CBAM and Procurement – When Uncertainty Becomes a Cost Factor

A new system, many questions

With the transition from a reporting regime to a fully operational certificate mechanism, one area of business is coming into sharper focus than before: procurement. Starting in 2026, CBAM will no longer only be about reporting – it will become financially binding. For purchasing teams, this means that decisions made today will impact not only tomorrow’s carbon footprint but also the balance sheet. In practice, this presents major challenges. The interplay between emissions data, certificate management, price forecasting and shifting legal frameworks makes it nearly impossible to define a clear path for procurement planning. Uncertainty becomes a permanent part of every purchase order.

2026 is not 2027 – and not 2025 either

One of the more confusing aspects is the unique character of 2026. While this year is officially the start of CBAM’s “definitive phase,” the recent Omnibus Initiative introduces a kind of transition period within that phase. Certficate prices will be calculated using quarterly averages after the fact, and purchases will begin only in February 2027. This means that decisions made today affect costs that won’t materialize for another 18 months – and whose precise magnitude won’t be known until then. As a result, uncertainty becomes systemic. Certificate management in 2026 follows different rules than those of the standard definitive phase. For companies preparing to implement a new control logic, this complicates not just the planning process – it raises operational questions as well: How can price risks be mitigated? What budgets need to be available, and when? And how can all of this be integrated into existing procurement processes?

Uncertain price factors

The fundamental challenge remains the same: companies purchase products without knowing the (verified) CO₂ content at the time of purchase. Verified emissions data will only be available retroactively, once production is complete or better: when the emissions monitoring period has ended. Whether and to what extent a supplier can provide verified data remains uncertain. In many cases, companies must work with estimates or expected values. The same goes for certificate prices. They are subject to fluctuation and can only be forecasted for the future. If you don’t hedge in time, or if certificates are not purchased - in the normal definitive phase - during the same week as the goods, you can only work within price corridors to estimate what you will end up paying. For procurement planning, this means decisions are based on multiple assumptions. Prices must be calculated within ranges that vary significantly by product group, country of origin, and market conditions. In economically challenging times, this level of uncertainty is especially difficult to bear – as it directly impacts margins, planning reliability and competitiveness across entire business units.

The relative share is increasing – and so is the pressure

In CBAM’s early years, the financial impact of carbon costs may remain modest. The mechanism is being introduced gradually, the certificate volumes are still limited, and the price per certificate carries less weight. But that is expected to change. As the system matures and prices rise, CBAM-related costs will take up a larger share of the total product price. What is a marginal variable today will soon become a key criterion in procurement. This means that companies investing early in high-quality emissions data, transparent supply chains and automated data analysis systems will be able to narrow their price ranges – and make more reliable and targeted purchasing decisions. The ability to not only track but also forecast CBAM costs will become a clear competitive advantage.

Conclusion

CBAM is not just reshaping the regulatory landscape – it’s also transforming the economic logic of procurement. Between retroactive data collection, delayed certificate purchasing and volatile pricing, many companies face a planning environment filled with uncertainty – one that can become increasingly costly. But those who prepare early for this new reality can gain clarity – and create room to maneuver. In the future, economic success in procurement will depend not only on price, but also on the strength of your data analysis.

Support with implementation

If you’d like to know how to adapt your procurement processes for CBAM or how to efficiently integrate emissions data, feel free to get in touch at helge@kolum.earth.