CBAM

 

The Carbon Border Adjustment Mechanism (CBAM) has been in force since 1 January 2026. It requires businesses that import iron, steel, aluminium, cement, fertilisers, electricity or hydrogen to purchase CO₂ certificates for the embedded emissions in their products. Those who are unprepared will face a financial impact – in certificate costs, penalties or operational disruption at the border.

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CBAM in practice

CBAM is a European mechanism that places a CO₂ price on certain imported goods, equivalent to the price EU producers pay under the Emissions Trading System (ETS). The aim is to prevent carbon leakage and create a level playing field for European industry.

‍The requirement applies to EU importers that import more than 50 tonnes of CBAM goods per year. They must register as an authorised CBAM declarant, report the embedded emissions and surrender CBAM certificates annually. The first CBAM declaration and certificate surrender for 2026 imports is required before 30 September 2027.

What challenges do businesses face?

CBAM requires detailed emissions data at product level from suppliers outside the EU. In practice, such data are often unavailable, or not in the required form. Businesses can fall back on default values, which are generally set conservatively. Those who hold primary supplier data therefore pay for fewer certificates in most cases. The financial impact of that choice can be considerable.

‍In addition, CBAM requires an internal process for data collection, reporting and certificate management that many organisations have not yet put in place.

Which businesses does this affect?

  • Importers of iron, steel, aluminium, cement, fertilisers, electricity or hydrogen
  • Businesses with suppliers outside the EU that cannot yet provide verified emissions data
  • Organisations that want to quantify and manage the financial impact of CBAM
  • Businesses that want to adjust their procurement strategy to reduce CBAM costs

Our approach

Pantarein guides you through the entire CBAM compliance journey: from the first impact analysis to the operational set-up of reporting and certificate management.

We work in four steps:‍


  1. CBAM impact analysis – We map which of your import flows fall under CBAM, the expected scale of the embedded emissions, and the indicative certificate costs based on current ETS prices.
  2. Supplier data and emissions calculation – We help you choose between primary supplier data and default values, and substantiate the financial impact of both options. Where primary data are available or obtainable, we guide this process, or we calculate the embedded emissions – in line with the CBAM methodology.
  3. Reporting and registration – We support the CBAM reporting to the European Commission and registration as an authorised CBAM declarant, including the annual declaration before 30 September of the year following the import.
  4. Procurement strategy and cost management – Based on the impact analysis, we assess whether and how your procurement strategy can be adjusted to structurally reduce CBAM costs – through supplier selection, shifting sourcing origin or product substitution.

What does it deliver?

  • Compliance certainty: timely registration, correct reporting and no operational disruption at the border
  • Cost management: a substantiated choice between primary data and default values, with a direct financial effect
  • Procurement insight: a clear picture of CBAM exposure by supplier and product group
  • Strategic options: substantiated choices on supplier selection and procurement strategy based on CO₂ impact
  • Future-readiness: a CBAM process that is ready for expansion to new product categories

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Ready to get CBAM under control?

‍CBAM is in force. Those who act now keep costs under control and avoid disruption. Pantarein guides you from impact analysis to operational compliance.

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