EU CBAM: What Every Importer Needs to Know Before the Full Phase-In.

The Carbon Border Adjustment Mechanism (CBAM) is an EU regulation designed to prevent 'carbon leakage' — the risk that EU companies shift production to countries with weaker climate rules to avoid the cost of the EU Emissions Trading System (ETS). By placing a carbon price on certain goods imported into the EU from non-ETS countries, CBAM levels the competitive playing field.

The mechanism entered a transitional reporting phase in October 2023 and moved to full financial enforcement on 1 January 2026. For freight importers moving physical goods from China or other non-EU countries in the covered sectors, this is now an active compliance and cost obligation — not a future planning item.

CBAM applies at EU Customs Union borders and covers goods in the following CN (Combined Nomenclature) code chapters as of 2026:

EU importers — specifically authorised CBAM declarants, which from 2026 means any EU-based importer of affected goods — must purchase CBAM certificates from a national authority to cover the embedded carbon in their imports. The price of a CBAM certificate is pegged to the weekly average auction price of EU ETS allowances.

At the current EU ETS price of approximately €55–€65 per tonne CO₂ equivalent, a consignment of 100 tonnes of structural steel with an embedded carbon intensity of 1.8 tCO₂/tonne would require certificates worth approximately €9,900–€11,700. The actual cost depends on the verified emission intensity reported by the supplier — which is why supplier carbon data collection has become a logistics and procurement priority.

The most urgent action for importers of affected goods is supplier engagement. Many Chinese steel and aluminium producers are now familiar with CBAM and can provide carbon intensity declarations, but the quality varies significantly. Forwarders and 3PLs with China-side presence can assist with supplier outreach and documentation collection.

For companies importing small volumes of affected goods as components of wider shipments (e.g., aluminium extrusions as packaging or structural elements), the threshold de minimis level (€150 intrinsic value per consignment) may exempt some shipments — but legal advice specific to your commodity and volume is essential before relying on this.

It is also worth modelling the landed cost of CBAM certificates across your import programme now, particularly if you are budgeting for 2026–2027. The EU ETS price has traded between €50 and €100 in the past 18 months; build sensitivity into your models.