News · 2026-09-10

"CBAM enters the payment phase: the essentials in one read"

The EU Carbon Border Adjustment Mechanism enters full application on 1 January 2026. Importers no longer face a reporting exercise, but a full set of verified emissions data.

The transition period is over - the timetable now has to be met

From 1 January 2026 CBAM moves into full application: importers above the annual volume threshold must obtain authorisation, and by 30 September 2027 at the latest must submit the 2026 declaration, purchase and surrender CBAM certificates.

The biggest difference from the transition period is that "reporting" becomes "settling": declare, buy certificates, surrender them - none of the steps can be skipped. For an importer, there are really only two dates to watch: 2026 is the year to gather the data, and 30 September 2027 is the day the account is closed. Authorisation is a precondition for declaring, so the preparation in the first half of the year is essentially about authorisation and data.

The keyword in compliance has become "data"

The question used to be "do you have certificates"; now it is "do you have data" - suppliers must be able to produce verified actual emissions figures. Certificates can be found on the market; data can only grow out of the supply chain. Those are two very different levels of difficulty.

Usable emissions data sits on top of records of production lines, energy and metering conventions. If none of that is recorded day to day, it is very hard to reconstruct at year end, and numbers assembled at the last minute rarely survive verification. In other words, this is a long-term capability for a supplier, not a once-a-year task.

Which categories are covered, and how it expands

Coverage currently includes steel, aluminium, cement, fertiliser, hydrogen and electricity. The plan: the delegated act for steel is expected in the fourth quarter of 2026; textiles, aluminium and tyres follow in 2027, becoming mandatory in 2028-2029.

That means a category outside the list today is not necessarily immune forever - the direction of expansion is already on the timetable.

What buyers should prepare in advance

First, list the suppliers involved in those categories and confirm one by one whether they can provide emissions data. Second, write "provide verified data" into the contract as a condition of continued supply. Third, build a process for retaining the data rather than hunting for it during declaration season. If a supplier cannot provide the data, work out the alternative early instead of waiting until the deadline is close. Putting these three on a timetable is far more comfortable than handling them all at once in 2027.

To work through categories and suppliers one by one, start with the free verification checklist, or check the wording in the glossary.