CarbonComplyEU CBAM · Carbon Border Adjustment Mechanism
The definitive phase is live. Here's what it actually requires.
What changed on 1 January 2026
The transitional phase only asked EU importers to report embedded emissions. The definitive phase makes three things binding at once.
EU CBAM · where you are now
- Oct 2023
- Transitional phase begins
- Reporting only — no certificates.
- Jan 2026
- Definitive phase begins
- Authorisation, verified reporting and certificate obligations are binding.
- Sep 2027
- First certificates due
- Declare and surrender certificates for emissions embedded in 2026 imports.
Authorisation
EU importers of covered goods must hold authorised CBAM declarant status before they can bring your product in.
Verified reportingsource
Actual emissions figures — as opposed to EU default values — must be signed off by an accredited verifier who visits the installation.
Certificatessource
Certificate sales begin 1 February 2027. The first declaration and surrender deadline is 30 September 2027, for emissions embedded in 2026 imports.
What a filing actually requires
Not a sustainability dashboard — a specific, auditable figure in the shape the EU asks for.
Embedded emissions, per good, per installation
Calculated with the CBAM methodology for your sector — direct and indirect emissions from production, tied to the specific installation that made the goods, not a company-wide average.
A verifiable evidence chain
Production volumes, fuel and energy consumption, and purchased electricity, each traceable back to source documents — because an accredited verifier will ask.
Adjustment for carbon price already paid
Any carbon price you've already paid in India on the same emissions is deducted from what's owed in the EU — you need that paid-price evidence on file too.
The EU's declaration format
Your importer files through the CBAM registry, in the Commission's structure — a number in a spreadsheet doesn't satisfy it.
The supplier-data problem
Your embedded-emissions figure isn't just yours. It includes the emissions your own upstream suppliers embedded in what they sold you — scrap, alloys, clinker, intermediate goods. If they don't give you a number, the EU supplies one for you: a default value calculated to sit above the real global average. You end up certifying for a dirtier plant than the one you actually used.
How CarbonComply solves it
We send each supplier a tokenised link — no account, no login — where they enter their own specific embedded emissions and supporting documents. The moment that's verified, your calculation switches from the EU default to their actual figure. You chase your supply chain without chasing anyone by phone.
What you get
A CBAM report in the EU's shape
Ready for your importer to file, not a summary they have to reformat.
Supplier declarations, chased automatically
Tokenised links, no login, tracked until each one responds or lapses.
A hash-chained audit trail
Every input, every calculation step, immutable — your verifier gets read-only access to the whole chain.
The same data, run for CCTS too
If you're also an obligated entity under India's CCTS, the same plant data produces that figure as well — see CCTS.
Questions we actually get asked
- Is the transitional phase still running?
- No. The transitional phase (reporting only) ran from October 2023 to December 2025. The definitive phase started 1 January 2026 and is the phase you're in now — authorisation, verified reporting and certificate obligations are all binding.
- How much will CBAM certificates actually cost in 2026?
- Less than the eventual full exposure. The number of certificates you owe is reduced by the free allocation still granted to EU producers of the same goods, and that free allocation is being phased out gradually — a factor starting at 2.5% in 2026 and rising to 100% (no offset left) by 2034. Your bill grows every year through 2034; it does not arrive all at once.
- What happens if my suppliers won't give me emissions data?
- Your declaration falls back to the EU's default values for that good — figures set above the real global average, so you pay for a worse plant than the one you actually bought from. This is the single biggest lever most exporters have on their own CBAM cost, and it depends entirely on suppliers who have no EU account and no reason to log into anything.
- Who can verify our embedded emissions?
- From 2026, only an independent verifier accredited by an EU national accreditation body can sign off on actual (non-default) emissions data — and verifiers are required to visit the installation. The first CBAM verifiers are expected to be accredited around September 2026.
- Which sectors does CBAM cover?
- Cement, iron & steel, aluminium, fertilisers, electricity and hydrogen.
Not sure where your exposure stands?
Run the numbers yourself, or talk to us — either way, get a real figure instead of a guess.