CBAM: Carbon has a price—including for imports into the EU.

Economic theory has long been based on a simple idea: if the costs of the negative environmental and health impacts of goods and services are reflected in their prices, this creates an incentive to reduce those impacts. These are known as negative externalities, costs that would otherwise be borne by other people or society as a whole.

One example of this principle in practice is greenhouse gas emissions. In European industry, these have been priced since the introduction of the EU Emissions Trading System (EU ETS) in 2005. From 2026, this principle is being extended through the Carbon Border Adjustment Mechanism (CBAM) to selected goods imported from non-EU countries. For importers covered by the mechanism, the carbon footprint of products therefore represents a tangible budget item.

CBAM, or the Carbon Border Adjustment Mechanism, applies to selected goods in the iron and steel, aluminium, cement, fertiliser, electricity and hydrogen sectors. Whether a product falls within its scope depends on its specific customs classification codes. The aim of CBAM is to bring the cost of emissions embedded in imported goods closer to the costs borne by European producers and to limit the relocation of production to countries with less stringent climate policies.

Importers will have to cover the emissions embedded in imported goods by surrendering a corresponding number of CBAM certificates. Their price is based on EU ETS allowance auction prices. The final cost also depends on adjustments reflecting the free allowances allocated to European producers and on whether a carbon price already paid in the country of production can be taken into account.

Three dates are particularly important:

• 1 January 2026: The definitive CBAM period began, meaning that the financial obligation already applies to imports made in 2026.

• 1 February 2027: The sale of certificates will begin, including those required for imports made in 2026.

• 30 September 2027: The deadline for submitting the first annual CBAM declaration for 2026 and surrendering the corresponding number of certificates.

Companies therefore need to start collecting the necessary documentation now.

For cement, fertilisers, iron and steel, and aluminium, an exemption applies if the total annual imports of the relevant goods by a single importer do not exceed 50 tonnes per calendar year. However, this mass-based exemption does not apply to electricity or hydrogen.

The administrative and methodological requirements can be substantial. Companies need to determine the scope of their obligations correctly, obtain authorised CBAM declarant status and link customs data with emissions documentation provided by manufacturers. They can use either default values established by the European Commission or actual emissions data, which must be verified by an accredited verifier.

One practical example is the work carried out by CI3 for ELCON Bratislava to assess the import of steel structures from Türkiye. We reviewed the supplier's calculations, assessed the conditions for using emissions data and prepared three scenarios of expected costs. The work also included explaining deductions, the relationship between certificate prices and the EU ETS, and the responsibilities involved in customs representation. The outcome was an assessment and a calculation model to support budget planning.

CBAM connects emissions data with purchasing decisions and financial management. Importers should therefore focus on the quality of their documentation and anticipated costs already this year.

I also addressed the practical implications of CBAM as a trainer in the CBAM in Practice: Implications of the Carbon Border Tax training course organised by Seminaria. The course helps participants understand importers' obligations, how to work with suppliers' emissions data and how to prepare for the financial implications of CBAM. We see real value in this type of training and will very likely run it again in the future. We also plan to continue expanding our services in this area.

Related links:

EU ETS

CBAM

European Commission statement

European Commission guidelines apply

Exemption rules

Certificate price

Calculation principle

Detailed timelines and rules