The CBAM (Carbon Border Adjustment Mechanism), also known as CBAM, is one of the most relevant regulatory measures being implemented by the European Union to decarbonize international trade.
Its objective is clear: to equalize the cost of carbon emissions between products manufactured within the EU and those imported from third countries, thus avoiding the so-called carbon leakage and ensuring a more level playing field.
Since its entry into force in a transitional phase in October 2023, the CBAM has introduced new obligations for importers, especially in relation to the declaration of emissions associated with the goods.
From 2026, it moves into its final phase, incorporating a direct economic impact through the purchase of carbon certificates.
This regulatory change does not only affect the fiscal or environmental area. It has direct implications in:
📦 Management of imports and customs procedures
🌍 Selection and evaluation of international suppliers
📊 Traceability and availability of emissions data.
⚖️ The cost structure in the supply chain
In this context, understanding how CBAM works, which products are affected and what obligations companies must comply with is key to anticipate its impact and avoid operational or sanctioning risks.
What is CBAM (MAFC) and what is its objective?
The CBAM (Carbon Border Adjustment Mechanism) is a European Union regulatory instrument that establishes a border adjustment on the carbon emissions embodied in certain imported goods.
This mechanism obliges importers to declare the greenhouse gas (GHG) emissions associated with the production of the goods they bring into the EU and, at the final stage, to purchase CBAM certificates equivalent to the carbon cost they would have borne if those goods had been produced within the European territory.
CBAM is regulated by Regulation (EU) 2023/956, and is part of the “Fit for 55” legislative package, which aims to reduce EU net emissions by at least 55% by 2030.
Objective: avoid carbon leakage
It occurs when companies move production to countries with laxer climate regulations, or when European products are replaced by cheaper imports with a higher carbon footprint.
CBAM seeks to correct this distortion through two effects:
⚖️ Equalizing the cost of carbon between European and imported products
🌍 Incentivize emission reductions in third countries.
📉 Avoiding the relocation of carbon-intensive industries.
🏭 Protecting the competitiveness of industrial sectors within the EU.
Thus, the mechanism is not a traditional tariff, but a climate instrument with a direct impact on international trade.
Relationship with EU ETS and European Green Pact
The CBAM is directly linked to the EU ETS (EU Emissions Trading Scheme), which sets a price on carbon for industrial installations within the European area.
Until now, many of these industries received free allocations of emission allowances to avoid loss of competitiveness vis-à-vis third countries. However, this system generated an imbalance vis-à-vis imported products.
The CBAM acts as a complement to the EU ETS:
🔄 Replicate the cost of carbon in imported products.
📊 Based on the price of EU ETS allowances.
⛔ Progressively replaces free allowances in affected sectors.
All of this is part of the European Green Deal which seeks to transform the production model towards a climate-neutral economy.
In this context, CBAM is not an isolated measure, but part of a structural strategy that has a direct impact on import operations, logistics planning and international supplier management.
Which products and sectors are affected by CBAM?
Sectors included in the initial phase
In its current phase, the CBAM applies to a limited set of sectors characterized as highly carbon-intensive and at higher risk of carbon leakage.
The sectors included are:
🏭 Cement
⚡ Electricity
🔩 Iron and steel
🧱 Aluminum
🧪 Fertilizers
🧫 Hydrogen
These sectors have been prioritized because they combine two critical factors: a high level of emissions in their production process and a high volume of international trade.
Tariff codes and scope of the mechanism
The CBAM is not applied generically by sector, but to specific products defined by TARIC codes (based on the EU Combined Nomenclature).
This implies that:
📦 Not all products in a sector are necessarily included.
📑 The obligation depends on the exact tariff code declared to customs.
🔍 It is essential to validate whether a specific good is subject to CBAM.
For example, within iron and steel, the mechanism mainly covers:
-Commodity products (ingots, slabs, coils)
-Certain processed products (tubes, profiles, structures)
Many final products or complex manufactured products are left out for the time being, although this may change in future phases.
Possible future expansions
The CBAM is designed as a scalable mechanism. The European Commission has envisaged its progressive expansion in both scope and sectors.
The main lines of evolution include:
📈 Inclusion of new carbon-intensive industrial sectors.
🔗 Extension to transformed products and more complex value chains.
🌐 Integration with other climate regulatory instruments.
In addition, the phasing out of free allowances in the EU ETS (expected between 2026 and 2034) reinforces the need to expand the CBAM to maintain the consistency of the system.
For importing companies, this implies that the impact of CBAM is not static, but will increase in the coming years, affecting a greater number of products and operations.
