for mostproducts from 2028. Importers who invested in supplier engagement during thetransitional phase are now reaping the benefit. Those who did not are payingfor it, either in defaults or in a scramble for data.

Boundaries and definitions still confuse

The Commission's webinarprogramme has drawn thousands of attendees, and the questions asked tell theirown story. System boundaries, which processes count towards embedded emissions,and how to treat precursor materials remain the areas where honest businessesmost often get it wrong. The guidance is improving, but this is technicalterritory, and small definitional mistakes feed straight into the liability.

Liabilities are larger than expected

A recurring surprise is scale.Businesses that treated transitional reporting as a paperwork exercise are nowapplying quarterly certificate prices of around €75 per tonne of CO2e to theirimport volumes and finding the numbers material. The free allocation adjustmentsoftens 2026 considerably, but it declines every year, so today's manageablefigure is a floor rather than a ceiling.

The lesson

None of the businesses copingwell with CBAM did anything clever. They started early, asked their suppliersfor data before they needed it, and treated the numbers as a finance matterrather than a compliance chore. With the downstream extension on its way in2028, several thousand more businesses are about to face the same learningcurve. The head start is still available.

CBAM-Assured trains importersand suppliers in exactly this groundwork. Contact us to talk about where youstand.

‍