News in CBAM from 2026

CBAM is an EU tool designed to protect European industry from ‘carbon leakage’ – i.e. the relocation of production to countries with less stringent climate policies – while also encouraging emission reductions outside the EU. What can importers expect as we move into the next key phase, and what further changes is the European Commission planning?
 

End of transitional period and new obligations from 2026

The CBAM transitional period which began in October 2023 has ended. Until now, importers only had a reporting obligation, which involved the quarterly reporting of emissions associated with imported goods. New obligations apply from 1 January 2026.

• Registration as an authorised CBAM declarant: Only registered entities may import goods subject to CBAM. Under the Omnibus simplification, importers may continue to import after 1 January 2026 if they apply for authorised declarant status by 31 March 2026.
   
• Since goods subject to CBAM may only be imported by an authorised declarant from 1 January 2026, one of the TARIC certificates (e.g., Y238, which indicates that the entity applied for authorised declarant status before 31 March 2026) must be indicated in column 44 of the customs declaration. TARIC certificates are available on the customs administration website.
   
• Purchase and registration of CBAM certificates in quantities covering emissions released during the production of imported goods in third countries: The prices of certificates are linked to the price of emission allowances in the EU ETS. However, certificates will only be purchased from 1 February 2027, retroactively for 2026.
   
• Annual CBAM declaration: Importers will be required to submit an annual summary declaration of imported goods and their emissions. The first official report will have to be submitted by 30 September 2027.
   
• Refinement of the emissions calculation methodology: Importers must obtain accurate emissions data from their foreign suppliers.
   
• Possibility of recognising carbon tax paid outside the EU: If carbon tax has been paid in the country of origin, it can be deducted from the obligation to purchase CBAM certificates.
   

Extension of CBAM to other products from 2028

From 1 January 2028, CBAM will be extended to downstream products, i.e., products with a high steel and aluminium content, such as machinery, household appliances, industrial components, and others (a total of 180 items).

• 94 per cent of these products are industrial goods (e.g. basic metal parts, cylinders, radiators, casting machines).
   
• Six per cent are consumer goods (e.g. washing machines).

This should prevent production from being relocated to third countries and carbon-intensive products being imported back into the EU. At the same time, the Commission is tightening the rules to prevent the circumvention of CBAM. For example, it is introducing stricter requirements for tracking the origin and emissions of goods and seeking to strengthen the Commission's powers to deal with cases of circumvention.

Finally, it should be noted that the Commission has published an evaluation report on the CBAM transitional period (2023-2025), which confirms that CBAM is an effective tool for reducing emissions not only in the EU but thanks to international cooperation also in countries outside the EU. This can certainly be considered a first piece of positive news for 2026.