How CBAM works: emissions, calculation and certificates
Declaration of Embodied Emissions
The central element of the CBAM is the quantification of greenhouse gas (GHG) emissions associated with the production of imported goods.
There are two types of emissions:
🌫️ Direct emissions: generated during the production process (e.g. combustion in industrial furnaces)
⚡ Indirect emissions: associated with the consumption of electricity used in manufacturing.
During the transitional phase, importers must report these emissions on a quarterly basis, based on:
➤ A ctual data provided by the manufacturer.
➤ Calculation methods established by the European Commission.
➤ Default values (only when no verified data is available).
The accuracy of this data is critical, as it will have a direct economic impact in the final phase.
Carbon adjustment calculation
The adjustment introduced by the CBAM is based on replicating the cost of carbon applied within the EU through the EU ETS.
The calculation follows a clear logic:
📊 Total emissions embodied in the product are determined.
💶 EU ETS carbon price (€/ton of CO₂) is applied.
⚖️ Any carbon costs already paid in the country of origin (if applicable) are deducted.
This avoids double taxation and ensures that the adjustment is proportional.
The result is the number of CBAM certificates that the importer must acquire at the final stage.
CBAM Certificates: what they are and how they are managed
CBAM certificates are the instrument through which the economic adjustment of carbon at the border is materialized.
Key features:
🧾 Each certificate represents 1 ton of CO₂ equivalent.
💰 Its price is linked to the EU ETS weekly average.
🏢 Must be purchased by authorized importers.
Importers shall be obliged to:
📥 Purchase certificates based on declared emissions
📊 Annually declare verified emissions.
♻️ Deliver the corresponding number of certificates
This system introduces a new layer of financial and administrative management in import operations.
Related content:
👉 🔗 EU Customs 2026: key changes to ICS2, CBAM and EUDR.
👉 🔗 Environmental Logistics or Green Logistics: What it is and Benefits
👉 🔗 EUDR Regulation. What it is, application and what it is for.
👉 🔗 EU-India Free Trade Agreement. Guide 2026
CBAM implementation: timetable and key obligations
Transitional phase (2023-2025): reporting obligations
The transitional phase of the CBAM began on October 1, 2023 and lasted until December 31, 2025. During this period, there was no payment obligation, but there was a clear requirement for periodic and rigorous reporting.
Importers must submit a quarterly CBAM report that includes:
📦 Quantity of imported goods by product type.
🌫️ Direct and indirect embedded emissions
🏭 Emission calculation method used.
🌍 Country and production facility information
💶 Carbon cost paid at source (if applicable)
This report must be submitted through the CBAM Transitional Registry, a platform provided by the European Commission.
The aim of this phase is to allow companies and authorities to
📊 Generate reliable emissions data.
🔧 Adjust internal reporting systems.
⚙️ Identify operational and compliance risks
Final phase (from 2026): real economic impact
As of January 1, 2026, the CBAM enters its final phase, incorporating a direct financial obligation.
Main changes:
💰 Importers must purchase CBAM certificates.
📊 An annual verified emissions statement will be mandatory.
🧾 CBAM authorized importer status will be required.
In addition, the number of certificates to be delivered will be adjusted according to:
➤ Actual verified emissions.
➤ Carbon pricing in the EU ETS
➤ Possible carbon costs already borne at source.
This change makes CBAM a key factor in the import cost structure.
Which companies are required to comply
The CBAM does not apply to all companies equally, but to those that play a specific role in the import.
They are obligated:
🏢 Importers established in the EU declaring goods for customs clearance
📑 Indirect customs representatives (when acting on their own behalf).
🌍 Companies introducing CBAM products from third countries
They are not directly obligated:
❌ Exporters outside the EU (although they must provide data).
❌ Logistics operators not acting as importers.
However, in practice, compliance with CBAM requires close coordination between importers, suppliers and logistics operators, especially with regard to obtaining and validating emissions data.
Current obligations for importers in the EU
CBAM quarterly report: what to report
During the transitional phase, importers must submit a CBAM report for each calendar quarter (Q1, Q2, Q3 and Q4), within the deadline established after the close of each period.
The minimum required content includes:
📦 Total volume imported by product type and TARIC code
🌫️ Direct emissions generated in production
⚡ Indirect emissions associated with electricity consumption (where applicable)
🏭 Identification of the production facility.
📊 Calculation method used (actual data, default values, etc.)
💶 Carbon price paid at source (if any)
Data quality is a critical point: although default values are allowed in certain situations, the European Commission is progressively limiting their use.
