Six months into the definitive regime: what importers have learned
The EU CBAM's definitive regime is six months old. Since 1 January 2026, importers of covered goods above the 50-tonne threshold have needed authorised declarant status, and every consignment has added to a liability that falls due when certificate surrender begins in 2027. Enough time has passed to see where the real difficulties lie.
Supplier data is the bottleneck
The single most common problem is upstream. Importers can only report actual embedded emissions if their suppliers measure and share them, and many suppliers outside the EU are not yet equipped to do so. The fallback is default values, and the fallback gets more expensive: mark-ups on defaults are set to reach around 30 per cent for most products from 2028. Importers who invested in supplier engagement during the transitional phase are now reaping the benefit. Those who did not are paying for it, either in defaults or in a scramble for data.
Boundaries and definitions still confuse
The Commission's webinar programme has drawn thousands of attendees, and the questions asked tell their own story. System boundaries, which processes count towards embedded emissions, and how to treat precursor materials remain the areas where honest businesses most often get it wrong. The guidance is improving, but this is technical territory, and small definitional mistakes feed straight into the liability.
Liabilities are larger than expected
A recurring surprise is scale. Businesses that treated transitional reporting as a paperwork exercise are now applying quarterly certificate prices of around €75 per tonne of CO2e to their import volumes and finding the numbers material. The free allocation adjustment softens 2026 considerably, but it declines every year, so today's manageable figure is a floor rather than a ceiling.
The lesson
None of the businesses coping well with CBAM did anything clever. They started early, asked their suppliers for data before they needed it, and treated the numbers as a finance matter rather than a compliance chore. With the downstream extension on its way in 2028, several thousand more businesses are about to face the same learning curve. The head start is still available.
CBAM-Assured trains importers and suppliers in exactly this groundwork. Contact us to talk about where you stand.