The CBAM (Carbon Border Adjustment Mechanism) is an EU regulatory tool whose relevance to global trade will continue to grow over the coming years. Why? Because it introduces additional charges for CO₂ emissions related to the production of selected goods imported into the European Union. CBAM aims to reduce the relocation of energy-intensive production outside the EU to countries with less stringent climate policies. The mechanism covers goods from sectors with a high carbon footprint – primarily steel, iron, and aluminium, which dominate the import structure under CBAM. In addition, the regulation also includes cement, fertilisers, electricity, and hydrogen. It applies to imports from third countries that are not part of the EU Emissions Trading System (EU ETS). Exemptions apply to products originating from Iceland, Liechtenstein, Norway, and Switzerland – countries integrated into the EU carbon market.
Due to the reporting obligations, impact on pricing, and potential supply chain risks, CBAM poses a challenge for many companies – especially importers and industrial entities. This is why it is essential to partner with experts who not only understand the mechanics of CBAM but can also translate its complex requirements into clear actions and tangible business value.
Reporting comes first. Charges follow
Currently, CBAM is in a transitional phase, lasting until the end of 2025. During this period, importers are not yet required to pay CBAM-related charges but are obliged to submit quarterly reports on CO₂ emissions related to their imported goods. These reports must be based on actual emissions data provided by the producers. However, if the supplier is unable to provide such data, the importer must submit a report based on so-called “default values” (zero data). In practice, this approach may lead to an inflated level of reported emissions, and thus to higher costs once CBAM is fully enforced.
Importers are also required to document attempts to obtain actual emissions data. The lack of such proof, such as supplier correspondence, may trigger additional audits by the European Commission. Documentation confirming contact with suppliers should be properly archived and attached to each submitted report.
Starting in 2026, CBAM will enter its operational phase. In addition to reporting obligations, importers will be required to purchase special CBAM certificates, with the quantity dependent on the emissions embedded in the imported goods. Companies that begin implementing CBAM-compliant procedures now, such as collecting emissions data from suppliers, standardising reporting processes, and archiving documentation, will be better prepared for the upcoming regulatory obligations. This will directly reduce operational and cost-related risks.
Failure to prepare may result not only in financial penalties but also in the loss of CBAM authorised declarant status, which in practice means losing the right to import CBAM-regulated goods into the EU.
CBAM: upcoming simplifications and an expanded regulatory scope
In recent months, the European Commission announced changes under the Omnibus legislative package, aimed at simplifying certain administrative and reporting obligations under CBAM. These proposals are intended to ease the burden, particularly on smaller importers, while improving the transparency and predictability of the system.
One of the key changes is raising the reporting threshold to 50 tonnes of imported goods per year. This means that many small-scale importers will be exempt from quarterly reporting, significantly reducing the number of entities covered by CBAM obligations. In addition, procedures for importer authorisation, emission calculation methods, and data reporting standards will also be simplified.
From 2027 onward, importers will be able to declare emission-related costs already paid in third countries using published average national values. This aims to reduce the risk of double carbon taxation – both in the country of production and at the EU border. This change is particularly important for companies working with suppliers based in countries that already operate their own carbon pricing systems.
The Omnibus package also signals the next steps: CBAM will gradually expand to include additional sectors and products. As a result, more companies, also outside the currently regulated industries, should begin assessing how CBAM might affect their business operations in the near future.
Compliance means resilience and a competitive edge
At Rohlig SUUS Logistics, we understand the scale of the challenge. That’s why we provide comprehensive support to companies navigating CBAM compliance. Our experts actively monitor regulatory updates and legal interpretations, assist clients in preparing reports, collecting required data, and managing communication with suppliers. We also provide practical tools such as emissions data templates and correspondence forms to simplify the reporting process. What’s more, we support clients in exceptional cases, for example, when reports are delayed or data accuracy is in doubt.
CBAM is not just another environmental regulation – it represents a shift in the global trade paradigm. For some companies, it may become a barrier. But for those who prepare early and adapt strategically, CBAM can become a source of competitive advantage. The Omnibus package offers businesses some additional breathing room, but not an exemption from responsibility. That’s why having a partner who understands the complexity of this mechanism and can turn it into a business asset is more important than ever.
Expert comment: Dagmara Barwa, Deputy Customs Product Director, Rohlig SUUS Logistics