Role of the importer vs. foreign manufacturer
The obligor before the EU is always the importer. However, much of the necessary information depends on the manufacturer at origin.
This generates a clear operational dependency:
🏢 The importer is legally responsible for the report.
🌍 Emissions data must be provided by the manufacturer.
🔗 Traceability is required at the production facility level.
In practice, this implies:
📑 Requesting detailed technical information from suppliers
🔍 Validate the consistency of the data received.
⚙️ Establish internal collection and control processes
Without this coordination, the risk of non-compliance is high.
Risks and penalties for noncompliance
Failure to comply with CBAM obligations may result in significant financial penalties, even during the transitional phase.
Main risks:
⚠️ Failure to submit the quarterly report on time
📉 Incomplete or incorrect data declaration
❌ Failure to adequately justify the use of default values.
Sanctions are aligned with the EU ETS and can be placed around:
💰 Penalties per ton of CO₂ not correctly declared.
In addition to the economic impact, there are operational risks:
🚫 Blockages or incidents in customs procedures
📊 Increased level of inspection by authorities.
⚖️ Exposure to regulatory audits
The CBAM thus introduces a new compliance axis that combines environmental taxation, customs regulation and data control, with a direct impact on import operations.
Recent CBAM developments and regulatory developments
Recent updates and regulatory adjustments
Since its entry into force, CBAM has undergone technical and regulatory adjustments aimed at improving data quality and strengthening its practical application.
Among the most relevant changes:
📊 Increased demands on data quality: progressive reduction in the use of default values.
🔍 Strengthening of methodological requirements for the calculation of emissions.
🧾 Standardization of reporting formats within the CBAM Transitional Registry.
In addition, the European Commission has published additional technical guidelines for:
➤ Facilitate data collection by importers.
➤ Aligning criteria among Member States
➤ Reducing errors in the transient phase
The approach is clear: prepare the system for a final phase based on verifiable and auditable data.
Relationship with ICS2 and EUDR
CBAM does not operate in isolation. It is part of an increasingly demanding regulatory environment in terms of customs control, traceability and sustainability.
Two particularly relevant frameworks are:
ICS2 (Import Control System 2): European import security control system that requires advance declaration of data prior to the arrival of the goods.
EUDR (European Union Regulation against deforestation):: Regulation that makes it mandatory to demonstrate that certain products are not linked to deforestation.
Operational relationship with CBAM:
📦 Increase in the volume of data required for each import.
📊 Need for consistency between customs, environmental and trade information.
🔗 Integration of multiple regulatory systems into a single operational flow.
This implies that companies must evolve towards management models based on:
➡️ Structured information systems
➡️ Data validation processes
➡️ Coordination between departments (logistics, purchasing, compliance)
Increased customs control and traceability
The implementation of CBAM is raising the bar in terms of supply chain traceability.
Key aspects:
🔍 Accurate identification of the origin and actual producer
🏭 Linking emissions to specific installations.
📑 Consistency between data declared in CBAM and customs documents
This translates into:
📊 Increased level of inspection by authorities.
⚖️ Increased importer liability
🚫 Reduced margin for errors or missing information.
In this context, international logistics is no longer just operational, but also a data-intensive and compliance-intensive process, where the quality of information is as critical as the transport itself.
Impact of CBAM on international trade and logistics
Increased import costs
The CBAM introduces a new carbon-linked cost component that will directly affect imports from 2026.
This impact will depend on several factors:
💰 Emission intensity of the imported product.
📊 Carbon price in the EU ETS
🌍 Climate regulation in the country of origin
In practical terms:
🔹 Products with higher carbon footprint → higher CBAM cost.
🔹Suppliers without measurement systems → increased uncertainty and risk.
🔹Intensive sectors → more significant impact on margins.
This forces companies to integrate the cost of carbon into their pricing and procurement structure.
Supply chain reconfiguration
CBAM is driving changes in sourcing strategy globally.
Key trends:
🌍 Search for suppliers with lower carbon footprint
🔄 Relocation of sources of supply (nearshoring / reshoring).
⚖️ Evaluation of suppliers not only by cost, but also by emissions
This introduces a new criterion for decision making:
🔹Logistic cost + product cost + carbon cost
Supply chains are thus evaluated from an economic and environmental perspective simultaneously.
Traceability and data requirements
CBAM transforms data management into a critical element of logistics operations.
Key requirements:
📊 Access to reliable emissions data by product.
🏭 Identification of the production facility.
