CBAM from 2026: European Commission publishes new milestones

CBAM enters the next phase

As the end of the transitional phase approaches, the European Commission has adopted the most comprehensive legislative package on the Carbon Border Adjustment Mechanism to date. The mechanism is no longer under development – it is now almost fully defined in legal terms. Key elements have now been specified: potential further product coverage, pricing of certificates, emissions monitoring and verification, as well as the impact on customs declarations. This edition provides a detailed overview of the latest changes that will shape the system in the long term.

Expansion of the CBAM product scope to further processed goods

The Commission has published a draft that extends the scope of CBAM to a wide range of further processed goods. From 2028 onwards, the mechanism will no longer apply only to basic materials such as pig iron, aluminium, cement or fertilisers, but also to more complex products and intermediate goods. These include, among others, pipes, wires, foils, fasteners and various semi-finished and finished products. A list of the relevant customs tariff codes is available. Importing companies should identify affected goods as quickly as possible on the basis of the revised codes and carry out a new impact assessment. This expansion closes a loophole in climate protection that has existed since the introduction of CBAM. Including emissions embedded in further processed products ensures that the carbon price at the border reflects the entire value chain. Without this measure, incentives would have arisen to relocate energy-intensive processing steps abroad in order to avoid costs. The new rules prevent this circumvention mechanism and strengthen competitiveness within the EU.

Pricing of CBAM certificates

The Commission has finalised the method for setting the price of CBAM certificates. The price will be directly linked to the average auction price of EU Emissions Trading System allowances. In 2026, prices will be set on a quarterly basis, and from 2027 on a weekly basis. As a result, the CBAM certificate price will reflect as closely as possible the actual CO₂ costs borne by European producers. The calculation will be carried out centrally by the Commission and published regularly to ensure planning certainty for companies. Aligning CBAM pricing with the EU ETS strengthens the market-driven nature of the mechanism.

Standard values and the role of verified emissions data

Already during the transitional phase, companies were required to obtain and report actual emissions data. This obligation remains in place. From 2026 onwards, while companies formally have a choice under the regulation, economic considerations will strongly encourage the use of actual, verified emissions data. The Commission has published conservative standard values with a gradually increasing surcharge. This incentive mechanism is clearly designed to promote the shift towards verified production data from third countries. Standard values are increasingly losing their function as a permanent reporting option. The longer they are used, the higher the assumed emissions burden and thus the number of CBAM certificates required. Companies are therefore incentivised to cooperate with their suppliers or organise independent verification. The Commission makes it clear that the long-term objective is the comprehensive use of verified, installation-level emissions data.

Adjustment to the phase-out of free allocation

With the gradual phase-out of free allocation under the EU ETS, the Commission has introduced a new procedure for calculating CBAM costs. This takes into account the extent to which a comparable product within the EU still benefits from free allocation. The calculation is carried out using a technical process that incorporates benchmarks, correction factors, as well as data on precursor products and production routes. For complex products with multiple components, a step-by-step back-calculation along the value chain is applied. This ensures that neither double charging nor double relief occurs. Importing companies gain transparency regarding the future development of their payment obligations and can carry out long-term planning on a sound basis. However, the use of actual benchmark values also leads to increased information requirements vis-à-vis suppliers.

Accreditation and requirements for CBAM verifiers

The Commission has completed the legal framework for the accreditation of verification bodies. The new implementing regulation sets out detailed requirements, including expertise in specific product groups, quality assurance systems and experience in emissions reporting. Each verification body must be accredited for defined CBAM activities and have documented procedures in place. Verification teams consist of lead auditors and independent reviewers. Oversight of verifiers is carried out by national accreditation bodies, coordinated at EU level. This establishes a uniform quality standard that strengthens the credibility of emissions data and ensures fair verification in a European and international context. At the same time, it highlights that start-up difficulties are likely, especially in the initial phase. It remains to be seen whether sufficient verification capacity will be available to ensure that willing suppliers can obtain verification before the deadline for submitting the first CBAM declaration.

Technical improvements to the CBAM registry and new rules for declarants

The digital CBAM registry has been further developed technically to support full implementation. New functionalities include, among others, the delegation of reporting obligations, the automatic calculation of thresholds, and access for accredited verifiers. In addition, the interface with the customs system has been improved to avoid duplicate data entry. At the same time, the rules for authorised CBAM declarants have been revised. Companies can now import goods even while their registration is still under review, provided certain conditions are met. Competent authorities have been given greater clarity regarding the approval, suspension or withdrawal of registrations. These measures aim to reduce administrative burden and ensure legally secure participation in the system.

Conclusion

Many key building blocks are now defined – from product scope and pricing to verification and customs processes. From 2026 onwards, a binding framework will apply to importers, authorities and trading partners. The coming year will be characterised by adjustment and implementation, but also by opportunities for companies that actively engage with the system. Those who act now can not only minimise risks but also build competitive advantages. If you would like to analyse how these changes affect your supply chains or reporting strategies, feel free to contact me directly at helge@kolum.earth. We are happy to support you.