CBAM enters its final phase: New costs and obligations for industrial imports in 2026

 

The end of the transition phase: Carbon now has a price at the European border

 

From January 1, 2026, the stage of foreign trade in the European Union It has undergone a structural transformation. After the trial period ended on December 31, the final regulations have come into effect. Mecanismo de Ajuste en Frontera por Carbono (CBAMThis instrument, regulated by the Regulation (EU) 2023 / 956 and updated by Regulation (EU) 2025 / 2083It ceases to be a mere informational obligation and becomes a real and direct cost for companies that introduce emissions-intensive goods into the common market.

 

From this date onwards, the figure of authorized CBAM declarant It becomes indispensable. Customs authorities have been instructed to deny release for free circulation of any affected goods if the importer does not prove their status as an authorized operator or a valid exemption, which poses a critical risk to the continuity of the supply chain.

 

Affected sectors and operational requirements

 

The mechanism focuses on products whose manufacture has a high carbon footprint. Companies must strictly monitor their international purchases of the following materials:

 

  • Iron and steel industry: Steel and derivatives.
  • Metallurgy: Aluminum.
  • Construction: Cement.
  • Agriculture: fertilizers.
  • Energy: Electricity and Hydrogen.

 

To facilitate the transition, an exceptional deadline has been set until March 31th 2026 for those authorization requests that are already in process. However, the exemption threshold is extremely low: only imports that do not exceed the 50 net tons per year (excluding electricity and hydrogen), which forces virtually all industrial importers to comply with the standard.

 

The following details the key financial and administrative obligations that companies must meet:

 

Obligation Description and Deadlines
CBAM Certificates Mandatory purchase of certificates according to the emissions incorporated.
Annual statement Presentation of data on quantities and direct/indirect emissions.
Verification Emissions data must be validated by independent third parties.
First Installment The delivery of certificates for the 2026 emissions will take place in 2027.

 

Economic impact and strategic recommendations

 

El objetivo the Comisión Europea It is about preventing "carbon leakage" by equating the climate costs of imported products with those of domestic producers subject to the EU ETS (EU Emissions Trading System). The price of the certificates CBAM It will fluctuate according to the average of the weekly auctions of ETS, which introduces a new variable of volatility into purchasing budgets.

 

Entities like ChemSpain and various industry associations recommend that companies carry out a economic impact analysis Immediate. It is imperative to coordinate with foreign providers to obtain actual emissions data; otherwise, default values ​​will be applied, which usually increase the cost of the certificate.

 

Key points and frequently asked questions about CBAM in 2026

 

What happens if I don't have CBAM declarant authorization?

The customs of the European Union They will block the entry of your merchandise. The status of authorized declarant it is a requirement sine qua non to operate with the affected sectors from January 1, 2026.

When are the certificates actually due?

Although the obligation to register and calculate begins in 2026, the physical delivery of the certificates corresponding to the emissions generated this year must be carried out in the fiscal year 2027.

Does this cost affect all imports?

Only those that exceed the 50 net tons per year of the listed products. However, for the hydrogen and electricityThere is no minimum threshold; all imports are subject to the rule.

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