CBAM – Carbon Border Adjustment Mechanism made simple
Facts, obligations and checklist for EU importers
CBAM affects companies that import certain carbon-intensive goods into the European Union and requires them to provide detailed emissions data and register in the CBAM system. In the coming years, the purchase of CBAM certificates will also become mandatory.
On this page, you’ll find the most important facts and figures around CBAM.
What is CBAM – in a nutshell?
The Carbon Border Adjustment Mechanism (CBAM) is the EU’s carbon border adjustment system. For certain imported goods, a comparable carbon price will have to be paid to match the price charged for equivalent products manufactured in the EU under the EU Emissions Trading System (EU ETS). The goal is to prevent carbon leakage and encourage more climate-friendly production worldwide.
Which products fall under CBAM?
CBAM starts with six particularly carbon-intensive sectors:
- Cement
- Iron and steel
- Aluminium
- Fertilisers
- Hydrogen
- Electricity
The EU is already assessing an extension to additional products and downstream value-added stages. CBAM is therefore not just a raw materials topic – it will affect many supply chains in the medium term.
Who is affected by CBAM – directly and indirectly?
Directly affected by CBAM: EU importers
Legally, only companies based in the EU that import CBAM goods into the European Union are directly obligated.
This includes, for example:
- Manufacturing companies that import raw materials or precursors
- Trading companies that import finished CBAM goods into the EU
- Any other companies in the EU that release these goods for free circulation
These companies are required to register in the CBAM system, report emissions data and, from 2026 onwards, purchase and surrender CBAM certificates.
Indirectly affected: suppliers outside the EU
Manufacturers in third countries have no direct CBAM obligation towards the EU. In practice, however, they cannot avoid CBAM:
- Their EU customers need robust emissions data in order to meet their CBAM obligations.
- Without this data, importers must fall back on default values, which are often less favorable – and therefore more expensive.
The consequence:
Suppliers who cannot provide transparent, verified emissions data will gradually lose competitiveness.
Practical example:
A German automotive supplier importing steel parts from Türkiye is directly subject to CBAM: they must register, report emissions data and later surrender certificates.
The Turkish steel producer is indirectly affected: they need robust, installation-level emissions data and must provide it to their EU customer. If they don’t, the EU importer has to work with default values – or, in the medium term, look for alternative suppliers.
When does CBAM apply – and which deadlines matter?
CBAM is being introduced in two steps:
- Importers report the embedded emissions of their CBAM goods on a quarterly basis.
- No CBAM payments are due yet.
- As an importer, you must register by March 31, 2026 at the latest in order to continue importing.
- Start of certificate sales for the year 2026: February 2027
- Deadline for the first annual CBAM declaration (for 2026): 30 September 2027
How do companies register for CBAM?
Question: Where and how do companies register for CBAM?
Registration is carried out via the CBAM Register (CBAM Transitional Registry), which is operated by the European Commission.
National responsibility is key:
- Companies contact the National Competent Authority (NCA) in their Member State (for example, in Germany: the German Emissions Trading Authority – DEHSt).
- The NCA reviews the application and activates the company in the CBAM Transitional Registry.
- Access is usually provided via the national customs/CBAM portal or via the EU customs portal (TAXUD).
Without this registration, companies will no longer be able to regularly import CBAM goods into the EU from 2026 onwards.
Registration link: Taxation and CBAM Registry and Reporting
Simplification: what does the 50-tonne threshold mean?
With the so-called omnibus package, the CBAM rules have been simplified. The key point:
- Companies that import less than 50 tonnes of CBAM goods per year will, from 2026, be largely exempt from CBAM obligations.
According to the European Commission, this means that:
- around 90% of importers (especially SMEs) will be exempt from CBAM obligations,
- while over 99% of emissions will remain covered via large import volumes in the system.
For many industrial companies with substantial material flows – for example in steel, aluminium or fertilisers – CBAM will nevertheless remain fully relevant and effective.
Why CBAM is almost impossible without supply chain transparency
CBAM is not just a question of customs or tax – it is a data and supply chain topic:
Companies need to:
- know which products contain CBAM-relevant materials,
- collect structured information from suppliers – ideally at component and material level,
- consolidate material and emissions data in a single system that also covers other regulatory requirements such as REACH, RoHS, SCIP, battery and packaging legislation.
Companies that create transparency early can:
- reduce risks (e.g. misreporting, penalties),
- plan carbon-related costs more effectively,
- actively manage their product and corporate carbon footprint.
How Substantio supports you with CBAM
CBAM presents companies with two very practical challenges:
They need reliable data from their suppliers – and a structured report that allows them to link this data to their own volume and sales figures. This is exactly where Substantio comes in.
In Substantio, CBAM is implemented via a standardized supplier questionnaire. Your suppliers receive the request directly from the software and provide information including:
- Country of Origin
- Production process and installation
- Direct and indirect emissions (CO₂) of the supplied raw materials or precursors
All responses are collected centrally in Substantio and are available for evaluations and documentation.
Based on the supplier responses, Substantio generates a CBAM report covering all raw materials that must be declared.
This report shows transparently:
- which raw materials are CBAM-relevant,
- which countries they come from,
- with which emissions values they are imported into the EU.
This gives you the data backbone you need for your CBAM filings.
The raw material report generated in Substantio can then be mapped to your import and sales figures (for example from your ERP system). This allows you to:
- assign CBAM-relevant emissions to actual import volumes and products,
- better assess CBAM-related cost impacts at product or customer-group level.
In short:
Substantio helps you collect the key raw material and emissions data from your suppliers, turn it into a structured CBAM report – and provides the foundation for linking this report to your own sales figures.
Want to know how to set up your material and supply chain data so that you’re well prepared for CBAM and other requirements?
Wichtige Links & offizielle Ressourcen
European Council, Press release, CBAM: Council signs off simplification to the EU carbon leakage instrument
Reuters, EU’s carbon cost rules are changing: how companies can prepare for CBAM
Conclusion: CBAM is a C-suite topic – and a matter of your material data
CBAM is changing the rules for carbon-intensive imports into the EU. Companies that act now secure a clear advantage:
- analyze relevant products and import volumes,
- prepare registration as a CBAM declarant,
- structure supply chains and emissions data,
- establish digital processes and tools for repeatable data and compliance management.
FAQ's
Is CBAM mandatory?
Yes. CBAM is laid down in
and is therefore directly applicable in all EU Member States – similar to REACH.
Does CBAM also apply to small importers and SMEs?
In principle, yes. However, with the new 50-tonne threshold, many smaller importers will be exempt from obligations as long as their annual CBAM imports remain below this limit.
What happens if no emissions data is available from the supplier?
In that case, importers generally have to rely on default values – these are usually conservative and often lead to higher CBAM costs. Companies that request robust emissions data early reduce this risk.
Does CBAM apply only to raw materials or also to finished products?
For now, CBAM focuses on a clearly defined list of goods (for example specific steel, cement or fertiliser products). In the medium term, an extension to additional – especially downstream – products is being discussed. Companies should therefore factor CBAM into their strategic planning early.
