The European Union’s Carbon Border Adjustment Mechanism (CBAM) is moving into a phase where company capacity to collect, verify, and reconcile emissions data across international supply chains will be central. A fact check published on 28 October 2026 by BusinessEurope examined practical issues for implementing the system. The review focused on operational challenges linked to carbon leakage concerns and industrial competitiveness.
BusinessEurope supports CBAM’s climate and competitiveness goals while questioning how consistently and proportionately it is implemented. Importers are expected to determine which customs codes fall within the mechanism’s scope and identify the responsible declarant. They also need to secure usable emissions information and reconcile reported data with the quantities of goods entering the EU. BusinessEurope said weaknesses in these steps can add compliance costs before companies begin purchasing certificates.
CBAM timetable for 2027 certificate sales and 2026 import reporting
The definitive CBAM regime entered into force on 1 January 2026. Certificate sales are scheduled to start in February 2027. The first annual declarations for goods imported during 2026, along with surrender obligations, are due by 30 September 2027.
The schedule creates a period between transactions that generate future CBAM liabilities and the later settlement of surrender obligations. Even though certificate payments follow later, companies must collect and maintain records during the current reporting period. Those records are intended to support emissions calculations used for CBAM reporting.
Customs declarations provide information on imported goods and quantities but do not independently establish embedded emissions from production. BusinessEurope noted that obtaining the required emissions information may involve manufacturing-process records, energy consumption data, clearly defined product boundaries, precursor information, and verification by an accredited body. It also highlighted that responsibilities can be distributed across specialised compliance teams within large industrial groups.
Smaller importers may depend on foreign suppliers whose monitoring systems were not designed for European verification needs. BusinessEurope’s review described how this can affect the availability of usable emissions data for CBAM purposes. The operational burden is therefore tied to both internal processes and supplier documentation.
Industry-specific administrative burdens across steel, aluminium, and cement
BusinessEurope said compliance workload differs across covered industries under CBAM. Cement producers may face fewer production facilities and product families. Steel distributors can manage numerous grades, dimensions, and customs entries.
Aluminium supply chains introduce additional distinctions between primary and secondary production routes. As a result, similar reporting requirements can translate into different administrative workloads depending on a company’s operating model. BusinessEurope said regulatory guidance should reflect these differences across industrial and trading structures rather than focusing mainly on large vertically integrated producers.
The number of declarations submitted was described as an incomplete indicator of implementation quality. A company may meet filing deadlines while using inconsistent quantities, outdated supplier documentation, or emission factors that lack adequate support. BusinessEurope pointed to other indicators such as the frequency of material corrections and the share of emissions claims backed by appropriate verification.
The review also referenced competent authorities’ ability to investigate and resolve discrepancies. Evidence from the first compliance cycle could help regulators and business associations identify where targeted adjustments may be needed. BusinessEurope linked these points to how operational performance is assessed during early implementation.
Supplier emissions data quality and verification requirements
BusinessEurope said access to reliable emissions information varies among importers. Companies with multiple qualified suppliers may be able to use standardised reporting templates and contractual warranties covering information quality. Smaller manufacturers relying on a single overseas producer may have less negotiating power over data requirements.
Where suppliers cannot provide complete and verifiable data, importers may need to use applicable default values or consider changing sourcing arrangements. BusinessEurope added that having emissions data available is not sufficient on its own because information must withstand assessment by a verifier. It also noted possible scrutiny by the relevant competent authority after reporting.
This distinction affects both credibility of reported emissions and importers’ commercial position. Where actual production data cannot be substantiated adequately, BusinessEurope said compliance calculations may not reflect producers’ real emissions performance. The review therefore connected supplier documentation quality with outcomes in CBAM reporting.
50-tonne threshold limits small importers but not larger compliance complexity
The EU introduced a mass-based threshold of 50 tonnes for relevant goods, which reduces the number of small-volume importers subject to CBAM obligations. Electricity and hydrogen are treated separately from other covered goods under the mechanism described in BusinessEurope’s review.
BusinessEurope said exemptions for smaller importers do not remove administrative challenges faced by larger businesses managing hundreds of customs codes or sourcing products from multiple installations. It highlighted that improved digital interfaces, clearer definitions of responsibilities, and better coordination of customs enforcement remain important for effective implementation.
The review described these measures as addressing operational difficulties without necessarily changing CBAM’s underlying carbon requirements. It linked implementation effectiveness to how companies manage responsibilities across customs processes and emissions data handling rather than only changes in coverage thresholds.
Simplification proposals tied to documentation, verification, and surrender impacts
BusinessEurope framed regulatory simplification as a way to reduce unnecessary administrative work while avoiding weakening the carbon signal CBAM is designed to deliver. It warned that poorly designed exemptions or relaxed evidence requirements could allow suppliers to obscure emissions information or shift production toward products outside CBAM scope.
At the same time, excessive administrative complexity could disadvantage efficient producers whose data-management systems are not yet sufficiently developed. Potential improvements identified in the review include clarifying documentation and verification requirements, introducing proportionate risk controls, and retaining scrutiny where emissions claims materially affect certificate surrender numbers.
For company directors, BusinessEurope described CBAM compliance as extending beyond sustainability reporting into procurement, finance, information technology, and customs management. The review stated that companies need clear accountability for the declarant role, maintain supplier-by-supplier inventories of emissions data, document review of reported figures, and define escalation procedures when suppliers fail to provide required information.
BusinessEurope’s 28 October review placed these operational questions at the centre of discussion as the EU approaches first certificate-related obligations for 2026 imports.