From 2026, eligible declarants under the definitive Carbon Border Adjustment Mechanism (CBAM) must account for emissions embedded in specified products and surrender certificates after relevant adjustments. Choosing actual verified emissions or European Commission default values can change calculated obligations and the competitiveness of imports.
The first annual declaration for imports made in 2026 is due by 30 September 2027. The European Commission’s August 2026 sector guidance covers production boundaries, precursor treatment, monitoring requirements and calculation methods.
Importers buying from relatively clean steel mills, aluminium smelters or fertiliser plants may have reason to establish a producer’s actual emissions intensity instead of using an unfavourable default. Different manufacturing routes can produce significantly different emissions profiles for steel and aluminium, making installation data quality commercially consequential.
Actual values are not established by a supplier’s unsupported environmental claim. Their use depends on meeting detailed methodology and verification requirements. Default values can simplify administration, but may conceal advantages from efficient equipment or lower-carbon energy.
A properly supported claim using actual values may lower a calculated obligation, but gathering the data can reveal missing production records, unverified precursor data or inconsistent allocation. Importers should secure contractual rights to documentation, verifier access and error correction before depending on a supplier. They should also reconcile customs quantities with emissions data attributed to the goods.
Electricity claims depend on evidence
The Energy Community Secretariat reported significant obstacles to power imports from non-EU neighbours in the first quarter of 2026. One obstacle was the use of country-level default factors even when exported electricity had been generated by hydropower.
Claims based on actual electricity emissions are subject to conditions involving contracts, grid connections, congestion and physical scheduling. A generator’s renewable label or guarantee of origin alone does not establish eligibility to use actual emissions values.
For supplier comparisons to be meaningful, importers need the same customs product and technical specification, verified emissions methodology, origin and production period. Better data can inform supplier selection, investment in cleaner production and price negotiations, extending its management value beyond tax compliance.
Incomplete evidence can result in both a higher carbon-related liability and an inability to explain that liability to the EU industrial customer that ultimately pays. These data and documentation requirements therefore affect how importers assess suppliers as well as how they calculate obligations.