📑 Documentation aligned between supplier, importer and customs
This involves:
🔹Need for structured data management systems.
🔹Higher administrative burden on imports.
🔹Dependence on the quality of supplier information.
Without traceability, CBAM compliance becomes unfeasible.
Implications for customs processes
CBAM introduces a new layer of complexity to customs operations.
Main implications:
📦 Linkage between customs declaration and CBAM report
🔍 Increased level of control by authorities
⚖️ Need for consistency between commercial, technical and environmental data
In addition, the role of:
🔹Customs representatives.
🔹 Compliance systems
🔹 Pre-import validation processes.
Customs is no longer just a document control point, but has become a key node for environmental data verification, with a direct impact on the fluidity of operations.
How to prepare for the CBAM: operational keys
Document preparation and reporting systems
Adaptation to CBAM requires structuring an internal system capable of collecting, validating and reporting emissions data on a recurring basis.
Key elements:
📑 Identification of products concerned by TARIC code
📊 Definition of emission data sources.
🧾 Implementation of quarterly reporting procedures.
💻 Integration with internal systems (ERP, compliance, customs)
In addition, it is recommended:
🔍 Auditing the quality of the available data
⚙️ Standardize data collection formats
📈 Anticipating the economic impact in the run-up to 2026.
The goal is to avoid manual processes and reduce errors in an increasingly demanding environment.
Coordination with international suppliers
Compliance with CBAM is highly dependent on the supplier’s ability to generate reliable emissions data.
Critical aspects:
🌍 Request detailed information on production processes
🏭 Identify specific manufacturing facilities.
📊 Ensure calculation methodologies aligned with European standards.
Best practices:
🤝 Include CBAM requirements in contracts with providers
📑 Establish information exchange protocols.
🔄 Evaluate suppliers on the basis of their maturity in environmental reporting.
In many cases, it will be necessary to actively work with suppliers to raise their level of compliance.
Integration in logistic processes and compliance
CBAM should not be managed as an isolated process, but as part of the normal import operations.
This involves integrating it into:
📦 International purchase planning processes.
📊 Information flows between departments (logistics, purchasing, finance).
⚖️ Compliance and internal control systems
Key points:
🔗 Aligning CBAM data with customs declarations
📉 Minimize risks of errors or inconsistencies.
🚦 Establish pre-import controls.
Companies that integrate CBAM into their operations at an early stage will have a clear competitive advantage over those that manage it reactively.
The role of a logistics operator in the face of CBAM
Coordination of complex international operations
CBAM introduces new requirements that directly affect the planning and execution of international logistics operations.
In this context, the logistics operator acts as a coordination point between:
📦 Physical flows of goods
📊 Information flow (customs, technical and environmental)
🌍 Multiple stakeholders (importer, supplier, authorities)
Efficient management allows:
✔️Anticipar incidents before the arrival of the goods
✔️Alinear required documentation and data
✔️Reducir risk of blockage or delays at customs
Customs and regulatory compliance support
The current regulatory environment combines multiple frameworks (CBAM, ICS2, EUDR), which requires an integrated view of compliance.
The logistics operator adds value in:
📑 Pre-import documentation review
🔍 Verification of consistency between Customs and CBAM data
⚖️ Advice on applicable regulatory requirements
In addition, it facilitates adaptation to:
✔️Cambios normative continuous
✔️Nuevos reporting systems
✔️Exigencias of traceability
This reduces the operational burden on the importer and minimizes the risk of errors.
Integral vision of the supply chain
The impact of CBAM is not limited to an administrative process, but affects the overall design of the supply chain.
A logistics operator with an international focus allows:
🌍 Analyze routes and origins from a cost + carbon perspective.
📊 Integrating regulatory variables in decision making.
🔗 Coordinate different modes of transportation under the same operational criteria.
In this scenario, logistics is evolving towards a model where data management, regulatory compliance and operational efficiency are fully interconnected.
Having a specialized logistics partner facilitates this transition and allows you to operate with greater security in an increasingly demanding regulatory environment.
Across Logistics as a partner in the new challenges of international trade
The increasing regulatory complexity of international trade, with regulations such as CBAM, ICS2 or EUDR, requires increasingly precise management of information, customs processes and logistics operations.
In this context, having a specialized logistics partner makes it possible to operate with greater security, anticipate risks and guarantee regulatory compliance for each import.
Across Logistics works with a comprehensive approach that combines international transportation, customs management and regulatory knowledge, facilitating the adaptation of companies to an increasingly demanding and dynamic environment.
