CBAM’s definitive phase starts in January. A checklist for exporters to Europe
From 1 January 2026, the EU Carbon Border Adjustment Mechanism moves from reporting to paying. The October 2025 simplification exempts small importers — but cement, steel, aluminium and fertiliser exporters still need verified emissions data.
OCCASIO® Team
The EU’s Carbon Border Adjustment Mechanism (CBAM) puts a carbon price on certain imports — iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. After a transitional reporting phase that began in October 2023, the definitive regime starts on 1 January 2026.
What the October 2025 simplification changed
The CBAM “omnibus” (Regulation (EU) 2025/2083) made the system lighter for small players:
- A new 50-tonne annual threshold per importer replaces the old €150-per-consignment exemption. Below it, importers are exempt; above it, all their covered imports are in scope.
- The threshold is designed to exempt around 90% of operators while still covering over 99% of embedded emissions.
- Importers above the threshold should apply for authorised CBAM declarant status — by 31 March 2026 to keep importing while the application is processed.
- CBAM certificates for 2026 imports are bought and surrendered from February 2027; the first annual declaration is due by 30 September 2027.
Why exporters should care now
The legal obligation sits with the EU importer, but the cost depends on the exporter’s data. Without verified, installation-specific emissions, importers may fall back on default values — which are usually less favourable. European buyers will increasingly prefer suppliers who can document lower embedded emissions.
A five-point checklist
- Identify which of your products fall under CBAM codes, and which EU customers import above 50 tonnes a year.
- Set up installation-level monitoring of direct emissions and electricity use.
- Prepare for third-party verification of your emissions data.
- Cut embedded emissions where it is cheapest — electricity efficiency is often the fastest win. See our verified cement results at Cleopatra and Ciments d’Enfidha.
- Agree with customers how data and costs will be shared in contracts.
OCCASIO® helps exporters build the data, the reduction plan and the commercial story. Talk to OCCASIO®.
Sources
Written by
OCCASIO® Team
