CBAM: New rules, uncertain costs, and plant verification in focus

CBAM, which stands for Carbon Border Adjustment Mechanism, is the European Union’s mechanism that introduces a carbon adjustment at the border for certain imported goods. In practice, it aims to align the carbon cost embedded in imported products with the cost already borne by EU producers under the ETS system.

CBAM is entering a more concrete but also more complex phase for the companies involved. With the definitive phase starting on 1 January 2026, the key issue is no longer only regulatory compliance, but also the future cost outlook and the operational management of the new verification requirements along the supply chain.

The European Commission has already begun publishing quarterly CBAM certificate prices for 2026, with the first value set at 75.36 €/Ton Co2 for the first quarter. From 2027 onward, the mechanism will become even more dynamic, with prices calculated on a weekly basis, increasing cost volatility for importers.

An evolving framework

The latest developments confirm that CBAM is moving from a monitoring tool to a system with a direct economic impact. For companies, this means having to manage not only embedded emissions data, but also the effect of certificate prices on purchasing conditions and profitability.

A particularly important issue is the uncertainty surrounding the overall cost level in the medium term. At present, companies can only estimate the economic impact of certificates, because the pricing structure is still being refined and depends on the evolution of EU ETS auction prices and on the calculation rules that will become fully operational from 2027.

Plant verification

Another critical point concerns the verification of embedded emissions, which is becoming increasingly central in the definitive phase of CBAM. Declared emissions will need to be validated by an accredited third party and, in general, verification will also require a physical visit to the production plant, subject to limited exceptions.

This opens up another area of uncertainty for importing companies: in addition to certificate costs, the cost of certification and plant verification activities still needs to be defined more precisely. These costs may become significant, especially in more complex supply chains spread across multiple countries.

Impact on businesses

For operators in the sector, 2026 is only apparently a transition year. In reality, this is the period in which the elements that will truly affect costs in 2027 and beyond are being defined: certificate prices, data quality, verification, accreditation, and the ability of non-EU suppliers to provide reliable information.

In this context, it is essential to act early, collect the necessary data, and carefully assess suppliers and plants involved in CBAM-covered flows. Companies that prepare now will have a better chance of controlling the economic impact and reducing compliance risks.