CBAM: Five Operational Mistakes That Can Cost Companies Dearly
Rotterdam, 30 March 2026 – Since the Carbon Border Adjustment Mechanism (CBAM) entered full operation on 1 January this year, importing companies of certain goods have been facing tangible implementation challenges. In its day-to-day advisory work, the Customs Support Group (CSG), Europe’s leading independent provider of customs clearance and trade solutions, has identified five typical mistakes that can result in significant additional costs, compliance risks, and extra administrative effort.
Companies importing CBAM goods must have applied for authorised CBAM declarant status by 31 March 2026. Without authorisation, continued imports into the EU are at risk.
CBAM is a key instrument of the EU Green Deal and is intended to ensure that certain imported products, such as iron, steel, aluminium, cement and fertilisers, bear the same CO₂ costs as goods manufactured in the EU. Following a three-year transition period, during which companies were primarily able to set up reporting structures and test notification processes, the reported emissions will be mandatorily allocated to the imported goods from 1 January 2026.
On this basis, companies that import more than 50 tonnes of CBAM goods annually had to submit their application for the status of authorised CBAM declarants by 31st of March 2026. The authorisation ensures companies can continue importing CBAM goods into the EU without disruption. As authorised CBAM declarants companies need to purchase and surrender CBAM certificates for the goods imported in the previous year from 2027 onwards. This has immediate financial implications. Errors in data collection, classification or process integration can thus directly lead to additional burdens.
For many companies, CBAM is no longer a reporting exercise, but a new cost component affecting margins and sourcing decisions.
CBAM puts customs and financial processes in the spotlight
“CBAM is evolving from a pure reporting obligation to an operational control instrument that deeply affects customs, supply chain and financial processes,” says John Wegman, CEO of the Customs Support Group. “In our daily work, we see five typical operational errors that can directly lead to additional costs as well as compliance risks – and clear starting points for how to avoid them.”
- Lack of CBAM governance and integrated data management
Many companies treat CBAM as a purely technical reporting task, while in reality it requires coordinated ownership across customs, procurement, sustainability and finance. Without clear responsibilities and integrated data flows, companies face inconsistent reporting, delays, and increased risk of errors.
- Inadequate or incorrect classification of goods
Correctly assigning customs tariff codes is crucial to determining whether and how CBAM obligations apply. Errors in classification lead to incorrect reporting, delays and additional effort. Companies should regularly check and coordinate origin, classification and CBAM relevance.
- Failure to obtain authorised CBAM declarant status in time
Importers of CBAM goods exceeding the 50-tonnes threshold must now urgently apply for the status of authorised CBAM declarants. With 31 March 2026 widely considered a critical operational deadline, companies that have not yet submitted their application are exposed to significant risks. In practice, failure to apply in time may lead to delays, penalties, or even temporary inability to import CBAM goods, depending on how national authorities manage pending or late applications.
- Failure to assess the financial impact of CBAM
Many companies still approach CBAM as a reporting exercise, without quantifying its financial implications. However, from 2026 onwards, CBAM will directly affect import costs through the purchase of certificates. With the publication of default values and CBAM benchmarks, companies already have sufficient information to estimate their exposure. Failing to do so can lead to significant unexpected costs, margin erosion, and pricing issues.
- Underestimation of operational consequences and sanctions
Incorrect or incomplete reports can result not only in rework and manual corrections, but also – in the worst case – in financial penalties aligned with EU ETS levels. Beyond fines, companies may face increased scrutiny, delays, and ongoing administrative burden. CBAM should therefore be treated as a continuous operational process with regular controls – not as a one-off reporting exercise.
Practical example: When CBAM only becomes apparent during reporting
A typical case from industry shows how quickly CBAM risks can materialise in 2026: An EU importer of steel components from a third country enters the definitive phase without having assessed the financial implications of CBAM and without early engagement with its suppliers.
When preparing its first CBAM declaration, the importer requests emissions data from its supplier. However, the supplier considers the products to fall outside CBAM scope, as they are internally classified as “parts” rather than CBAM-relevant goods. As a result, no preparation work has been carried out and no emissions data is available.
It is only at this stage that it becomes apparent that the goods are in fact covered by CBAM based on their correct customs classification. Due to the lack of prior alignment and missing data, the importer is forced to rely on default values.
This results in significantly higher-than-expected CBAM costs, urgent coordination efforts, and pressure to renegotiate supplier terms and adjust pricing.
“CBAM is not a theoretical reporting project, but an operational stress test for customs, supply chain and data processes,” says Wegman. “It is not the rules themselves, but their implementation that determines whether companies manage risks or incur unnecessary costs.”
Free webinars on CBAM implementation
To support importing companies, the Customs Support Group regularly offers free webinars in which experts provide practical guidance on how to efficiently implement data structures, supply chain communication, and CBAM reporting. Current dates and topics are available at www.customssupport.com/resources/webinars.
About Customs Support Group
Customs Support Group (CSG) is Europe’s leading independent provider of customs clearance and trade solutions, enabling seamless cross-border operations through cutting-edge digital innovation and deep industry expertise. With a presence in 14 European countries at major strategic locations, CSG offers the most comprehensive range of customs services in the market. Serving over 60,000 customers and backed by a team of 1,700 dedicated customs professionals, CSG helps businesses enhance operational efficiency and regulatory compliance in an increasingly complex trade environment.
For media inquiries, please contact:
Customs Support Group
Julia Verbunt
Email: julia.verbunt@customssupport.com
