As of January 1, 2026, EU importers of certain goods will bear the financial costs of CO2 emissions – which means that if your company exports those goods to the EU, you are impacted!
The EU’s Carbon Border Adjustment Mechanism (CBAM) has officially moved from the “transition phase” to the ➡️ “definitive regime”, meaning that importers have to purchase certificates for the embedded carbon emissions of their goods. In short, there is a cost to the carbon emissions associated with your products that end up in the EU.
This is meant to put a fair and international price on carbon: non-EU exports are “priced” similar to the carbon costs incurred by European producers, levelling the playing field.
How do I know if I am impacted as an exporter?
If your company is outside of the EU but produces products in the following sectors that are eventually imported into the EU, your goods will have a carbon certificate attached to it (i.e. you are impacted by CBAM):
cement
aluminum
fertilizers
ferrous materials
hydrogen
electricity
This covers industries like pipes, structural steel, railway materials, screws, industrial goods and household appliances, automotive parts, and more 🚗.
The minimum weight threshold to be impacted is 50 tonnes of CBAM goods into the EU. If you’re not sure if you meet that or not – your importers will know. So, get in touch with your customers to make sure you are meeting their needs.
What is my responsibility as a non-EU supplier that is impacted?
Up until January 1, 2026, your EU importers were allowed to use estimated carbon emissions data for the impacted goods. Now, they will require actual emissions data from their non-EU suppliers to apply the appropriate certificate to.
So, companies like you who make products in the impacted categories (especially those with steel, aluminium and iron) should be on alert – you are now responsible for supplying actual carbon emissions data to your importers.
TLDR 
if your goods end up in the EU, you need to measure your carbon emissions for your customers/importers – and it’s no longer optional.
Whose responsibility is it to report on the carbon emissions of my products? What is the cost to my customers?
Ultimately, the importer (your customers) are the ones who bear the burden of the CBAM when it comes to paying for certificates. Importers will buy CBAM certificates from the national authorities in their country, and the price of the certificates will be based on the auction price of EU ETS allowances expressed in €/tonne of CO2 emitted, as a quarterly average in 2026 and as a weekly average from 2027 onwards.
These certificates will be purchased annually by the EU importers, as they have to declare the emissions associated with their imports each year.
However, the data the importers need to purchase those certificates comes from you – their suppliers/exporters. So, if you want to keep your EU business, measuring and reporting on your emissions is a requirement for those customers to purchase from you.
Does reducing my carbon emissions have any benefits now that CBAM is in effect?
Since the cost of certificates is directly linked to the amount of emissions produced by your goods, the less carbon-intensive you are, the more attractive you are as a supplier to EU importers. 📣 Reducing your carbon emissions has officially created a competitive advantage when it comes to EU buyers.
📆 What are the deadlines for compliance as an exporter?
The deadline for importers to apply for 2026 certificates (based on 2025 data) is March 31, 2026. That means that your customers will need your CBAM emissions data ASAP.
Looking ahead, from May 31, 2027 onwards, importers will have to submit a CBAM declaration for the previous calendar year to their national authority by May 31 of each year. This means that as an exporter, you will likely need to prepare and submit your CBAM emissions data months prior to that annual May 31 deadline.
Importers will submit CBAM certificates (pay for the carbon price of their imported goods) to their authority by July 1 of each year, which again will depend on the embedded emissions of your goods.
What should I do if I am impacted as an exporter/supplier?
- Find out if you currently measure your carbon emissions as a company, specifically looking at your Scope 1 and 2 emissions.
If you’re already measuring, you’re off to a great start – this is the basis of CBAM reporting and compliance. If not, you’ll need to assign someone 🧑 to lead this initiative.If there is no one with internal expertise on the GHG Protocol, carbon emissions, and CBAM, it is likely that you will need external support to accurately and confidently measure your carbon emissions for CBAM.
- Get in touch with your customer (the impacted EU importer) to understand what they need, and in what format.
Some importers are managing the CBAM data collection themselves, some are using third-party consultants and/or software, and some may be underwater themselves trying to keep up with the regulation!Depending on your customer’s chosen path and understanding of what is required, you may be asked to complete the CBAM Communication Template for Installations. This is the standard form required of exporters that describes the emissions associated with their impacted goods.
If your customer is working with a third-party or software to collect the data, they may ask you to complete a custom form that allows them to complete the template on your behalf (or allows them to complete their own required forms). Data you might be asked to provide includes your Scope 1 and 2 emissions, product-specific information, and details about your raw materials or suppliers as well.
- Measure your carbon emissions and set up a system to ensure that data is updated at least annually.
There are many paths you can take to measure your company’s carbon emissions. If you have in-house capability, expertise, and resources, you might decide to track and report emissions without external support.
Some companies choose to hire one-time consultants to prepare an inventory, although increasingly many companies are choosing to use purpose-built software to both empower their own teams, save money, and ensure ongoing annual compliance.
If you have never measured your emissions before, know that it is not an easy task! Even using automated software like Carbohound, measuring annual emissions takes at least 4-6 weeks to complete on average.
This is because to calculate your emissions, you need to pull data from across your business operations including your ⚡️ electricity and utility usage, ⛽️ fuel consumption from your fleet, 🛒 information from your supply chain, and more.
Fill out the form to download a pdf guide →
What are the consequences of not measuring my emissions for CBAM and not disclosing to my EU customers?
For your customers, there are penalties for non-compliance. So if they keep buying from you but simply don’t report on the emissions associated with your goods (or the data is inconsistent/insufficient/incorrect), a fee of €100 per undeclared ton of CO2 will be charged.
Each national authority also has the ability to impose their own administrative fines, and may also require a third-party audit at the importer’s expense. These are a lot of costs and risks to your customer, and it’s possible that they could even lose their status as a CBAM declarant (importer) if they continue to violate the regulations.
For you, the producer of these goods, the consequences are simple: your risk of losing your EU customers is already way up if you don’t comply, and this keeps rising over time.
Not only is it more expensive for your customers to import carbon-intensive products, your customers run the risk of losing their own business operations by working with non-compliant suppliers.
After your initial emissions reporting, leverage this data to benefit your business beyond compliance. Look for usage reduction opportunities and anomalies.
Engaging with your supply chain can also help you reduce your footprint, build a relationship with your vendors, and be part of a long-term sustainability strategy.
If you do have to complete the full CBAM Communication Template for Installations, you can follow our how-to video below!