CBAM: The 2026 Changes Businesses Can’t Afford to Ignore

The Carbon Border Adjustment Mechanism (CBAM) is no longer a topic solely relevant to environmental experts or large industrial players. It is a reality that is fundamentally reshaping international trade and which, starting in 2026, will impose stricter requirements and specific obligations on a growing number of companies.

If your business handles imports of CBAM goods (fertilizers, cement, and especially iron, steel, and aluminium products) into the European Union, it is essential to transition from the “transitional phase” to final implementation.

The CBAM Revolution: Preventing Carbon Leakage

CBAM came into force in 2023 with a clear objective: to prevent carbon leakage. This mechanism was introduced to ensure that the carbon price paid on goods produced in the EU (which are subject to the EU Emissions Trading System, or ETS) matches that paid on imported goods. The intention is to prevent companies from relocating production to countries with less rigorous climate policies, thereby merely shifting emissions elsewhere.

CBAM implementation is gradual and runs parallel with the phasing out of free ETS allowances.

Towards the Definitive Period: The Urgency of 2026

 As we begin the definitive period, 2026 represents a major turning point. Why must your company act now? The primary and most significant change is the requirement to become an Authorised CBAM Declarant. Starting in 2026, importers who anticipate exceeding the new single threshold for CBAM goods imports, based on annual mass, must apply for authorisation.

The New Threshold and the Risk of Penalties

 Regulation (EU) 2025/2083 introduced key simplifications, but also binding obligations:

• New Single Threshold: The single threshold, based on the cumulative net mass across all CBAM goods, is set at 50 tonnes starting in 2026.
• Mandatory Authorization: If you anticipate exceeding this threshold, you must obtain the status of Authorised CBAM Declarant before crossing it.
• The Major Risk: Importing CBAM goods from January 1, 2026, without the necessary authorization, if the threshold is exceeded, can result in penalties.

It is crucial to remember that the application for authorization must be submitted by 31/12/2025. There is, however, a derogation that allows importers who have submitted the application by March 31, 2026, to temporarily continue importing goods until the competent authority reaches a decision.

Not Just Imports: Also Focusing on Exports

While CBAM aims to protect European goods, the European Commission is also evaluating the risks for exporters.

With the gradual phasing out of free ETS allowances, the risk of carbon leakage increases for CBAM goods destined for export markets, especially if third countries do not introduce an equivalent carbon price. For this reason, the Commission has announced its intention to introduce a new measure to mitigate the risk of carbon leakage for exporters of CBAM goods.

This proposal, introduced at the end of 2025, aims to support at-risk goods producers and ensure fair treatment for all commodities, whether produced and sold within the EU, or imported or exported.

Crucial Topics and Choosing the Right Partner

Successful preparation for current CBAM requires considering several crucial factors. These range from accurate commodity classification – a necessity given the new 50-tonne threshold – to the mandatory external verification of actual emissions data. It also includes the effective management of special customs procedures, such as Inward Processing and re-importations. CBAM is not simply a tax; it is a complex regulatory system demanding meticulous planning and precision.

 Approaching these changes prepared is the only way to turn a regulatory requirement into a competitive advantage. Customs Support Group is the ideal partner to guide your company through this transition. Our comprehensive support includes general regulatory consulting, direct assistance with CBAM reporting, and timely updates on new developments, as well as dedicated support for submitting your Authorized CBAM Declarant application. By leveraging our deep customs expertise and focus on digital innovation, we can help you achieve the necessary status while simultaneously simplifying your processes, minimizing compliance risks, and preventing penalties.

Don’t navigate these challenges alone. Contact our experts today for dedicated support on CBAM and all your wider customs and trade requirements.