What is CBAM?
CBAM — the Carbon Border Adjustment Mechanism — puts a carbon price on certain goods imported into the EU. If you import covered products, you have new operational obligations: collect supplier emissions, calculate embedded emissions, and file quarterly declarations. From 2026, you'll also need to buy CBAM certificates.
Why this matters
CBAM is one of the first EU rules where the bottleneck isn't legal interpretation — it's operational. The hard part is getting accurate emissions data from non-EU suppliers, mapping CN codes correctly, and producing declarations a customs authority can audit. Most SMEs underestimate how long supplier engagement takes.
Who is concerned?
- EU importers of iron, steel, aluminium, cement, fertilizers, hydrogen and electricity (current scope).
- Companies that source semi-finished or finished goods made from CBAM-covered materials.
- Trading companies and distributors acting as the declarant of record.
- Procurement, supply chain and finance teams who own supplier relationships and customs.
Key operational implications
- Map every imported product to a CN code and check CBAM coverage.
- Identify the production installation behind each shipment, not just the supplier name.
- Collect actual embedded emissions from suppliers — direct and, where required, indirect.
- File quarterly declarations with the data and methodologies you used.
- Maintain audit-ready evidence: supplier letters, calculations, source data, version history.
- From 2026: register as an authorised CBAM declarant and purchase certificates against verified emissions.
Common mistakes
Defaulting to default values forever
Wrong CN code mapping
Treating suppliers as one black box
No audit trail
Timeline at a glance
- Transition phase (until end of 2025): quarterly reporting, default values still allowed.
- From 2026: definitive regime — actual emissions, authorised declarants, certificate purchases.
- Scope expansion: more sectors expected over the second half of the decade.
Practical example
An SME importing 200 tons of steel components per quarter from Türkiye must (1) confirm the CN code is in CBAM scope, (2) ask the supplier for installation-level emissions per ton, (3) calculate embedded emissions for the shipment, (4) file the quarterly declaration, and (5) keep the supplier letter and calculations as evidence. The same product from an EU mill is not in scope.
What companies should do next
- Run a CBAM applicability check on your import list.
- Build a prioritized supplier list (volume × emissions intensity).
- Send a structured emissions data request to your top suppliers.
- Set up a single source of truth for declarations and evidence.
- Plan for authorised declarant registration ahead of 2026.
Mission17 can help with
Operational support
- CN code mapping with CBAM coverage flags.
- Supplier emissions request workflows and reminders.
- Embedded emissions calculations with versioned methodology.
- Quarterly declaration assembly with full audit trail.
- Certificate planning and exposure forecasting.
FAQ
Are we exempt if our supplier is ISO 14064 certified?＋
No. Certifications help quality, but you still need actual installation-level emissions and the methodology behind them.
What if the supplier refuses to share data?＋
You can use default values during the transition phase, but you should document the request and escalate. Long-term, missing data becomes a sourcing risk.
Do we need a customs broker?＋
Brokers handle declarations, but CBAM responsibility sits with the importer. The data and evidence must come from you.
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