CBAM – Final Phase 2026
CBAM – Final Phase: Sustainability as Market-Access Requirement
Starting January 1st, 2026, the Carbon Border Adjustment Mechanism (CBAM) will enter into full force, introducing a carbon cost on imports with high embedded emissions – including aluminum, cement, electricity, fertilizers, iron and steel – to support more sustainable global trade.
The New Regulation (EU) 2025/2083 launches the definitive phase of CBAM, fully integrating climate policy into international trade.
Importers and their indirect customs representatives will be required to obtain the status of authorized CBAM declarant and operate through the EU’s digital CBAM Registry.
The annual CBAM declaration must be submitted by September 30th of the year following the imports (first deadline: 2027), while the purchase of CBAM certificates to offset emissions will begin in 2027 for emissions related to 2026.
Updates:
- A de minimis threshold – 50 tons per year for CBAM goods, easing the burden on smaller firms.
- Reduction of the mandatory certificate holding requirement from 80% to 50% of quarterly emissions.
- Possibility for authorized declarants to delegate the CBAM declaration to a third party.
What to do?
- Check whether exempt due to the de minimis
- Apply for CBAM authorization before the end of 2025 (temporary waiver until March 31st, 2026).
- Set up robust systems for collecting data on embedded emissions in imported goods.
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