CBAM 2026: New EU Rules, Deadlines and What Exporters Must Do Now
CBAM is no longer a future rule to watch. It is live.
The EU Carbon Border Adjustment Mechanism moved into its definitive period on 1 January 2026. For importers into the EU, this means authorisation checks at customs, emissions data collection and certificate planning. For non-EU exporters, it means EU customers will expect cleaner data, better documentation and support with verified emissions.
Here is what has changed, what matters now, and how businesses can prepare.
What changed from 1 January 2026?
The transitional phase ended on 31 December 2025. From 1 January 2026, CBAM applies under its definitive regime.
EU customs systems now validate CBAM authorisations before covered goods are released for free circulation. In the first week of operation, the European Commission reported more than 12,000 authorisation applications and over 10,000 import customs declarations validated automatically in real time.
This is important for exporters outside the EU. Even though the legal declarant is usually the EU importer, the importer depends on supplier data. If emissions data is missing, unclear or unverified, the exporter can become the bottleneck.
The 50-tonne simplification
The EU's CBAM simplification package introduced a single annual mass-based threshold of 50 tonnes.
Companies importing less than 50 tonnes of CBAM goods each year are generally exempt from CBAM obligations. The European Commission expects this to exempt around 182,000 importers, mostly SMEs and individuals, while still covering over 99% of emissions in scope.
For importers above the threshold, the package simplifies authorisation, emissions calculation, reporting and financial compliance. Electricity and hydrogen have sector-specific treatment, so businesses in those sectors should check the official guidance rather than rely on the general threshold alone.
CBAM certificate prices in 2026
CBAM certificate prices are linked to EU ETS allowance auction prices.
In 2026, the Commission is publishing four quarterly prices. The Q1 2026 price was €75.36 per certificate and the Q2 2026 price was €75.28 per certificate. From 2027, prices will be published weekly.
All CBAM certificates will be purchased on the common central platform from February 2027. The first annual CBAM declaration for 2026 imports, along with the corresponding certificate surrender, is due by 30 September 2027.
This gives businesses time to prepare, but not time to ignore the data work. Emissions monitoring for 2026 imports is already part of the compliance trail.
Verification and actual emissions data
Importers can use default values or actual verified emissions data. Where actual emissions are used, the data must be verified by an independent verifier accredited by an EU national accreditation body.
The first CBAM verifier accreditations are expected around September 2026. Accredited verifiers can register in the CBAM Registry, review monitoring approaches, assess emissions calculations and issue verification reports.
For non-EU suppliers, this makes installation-level data quality critical. Activity data, emission factors, electricity use, production volumes and allocation methods need to be documented in a way that can survive verification.
What may change next?
In June 2026, the Council agreed to extend CBAM to specific downstream goods and strengthen anti-circumvention safeguards. This follows the Commission's December 2025 proposal.
This is not yet a finished extension of scope. The next steps depend on the European Parliament and trilogue discussions. Businesses in steel, aluminium and downstream value chains should track this closely because products outside today's Annex I list may come into scope later.
What exporters should do now
Map your products. Check which products fall under CBAM-covered sectors and confirm the correct CN codes. Do not assume the product name alone settles the question.
Set up installation-level monitoring. Track activity data, direct emissions, relevant indirect emissions and production volumes at the installation level. Keep the evidence organised from the start.
Decide between default and actual values. Default values may be simpler, but actual verified emissions can better reflect your real footprint. The right choice depends on data quality, customer expectations and verification readiness.
Share data with EU customers early. EU declarants can retrieve emissions data from registered non-EU installation operators through the CBAM Registry. Suppliers should align with customers on data format, confidentiality and timing.
Prepare for verification. A verification-ready file should include the monitoring plan, source data, calculations, assumptions, allocation method and supporting evidence. Do not wait until 2027 to rebuild 2026 data.
How Sustainability 101 can help
Learn CBAM calculation
Sustainability 101's Masterclass on CBAM Calculation covers CBAM fundamentals, EU ETS basics, registration and reporting, calculations, sector deep dives, case studies and practical compliance steps.
The live course page currently lists the CBAM module at ₹5,999, inclusive of 18% GST. It includes 6+ hours of content, a 50-mark assessment, 60+ quizzes and 10+ case studies.
Use free resources
Start with our existing explainers:
For official material, use the European Commission's CBAM definitive regime page, certificate price page, verification page and August 2026 guidance series.
Get CBAM calculation consultancy support
If your team needs help with product mapping, emissions calculations, supplier data templates, default-vs-actual value decisions or verification readiness, Sustainability 101 can support you through CBAM calculation consultancy.
The bottom line
CBAM's definitive period has started. The first declaration deadline is in 2027, but the data being created in 2026 will decide how painful that deadline becomes.
For exporters, the safest approach is simple: map products early, build installation-level data, align with EU customers and prepare verification files before they are requested.
Comments